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 https://www.osha.gov.

March 17, 1993

Mr. Walt Hodwanes
7051 S.R. 40 W.
Ocala, Florida 34482

Dear Mr. Hodwanes:

This is in response to your letter of January 10, concerning your inquiry as to whether the Occupational Safety and Health Administration (OSHA) has any rulings or requirements for employees in the electrical trade to wear steel-toe shoes.

We noted in your letter that you do not wear anything metal, such as rings, watches, and other pieces of jewelry, and that your continuing employment with the company depends upon your wearing of safety shoes.

OSHA has no specific requirement for employees in the electrical trade to wear safety-toe shoes. The employer may require employees to use personal protective equipment (PPE) to comply with the employer's established safety rules, so long as the PPE itself does not present a hazard.

OSHA does not generally consider the wearing of steel-toe shoes by electrical tradesmen to be hazardous, so long as the conductive portion of the shoe is not in contact with the employee's foot and is not exposed on the outside of the shoe. One option you and your employer may wish to consider is the purchase of non-metallic safety footwear that provides both foot protection and is non-conductive.

We commend your long history of working safely by not wearing conductive articles while performing electrical work. As you may be aware, OSHA prohibits, under 1910.333(c)(8), Safety-Related Work Practices standard, the wearing of conductive articles of jewelry and clothing which might contact exposed energized parts, unless the articles, if worn, are rendered nonconductive by insulating means.

Enclosed are copies of our PPE general requirements standard found at 29 CFR 1910.132, our foot protection standard found at 1910.136, and our electrical safety-related work practices standard found at 1910.331 through 1910.335.

If you have any additional questions, please feel free to contact James C. Dillard, a member of my staff, at (202) 219-8031.


Roger A. Clark, Director
Directorate of Compliance Programs