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.

February 18, 1994

Mr. Gilbert Perry
835 Sherman Farm Road
Harrisville, Rhode Island 02830

Dear Mr. Perry:

Thank you for your inquiries of March 1 and 3, 1993. In your letters you request an interpretation of a "rule 5100" regarding footwear. You also questioned whether or not "over the shoe rubbers qualify as acceptable footwear, according to rule 5100. We apologize for the delay in responding to your request.

The Occupational Safety and Health Administration (OSHA) does not have a rule "5100". Enclosed is OSHA's foot protection standard 29 FR 1910.136 which requires that the American National Standard Institute (ANSI) standard for Men's Safety-Toe Footwear, Z41.1-1967 be met. This ANSI standard requires that the safety shoes meet a compression test and an impact test. The best way to determine if the ANSI standard requirement has been met by the shoe manufacture is to look for the "ANSI Z41.1" marking in the shoe.

OSHA does not accept rubber over-shoes as acceptable foot protection when there is exposure to foot injury due to weight falling on the employees feet although such footwear may be worn over acceptable foot protection.

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

Sincerely,



Rolland E. Stroup, Chief
Division of Safety Abatement Assistance