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.

November 17, 1993

Ms. Patricia H. Falls
Executive Vice President
Firstline Safety Management, Inc.
P.O. Box 230
Lovettsville, Virginia 22080

Dear Ms. Falls:

This is in response to your letter of September 7 requesting an interpretation of Occupational Safety and Health Administration (OSHA) standards applying to foot protection. I apologize for the delay in responding to your inquiry.

With regard to whether steel-toed and steel-shanked tennis shoes would be suitable for use at a construction site, please be advised that if the protective footwear meets the requirements and specifications in the American National Standard Institute (ANSI) consensus standard Z41.1-1967 for safety-toe footwear, the shoes would be considered by OSHA to be suitable for use at construction sites for those situations that do not require special foot protection. However, specific site conditions may also warrant the need for metatarsus protection or protection from hazardous liquids, sparks or electric shock.

Please note that ANSI Z41-1991 has replaced ANSI Z41.1-1967. The Agency will not cite if the shoes used meet the current standard (Z41-1991) even where there are differences between the 1967 and 1991 standards.

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

Sincerely,



Roy F. Gurnham, Esq., P.E.
Director
Office of Construction and Maritime
Compliance Assistance



September 7, 1993

Office of Construction and Maritime
Compliance Assistance
U.S. Department of Labor-OSHA
Room N 3610
Washington, D.C. 20210

Attention: Roy Gurnham

Reference: Steel-Toed/Steel-Shanked Tennis Shoe

Dear Mr. Gurnham:

For construction sites, is the steel-toed and steel-shanked tennis shoe suitable?

Sincerely,



Firstline Safety Management, Inc.
Patricia H. Falls
Executive Vice President