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.

September 20, 1993

Jerry Zebor
Senior Safety Engineer
Johnson Controls
World Services, Inc.
Bangor Support Project J-80
Naval Submarine Base Bangor
Silverdale, WA 98315

Dear Mr. Zebor:

This is in response to your letters of May 26, June 4, and July 28 requesting an interpretation of the 29 CFR 1910.132(a) (Personal Protective Equipment, General Requirements), phrase "...shall be provided...". Please accept our apologies for the delayed response.

You are correct in your conclusion that "...the employer has responsibility to facilitate the provision of certain PPE (including footwear) and insure its use."

The current standard does not state that the employer must purchase and distribute protective footwear "...with no cost to the employee". This question has been raised several times since the inception of OSHA, and it has normally been considered a labor/management relations matter, resolved through formal or informal negotiations between the affected parties.

It is the responsibility of the employer to evaluate the workplace for hazards that could result in foot injuries. If a hazard cannot be removed by engineering, or administratively controlled in the workplace then personal protective equipment would be required.

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


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