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.

July 12,1993

Mr. Mark E. Grundman, President
M. G. Grundman & Sons, Inc.
906 North Seventh Street
P.O. Box 404
Vincennes, Indiana 47591

Dear Mr. Grundman:

This is in response to your letter of March 17, addressed to OSHA, and a follow-up to your telephone conversations of June 11 and 15 with Camille Villanova of our staff. You asked for information about the use of your custom shoes in an industrial environment where safety footwear is required. The telephone conversation covered several topics which are summarized below:

o The OSHA standards address requirements for employers and employees in the workplace.

o Methods of abatement of hazards should be developed in the following priority order:
1) engineering controls

2) administrative controls

3) personal protective equipment.

If a hazard cannot be removed by engineering, or administratively controlled in the workplace then personal protective equipment would be required.
o The OSHA standards reference the ANSI (American National Standards Institute) consensus standards for the design and testing specifications of safety-toe footwear.

Note: these consensus standards were originally published as the "USA Standard for Men's Safety- Toe Footwear", Z41.1-1967, and are now titled "American National Standard for Personnel Protection-Protective Footwear", Z41-1983.

The current publication is available from:
American National Standards Institute
1430 Broadway
New York, New York 10018
212-642-4900.
o The availability of materials for toe caps and sole puncture resistance were discussed.

o The ANSI committee was discussed. The name of OSHA's ANSI Z41 committee member is as follows:
Ms. Audrey Best
OSHA, Directorate of Safety Standards Programs
200 Constitution Avenue, NW
Room N3609
Washington, D.C. 20210
(202) 219-7216.
o Information about the leadership of the ANSI Z41 committee was also given to you. Mr. Dale Haskin is the Secretary of the ANSI committee and can be reached at:
The National Safety Council American National Standard for Personnel Protection-Protective Footwear, Z41-1983 Committee Post Office Box 558 Itasca, Illinois 60143 1(800) 621-7619

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,

Raymond E. Donnelly, Director Office of General Industry Compliance Assistance