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 http://www.osha.gov.

October 4, 1984

Mr. Joel I. Keiler
Attorney at Law
P.O. Box 3326
McLean, Virginia 22103

Dear Mr. Keiler:

This is in response to your letter of September 10, concerning the Occupational Safety and Health Administration's (OSHA) requirements for safety shoes.

Enclosed are copies of the appropriate sections of the Occupational Safety and Health Standards for General Industry. Section 1910.132, page 270, and Section 1910.136, page 276, are the regulations dealing with foot protection. As you will note, the requirement to wear foot protection (Section 1910.132(a)) does not address a worker's occupation, but rather addresses the hazard. The activities and environment of the worker must be evaluated to determine if there is a foot hazard in the form of objects likely to be dropped or likely to fall on his or her feet. If this hazard is present, then foot protection must be worn.

Secton 1910.136 addresses the design of safety shoes and requires them to meet American National Standard for Men's Safety-Toe Footwear, Z41.1-1967. This standard requires that the safety shoes meet a compression test and an impact test. It does not specify the means by which to reinforce the shoe to pass the test. Steel toe boxes are the prevalent means used, however, fiberglass has been used in some cases. The best method to determine if the requirement has been met is to look for a marking in the show "ANSI Z41.1." As a matter of information, OSHA does accept protective footwear designed and marked in accordance with later editions of the ANSI Z41.1 standard.

If we can be of further assistance, please contact us.

Sincerely,



Barry J. White
Director, Directorate of Safety
Standards Programs