OSHA’s requirements for foot protection [1910.136] occupy about a quarter of a page. The entire focus is on ensuring employees wear protective footwear. There is no mention of properly alternating footwear to avoid cushion compression and, thus, chronic stress on the structures of the feet.
Simply following the OSHA requirements will not keep employees’ feet safe. It’s partly because PPE is the tail end of hazard elimination. It’s the last of six control strategies, as outlined in NFPA 70E Table F.3:
- Hazard elimination.
- Substitution.
- Engineering controls.
- Awareness.
- Administrative controls.
- PPE.
Hazard elimination
Suppose Jim is absentmindedly standing behind a fully loaded lift truck and it backs up over his foot. The weight over that tire exceeds the crush limit of the cap in Joe’s work boot toe. Or maybe it’s his arch that gets run over. In this example, Joe did not need to be there.
In many cases, a hazard can be eliminated by simply not being where you are not required to be. Having a chat next to a drinking fountain poses a different hazard level from having the same chat while standing in front of an open fuse cabinet in the medium voltage transformer pen.
If a motor is being lifted or lowered, there’s no reason for someone to stand there to steady the load. If you have incorrectly set up the lift, you need to set the motor back down and fix the problem. Standing there likely puts your feet directly in the fall path of the motor. If something goes wrong with the lifting gear or the equipment being used to lift the motor, your shoes will not be enough protection.
You can eliminate the hazard by simply walking away from the danger zone before the lift begins. In fact, the person operating the lifting device should insist that everyone be clear of the area first.
Many times, hazards exist because of clutter, incorrect storage (e.g., pipe racks being used incorrectly), or other practices that unnecessarily produce a foot hazard. Scrap wood is a big offender here. Your OSHA-compliant shoes are not designed to repel nails that you might step on. Other foot-piercing hazards may be present at your facility or job location; identify and, if possible, eliminate them.
Substitution
The parts needed for repairs on Line 4 come in a 70-lb tote. It’s awkward and people often have difficulty setting it down without just dropping it. Crushing force to the dorsal parts of your feet (the parts facing up when you are standing) is one danger, even though your toes are protected because you wear the mandatory OSHA-compliant shoes. However, your back could be strained, resulting in mechanical changes that later manifest in foot injuries such as a hairline stress fracture.
The solution here is divide up that repair kit. Nobody is going to do all possible repairs on one visit, so why have a single kit for that purpose? One way to lighten it up is to convert at least part of it from a tote you lift and carry to a locker located near Line 4. Replacing the tote bin with a wheeled tote or cart is even better.
A similar thing has occurred with toolboxes. Today’s mobile tech often uses a ballistic construction backpack instead of a bulky toolbox. Multi-purpose tools further reduce the weight of what you might drop on your foot or strain your back with.
Engineering controls
This typically means adding guards and interlocks. For a purely electrical situation, you might install a plexiglass cover over energized terminals in a control cabinet. But what about a foot safety situation?
Consider a big scrap grinder with an open chute. You’ve got to replace a photoeye; to do that, you’ll be standing very close to that chute. Even with everything de-energized, you can suffer a painful injury such as a broken metatarsal bone or sprained ankle if you step into space over that chute opening and fall in. A piece of plywood could be laid over the chute opening, or perhaps an equipment modification can be made to slide a cover into place when the unit is in any mode other than fill mode.
Awareness
This usually means posting signs about hazards in the local area. An example is a sign that says, “Keep hands and feet at least 18 in.” In many cases, a sign should not be necessary. Simply being aware of where your feet are and applying common sense should suffice.
For example, you are riding shotgun in a company golf cart. Dangling your right foot over the edge of the passenger deck could be very bad for your foot if your pal who is driving the cart scooches just barely past a steel column on your side.
Watch where you’re going, and watch where you’re standing.
Administrative controls
When planning a job, keep foot safety in mind. For example, the work is near pallets of parts used in production; this means extra lift-truck traffic near where the work is. Ask if those pallets can be relocated ahead of when the work starts and for the duration of the job.
PPE
This is where the OSHA requirements come in. PPE is in the category of “when all else fails,” not “so you don’t have to do anything else.” Ensure you have not failed to fully implement the other strategies. You want to create a situation in which PPE is not actually needed, but you wear it as an added layer of protection in case something goes wrong. And things go wrong all the time.
Chronic issues
Note that these controls were designed with acute injury in mind. What about chronic injury, which is common with feet? What other issues can arise even when OSHA-compliant footwear is on your feet?
Poor posture distorts the natural spring in your posterior chain. The most common posture problem today is head forward. It’s so common because people spend hours each day craning their head forward over a phone screen, toward a computer screen, or even toward the terminals they are terminating to.
A chiropractor can analyze your neck for the degree of head forward and provide specific exercises you can do at home, though you are likely to need chiropractic treatments to correct years of head forward posture.
Incorrect usage cycles result in shoes that do not adequately cushion and poor putaway practices result in shoes that harbor mold, fungus, and/or other critters that destroy the shoe, stink, and unnecessarily expose your feet to pathogens.
Never wear the same pair of shoes two days in a row. Wash socks between uses, and replace them when they wear thin.
When you take your shoes off at the end of the day, spritz inside them with some white vinegar and let them air dry. This is something you should do with any shoes in which you exert yourself: running shoes, climbing shoes, weightlifting shoes, golf shoes, etc. And it’s true for those well-polished shoes you were dancing in at your cousin’s wedding.
Many people who spend their day walking on cement floors also have chronically tired and achy feet. Healthy feet might feel a little tired or achy now and then, but if your feet always feel that way, see a podiatrist. Bring your work shoes with you.
Many people with achy feet forego the podiatrist visit and opt for heavily cushioned sneakers. This actually exacerbates many kinds of foot problems. Going the opposite route, wearing sneakers with thin padding or, even better, going barefoot where practical and safe, will allow your feet to properly flex as they were meant to.
