Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

December 10, 1979

Mr. V. R. Wallace
525 Hibiscus Blvd.
Merritt Island, Florida 32952

Dear Mr. Wallace:

This is in response to your recent inquiry regarding the approval and use of "PRO-TEK-TO" safety toe caps. We apologize for the delay in response.

The OSHA standard 29 CFR 1910.132(a), (copy enclosed), outlines the general requirements for protection of extremities. However, it is the employer's responsibility to determine the particular type of personal protective footwear needed.

The standard requires that foot protection be used whenever it is necessary by reason of hazard of processes or environment which could cause foot injury. The employer should determine which, if any, of his employees are exposed to the foot injury hazard. This does not mean that those employees requiring foot protection are required to wear foot protection at all times when working. When employees are exposed to the possibility of foot injuries, foot protection shall be worn. When employees are not exposed to possible foot injuries, the foot protection is not required by the OSHA standard, which then becomes solely a matter of employment conditions existing between the employer and his employees.

When foot protection is required, it shall be such that it does not offer an accident hazard in itself. For instance, it may be inappropriate to wear a clip-on toe guard in certain situations such as in climbing, working at high levels, or near areas containing exposed live parts of electrical circuits or equipment. Thus, it is the responsibility of the employer, prior to the OSHA inspection, to evaluate with good judgment the foot injury hazards of the specific situations and activities in which he may involve his employees, and decide whether foot protection is required and, if so, what type is needed to be worn without introducing another, perhaps graver, accident hazard.

I hope this information will be of help to you. If we may be of any further assistance, please feel free to call or write.


Grover C. Wrenn Director,
Federal Compliance and State Programs