The anatomy of the foot is extremely complex with 26 bones, 30 joints, 19 muscles and over 100 ligaments. In conjunction to the complexity, the feet, like the hands, are body extremities which are not naturally well protected. This opens the feet up to a high potential and severity of injury if not protected correctly.
The workplace offers numerous hazards to the feet including falling objects, stepping on sharp objects, objects rolling over or onto the feet, slips, trips and falls, chemical exposure, electrical current, extreme cold and wet environments. According to the Bureau of Labor Statistics (BLS), more than 60,000 foot injuries per year result in lost work days. The BLS also cites a study of foot injuries that found 75% of the injuries occurred when workers were not in compliance.
According to the National Council on Compensation Insurance, foot injuries cost employers an average of $9,600 per lost work day and a serious foot injury can have a dramatic effect on the quality of life both at work and at home.
All employers have a legal duty to protect their employees from hazards in the workplace. The following steps should be taken to prevent sprains, strains, cuts, broken bones, burns and amputation foot-related injuries.
1. Hazard Assessment
OSHA standard 1910.132 (d) (1) states that the employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE).
Considerations for hazard assessments:
- Frequency of exposure to injury. How often is the employee exposed to the hazard?
- Severity of potential injuries – How bad of an injury could occur?
- Company’s accident experience with foot injuries. Are your insurance claims in line with the industry or above average?
- Industry best practice – What do your competitors do?
2. Proper Selection of PPE
If the finding of the hazard assessment determines that foot hazards are present, or likely to be present, OSHA standard 1910.132 (d) (1) (i) states that the employer shall select and have each affected employee use the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment.
OSHA also spells out the construction design standards for protective footwear under 1910.136 (b) (1) (i) which must comply with American Society of Testing Materials standard ASTM F2412-11. Standard Test Methods for Foot Protection is broken down into seven categories:
- Impact resistance for the toe area of footwear (I/75)
- Compression resistance for the toe area of footwear (C/75)
- Metatarsal protection that reduces the chance of injury to the metatarsal bones at the top of the foot (Mt/75)
- Conductive properties which reduce hazards that may result from static electricity buildup, and reduce the possibility of ignition of explosives and volatile chemicals (Cd)
- Electrical Hazard by stepping on live wire (EH)
- Static dissipative (SD) properties to reduce hazards due to excessively low footwear electrical resistance that may exist where SD footwear is required.
- Puncture resistance footwear devices (PR)
3. Written Plan
The new policies and procedures from the previous two steps should be updated in your corporate Safety and Health Manual under the PPE section. Clear policies and procedures are the foundation of your safety program.
4. Proper Training
Once the hazard assessment, proper selection of PPE and written plan are completed the employees must be trained on these three aspects. OSHA 1910.132 (f) states that each employee shall be trained to know at least the following:
- When PPE is necessary
- What PPE is necessary
- How to properly don, doff, adjust, and wear PPE
- The limitations of the PPE
- The proper care, maintenance, useful life and disposal of the PPE
5. Disciplinary Action
As with all safety programs, the foot protection policy and procedures must be inspected for compliance and change in hazards. If an employee who has been trained demonstrates that they are lacking the understanding and skills relating to proper foot protection, it is the employers responsibility to provide retraining to that employee. If employees are found deliberately breaking the policy and procedures for foot protection, the progressive disciplinary action should be used.