Protective footwear requirements

Employers must ensure employees wear protective footwear when they work where there is a danger of foot injuries from falling or rolling objects or from objects piercing the sole. See the requirement in 1917.94(a).

• This is a hazard-based requirement: if the work area presents those specific hazards, footwear is required.
• If those hazards are not present in an area, 1917.94(a) does not mandate footwear there, but employers should still assess and control other foot hazards.1917.94(a)

Protective footwear that complies with any of the listed consensus standards in 1917.94(b)(1) is acceptable: ASTM F-2412-2005 and ASTM F-2413-2005, ANSI Z41-1999, or ANSI Z41-1991. See 1917.94(b)(1) and its subparts 1917.94(b)(1)(i), 1917.94(b)(1)(ii), and 1917.94(b)(1)(iii).

• The ASTM pair (F2412/F2413) are the modern test methods and performance specs referenced in the rule (1917.94(b)(1)(i)).
• Employers can choose any of these consensus standards as a baseline for compliant footwear.1917.94(b)(1)

Yes — footwear not constructed to those exact consensus standards can be used if the employer demonstrates it is at least as effective as footwear made to one of the listed standards. See 1917.94(b)(2).

• Demonstrations of equivalence usually include manufacturer test reports, third-party test data, engineering analyses, or certification showing equal or superior performance to the listed standards.
• Keep the equivalence documentation on file so you can show compliance during inspections.1917.94(b)(2)

Yes — OSHA accepts footwear that meets ASTM F-2412-2005 and ASTM F-2413-2005 because those standards are incorporated by reference in 1917.3 and are listed in 1917.94(b)(1)(i).

• When you rely on ASTM F2412/F2413 compliance, manufacturers’ test reports that reference those specific ASTM tests are direct evidence of conformity.
• Incorporation by reference means OSHA recognizes those consensus standards as meeting the performance expectations in Part 1917.1917.94(b)(1)(i) and 1917.3.

Yes — 1917.94 explicitly lists ANSI Z41-1999 and ANSI Z41-1991 as acceptable consensus standards, so footwear meeting either older ANSI version complies with the rule. See 1917.94(b)(1)(ii) and 1917.94(b)(1)(iii).

• If you use footwear certified to those ANSI editions, retain the manufacturer’s certification or labeling showing the ANSI standard referenced.
• If you prefer to use newer consensus standards, you also may, but ensure you have evidence that the footwear meets performance requirements.1917.94(b)(1)(ii)-(iii)

No — employers must provide required personal protective equipment at no cost to employees in most cases; they may not make employees bear the cost of PPE the employer is required to provide. See the OSHA interpretation on employer payment for PPE at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 which explains payment rules that apply to Part 1917.

• The 2014 interpretation states employers may use deposit systems or require return of employer-owned PPE, but the employer cannot shift the net cost of required PPE to the employee.
• Keep written PPE policies and receipts showing the employer provided the footwear to demonstrate compliance.https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and 1917.94.

Yes — an employer may use a refundable deposit system for PPE they own, provided the system does not effectively charge the employee for required PPE or circumvent the payment rule. See the employer payment guidance at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and the protective footwear rule at 1917.94.

• The deposit is allowed if the employer retains ownership and repays the deposit when the PPE is returned, or otherwise recovers the cost without imposing wear-and-tear charges related to work.
• Document the deposit policy in writing and make repayment procedures clear to avoid an involuntary cost to the employee.https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and 1917.94.

An employer may recover the cost of employer-owned PPE that an employee fails to return, but must do so in a way that complies with federal, state, and local law and the payment rule; the employer cannot charge employees for ordinary wear and tear caused by workplace conditions. See the PPE payment interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and 1917.94.

• Before making payroll deductions, check and follow applicable wage and hour laws and any written agreements authorizing deductions.
• Document attempts to retrieve the footwear and the basis for any charge (e.g., replacement cost if the item was willfully kept), and do not charge for damage that resulted from normal work use.https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13 and 1917.94.

Acceptable evidence includes manufacturer test reports using recognized test methods, third-party laboratory test results, engineering evaluations comparing performance, and certifications showing equal or superior performance to the listed standards. See 1917.94(b)(2).

• Use recognized test methods (for example, ASTM test methods referenced in 1917.94(b)(1)(i)) whenever possible.
• Keep written equivalence documentation on file and available for inspection.1917.94(b)(2)

1917.94 itself does not list specific labeling requirements, but the consensus standards referenced (for example, ASTM or ANSI) include manufacturer marking and labeling provisions; using footwear labeled to those standards is a straightforward way to show compliance. See 1917.94(b)(1)(i)-(iii).

• If you rely on a manufacturer’s marking that cites the ASTM or ANSI standard, retain the manufacturer’s certification or labeling as proof.
• For nonstandard footwear demonstrated equivalent under 1917.94(b)(2), keep the equivalence documentation in lieu of standard markings.1917.94(b)(1)

Yes — 1917.94(a) requires protective footwear only when there is a danger of foot injury from falling or rolling objects or objects that can pierce the sole; in a low-hazard area without those dangers the rule does not require protective footwear. See 1917.94(a).

• Conduct a hazard assessment to determine where the specific hazards exist; post clear rules for where protective footwear is required.
• Even in low-hazard areas, employers should evaluate other potential foot hazards (slips, chemicals, electrical exposure) and provide appropriate controls.1917.94(a)

Composite toe caps are permitted if the footwear meets one of the acceptable consensus standards or is demonstrated to be at least as effective as a listed standard. The rule focuses on performance, not the specific material used. See 1917.94(b)(1) and 1917.94(b)(2).

• Many ASTM- or ANSI-rated boots use composite toes that meet the required impact and compression tests.
• Keep documentation showing the toe cap material met the performance criteria in the referenced standard.1917.94(b)(1)

A hazard from objects that could pierce the sole (for example, nails, metal shards, or sharp debris on the deck) triggers the need for puncture-resistant footwear under 1917.94(a). See 1917.94(a).

• Choose footwear that meets puncture-resistance performance in one of the consensus standards (for example, the performance tests in ASTM/ANSI footwear standards listed in 1917.94(b)(1)).
• If using alternate footwear, document test results showing equal or better puncture resistance per 1917.94(b)(2).

No — if the employee is working in an area that presents the hazards described in 1917.94(a), the employer must ensure the employee wears protective footwear while performing that work. See 1917.94(a).

• Employers must supervise and enforce the footwear requirement and provide replacements if footwear becomes damaged.
• Allowing removal in hazardous zones would fail to protect the employee and could lead to citations.1917.94(a)

Not necessarily — OSHA has advised that some "designated waterfront facilities" (used solely for bulk storage, handling, and transfer of liquids or gases) may fall outside the scope of certain Part 1917 requirements; employers should verify which standards apply at their specific facility. See the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31 and review 1917.

• The 2017 interpretation explains that whether Part 1917 or Part 1910 applies depends on how the facility is classified under the regulation.
• If Part 1917 does not apply, employers should determine which OSHA standards do apply to the operation and still follow applicable PPE and hazard controls.https://www.osha.gov/laws-regs/standardinterpretations/2017-05-31 and 1917.

No — a manufacturer’s claim alone is weak evidence; compliance under 1917.94(b)(2) is best supported with objective proof such as third-party test reports, laboratory results, or engineering comparisons showing the footwear is at least as effective as one of the listed consensus standards. See 1917.94(b)(2).

• Ask the manufacturer for test certificates referencing the specific ASTM or ANSI test methods or independent lab reports.
• Keep the equivalence documentation available for inspections and to support your hazard controls.1917.94(b)(2)

Not automatically — footwear that complied with one of the standards listed in 1917.94(b)(1) or that you have demonstrated is at least as effective under 1917.94(b)(2) remains acceptable until you need to replace it; you are not required to retroactively replace footwear solely because a newer standard edition is published. See 1917.94(b)(1) and 1917.94(b)(2).

• For purchases after a standards update, prefer footwear certified to the latest consensus methods or retain equivalence documentation.
• Keep records showing why currently used footwear continues to meet the performance needed for identified hazards.1917.94(b)(1)-(2).

1917.94 does not specifically require a training program for protective footwear, but employers are responsible for ensuring PPE is used properly, which in practice means providing instruction on when footwear is required, proper fit, inspection, and care. See 1917.94.

• Good practices include training on how to inspect footwear for damage, how to clean and maintain it, and when to report or replace damaged footwear.
• Document any training as part of your hazard communication/PPE program to show due diligence.1917.94