How to Toe the Line and Help Foot the Bill for Safety Costs

Economising on safety costs is something fewcomply with the criteria set forth in ANSI
would argue with either. So, here's a safety shoeZ41-1991, replaced by the American Society for
alternative you should know about.Testing and Materials (ASTM) F2412-05 and
Rubber overshoe safety toe caps - ' shoes withASTM F2413-05, or the employer may opt to
toes' - are getting more attention, for moredemonstrate that other criteria are equally
reasons than simply cost-effectiveness. And noteffective. If the employer pursues the second
just because of the ever increasing numbers ofoption, then compliance with the consensus
temporary workers employed in this country. It'sstandards is not mandatory. This means, the
the ever increasing cost of providing fully-loadedburden lies on the employer to demonstrate that
temporary safety shoes that's bringing the wholethe footwear provided is equally as protective as
matter of toe protection to the attention ofthe footwear that meet the ASTM F2412-05 and
senior management. The recent challenge by thethe ASTM F2413-05 standards.
United States Postal Service and OSHA's rulingIn another fairly recent ruling, OSHA declined to
attests to that. Anywhere a safety shoecomment on the suitability of the now ubiquitous
alternative exists, that sits all right with OSHA in‘Croc’ clogs. It said, in situations where no
the USA or CCOHS in Canada, it's a win-winhazard exists, the matter of appropriate
situation.footwear at work is between the employer and
There’s not a thing wrong with generallyemployee. This principle was reiterated when
accepted safety toe cap footwear, but all tooOSHA was asked to comment on rubber
often it seems the expensive choice is selectedover-shoes. OSHA was firm in stating that it does
out of fear or a lack of understanding. Althoughnot find rubber overshoes acceptable where they
it's true to say safety shoe policies inprovide no toe protection. However, provided
manufacturing have embraced rubber pull onthey can demonstrate that they meet minimum
safety toe cap products for visitors they havestandards they are acceptable.
been 'missing in action' elsewhere. I know of oneWhat then would be “acceptable foot
particular food processing plant that refuses toprotection” where there is a chance of toe
use a '”better than those yellow clackerinjury? The first choice of many employers is
things” solution, but tolerates gunk that mightASTM or CSA tagged safety shoes or boots -
be introduced to the production floor on the solesthe so called "approved" footwear we hear so
of visitors' shoes. Their thinking is they had bettermuch about in advertising. For sure, a fully loaded
address the greasy floors than more effectivelysafety shoe or boot will provide more than
provide toe protection. Some might argue theenough legal defence in the event of a challenge
greasy floor is a hazard that should not befrom OSHA. What is also true is that such a
tolerated.policy comes at a very high cost. Not every
All employers are subject to statutoryemployee requires safety toecap, steel-soled,
requirements and minimum standards that reflectelectricity dissipative footwear. For many work
our desire to protect workers. It is up to thesituations only toe protection from falling or rolling
employer to implement safety rules andheavy objects is required. Is it wise then to incur
regulations but bodies such as OSHA allowsthe full cost of a safety shoe or boot?
significant latitude in doing so, provided choices areFor example, an office worker visiting a loading
reasonable and done responsibly. Careful attentiondock to pick up documents will not perform any
is required as errors in judgement, as with willfulmanufacturing duties while en route. This might
neglect, will be punished under the law.imply that the PPE provided to the workers may
Unfortunately, the tendency in a fear andnot be necessary for the office worker.
compliance atmosphere is to avoid failure ratherHowever, since the office worker might be
than attempt success. Compliance isexposed to falling objects, or in close proximity to
commendable but can instill fear. That can stifleheavy moving equipment, it would be reasonable
creativity which can result in unnecessarily highto foresee only the need for toe protection
costs.against impact and compression.
Take the whole matter of safety footwear.In another situation a risk assessment for the
Company safety policies that lack creativity canproduction area might indicate the need for slip
result in over-spending far in excess of the typicalresistant footwear and toe protection. However,
fine for a safety transgression. It's a bit like this;it is also reasonable to expect that a visiting office
we know there's always the possibility of rain butworker might not encounter slippery conditions.
do we need to wear a raincoat every day? Or,Furthermore, such conditions are not supposed to
would a small umbrella, costing a lot less than apersist and it might be reasonable to expect the
raincoat, do the job just as well? Throw in theoffice worker to take reasonable evasive action
ability to offer others shelter if the need arisesto avoid the risk should it occur.
and you get the idea.The danger from sharp objects underfoot
An employer is required to provide personalrequires steel sole protective footwear but where
protective equipment where the risk assessmentno such risk is anticipated toe protection may be
indicates as much. Risk assessment is theall that is required. A good example would be the
cornerstone of industrial safety and statutorypaper-making and the newspaper print production
bodies require employers to undertake one toindustry, where there is little chance of sharp
determine what hazards can reasonably beobjects but always a chance of rolling stock or
expected in any particular working environment.heavy moving equipment that can injure toes.
There is always the chance of accident but riskHaving steel sole shoes or boots that can
assessments are not expected to be clairvoyant.dissipate electrical shock is just over-kill and costly.
They are expected to review routine operationsRubber safetytoe overshoes provide the same
and recommend the proper Personal Protectiveprotection from impact and compression as
Equipment. (The employer is also expected to paysafety shoes and boots. The steel toecap meets
for it.) Risk assessments are expected to bethe same ASTM standards and can easily be
'reasonable' and the onus is on OSHA to proveverified by test results from the major testing
otherwise.bodies. This is what makes OSHA happy. Rubber
There are two important things to remember.has been used for a long time in the safety
Firstly, it is the employer who decides how bestfootwear industry and its slip resistance qualities
to comply with the law. Secondly, organizationsare well known. The rubber material is flexible but
like OSHA do not mandate any particular piece ofsturdy, in some cases as thick as 6mm resulting
equipment to be used.in a firm fit and some long wearing characteristics.
In the case of foot safety, OSHA’sRubber safetytoe overshoes are a lot less
occupational foot protection standard is 29 CFRexpensive than safety shoes or boots and they
1910.136. This requires the use of protectiveeliminate the hazard of passing along unsanitary
footwear when employees are working in areasfootwear. They are especially useful where only
where there is a danger of foot injuries due tooccasional toe protection is required, such as with
falling or rolling objects. Once that hazard hasvisitors to production facilities, temporary workers
been determined, OSHA does not recommend, orand for medical reasons.
approve of, any particular safety footwear.Safety personnel looking for budget savings, as in
According to OSHA in a recent letter to thetoday’s economy, would be well advised to
United States Postal Service, an employer mayconsider them for these reasons and more.