Protective footwear requirements

Yes. Under 1918.104(a), the employer must ensure each affected employee wears protective footwear when working in areas where there is a danger of foot injuries from falling or rolling objects or objects piercing the sole.

• This means the employer must identify work areas with those hazards and provide appropriate footwear for employees who work in them.
• See also the general requirement that protective footwear meet the consensus standards listed in 1918.104(b).

OSHA accepts footwear that complies with the listed consensus standards in 1918.104(b)(1).

• ASTM F-2412-2005 and ASTM F-2413-2005 are accepted per 1918.104(b)(1)(i).
• ANSI Z41-1999 is accepted per 1918.104(b)(1)(ii).
• ANSI Z41-1991 is accepted per 1918.104(b)(1)(iii).

These are the specific referenced standards employers can rely on to select compliant protective footwear.

Yes. Protective footwear not built exactly to those consensus standards is allowed if the employer can demonstrate it is at least as effective as footwear constructed to one of the listed standards, per 1918.104(b)(2).

• The employer should document the basis for equivalence (test reports, manufacturer data, third-party certification) showing equal protection against impacts, compression, and puncture as the referenced standards.
• Keep equivalence documentation available in case of inspection.

Yes—employers must pay for required PPE such as protective footwear unless a specific exception applies, consistent with OSHA's payment rule explained in the interpretation Employee PPE payment methods.

• The 2014 OSHA interpretation on PPE payment methods explains that OSHA requires employers to provide required PPE at no cost to employees in covered provisions of 29 CFR, including those in Part 1918.
• Employers may retain ownership and require return of issued footwear on separation, but they may not shift the normal cost of required PPE to the employee or charge for work-related wear and tear.

Yes, but only if the deposit system does not result in an involuntary cost to the employee and does not circumvent the payment requirement, per the Employee PPE payment methods interpretation.

• OSHA allows deposit systems (for example, to encourage return of employer-owned PPE) provided they are administered so the employee is not effectively paying for required PPE.
• If the employer retains ownership, they may require return of PPE when employment ends and may take reasonable steps to recover unreturned employer property.

Protective footwear is required where there is a danger of foot injuries due to falling or rolling objects or objects piercing the sole, as stated in 1918.104(a).

• Falling or rolling object hazards typically call for impact- and compression-resistant toe protection (e.g., steel toe or composite toe).
• Puncture hazards (sharp nails, debris) call for puncture-resistant soles or insoles meeting the consensus standards referenced in 1918.104(b).

The ASTM standards referenced in 1918.104(b)(1)(i) specify test methods (ASTM F2412-2005) and performance requirements (ASTM F2413-2005) for protective footwear such as impact, compression, and puncture resistance.

• Employers selecting ASTM-compliant footwear can expect documented test methods and performance classes for toe protection, sole puncture resistance, and other protective features.
• Those standards are incorporated by reference in 1918.3, which the maritime standard points to for the detailed technical specs.

An employer may allow employee-owned boots only if they meet the required protective performance or the employer documents equivalence to the referenced standards in 1918.104(b), and payment rules are respected per OSHA guidance.

• If the work area requires employer-provided protective footwear, the employer generally must provide acceptable PPE at no cost as explained in the Employee PPE payment methods interpretation.
• If an employee's own boots meet ASTM/ANSI performance or the employer establishes equivalence under 1918.104(b)(2), the employer can accept them—but should document compliance and maintain records.

The employer should keep clear, written evidence such as independent test reports, manufacturer test data, certification by a recognized test lab, or engineering analysis that shows the footwear provides protection equal to the referenced consensus standards in 1918.104(b)(1).

• Useful documentation includes specific test results for impact, compression, and sole puncture resistance and identification of which ASTM/ANSI performance class they match or exceed.
• Keep equivalence documentation readily available in case of an OSHA inspection.

Yes. Footwear meeting the consensus standards typically carries manufacturer labeling or markings showing the standard and performance classifications, as described in the consensus standards accepted by 1918.104(b)(1).

• Check manufacturer labels, tags, or documentation for references to ASTM F2413, ASTM F2412, or the applicable ANSI Z41 edition indicating which protective features (toe impact, compression, puncture resistance) the footwear meets.
• If footwear lacks such markings, request test documentation from the manufacturer or supplier to verify compliance or equivalence under 1918.104(b)(2).

No. The longshoring rule 1918.104 does not explicitly require slip-resistant soles; it focuses on hazards from falling or rolling objects and objects piercing the sole and requires footwear that meets accepted consensus standards.

• Slip resistance may be addressed by the consensus standards (for example, some ASTM/ANSI footwear specifications include traction tests), so employers should consult the specific standard (see 1918.104(b)(1)(i)).
• Employers should also assess workplace slip hazards separately and provide footwear or controls appropriate to that hazard even if not explicitly required by 1918.104.

The regulatory text requires that the employer ensure each affected employee wears protective footwear in hazardous areas per 1918.104(a), but employers should also protect visitors and contractors from recognized hazards as part of overall workplace safety.

• Contractors working on site who are exposed to the same hazards would normally be treated as "affected employees" and must wear appropriate protective footwear.
• For visitors, employers should provide or require suitable protective footwear or restrict access to hazardous areas to prevent injury.

Yes, provided the metatarsal guards or overshoes meet the protective performance required by the consensus standards in 1918.104(b)(1) or the employer demonstrates they are at least as effective under 1918.104(b)(2).

• Some jobs call for full-toe boots with built-in toe protection; in other cases, wrap-around metatarsal guards that meet the standard's performance tests may be acceptable.
• The employer should document that the selected protection provides equivalent impact/compression resistance and secure fit for the task.

Yes. If the employer retains ownership of the protective footwear, they may require its return upon termination of employment consistent with OSHA's guidance in the Employee PPE payment methods interpretation.

• The 2014 interpretation explains employers may use ownership and return policies and may attempt to recover unreturned employer property, provided such policies do not result in employees effectively paying for required PPE.
• Employers should document issuance and have clear return procedures to avoid disputes.

Employers must evaluate their workplace and identify areas where there is a danger of foot injuries from falling/rolling objects or objects piercing the sole, then ensure affected employees wear protective footwear as required by 1918.104(a).

• A workplace hazard assessment (walk-through, review of tasks, incident history) will show where those foot hazards exist.
• Where hazards are present, select footwear meeting the consensus standards in 1918.104(b)(1) or demonstrate equivalence under 1918.104(b)(2).

OSHA accepts footwear that complies with the consensus standards listed in 1918.104(b)(1), and footwear meeting later versions of those standards may be acceptable if the employer can show equivalence under 1918.104(b)(2).

• Because 1918.104 cites specific editions, employers should either use footwear conforming to those editions or keep documentation showing a newer edition provides equal or greater protection.
• Consult the test and performance data from the newer standard to demonstrate equivalence.

An OSHA inspector will look to see that employees in identified hazardous areas are wearing protective footwear that meets the consensus standards in 1918.104(b)(1) or that the employer has documentation showing equivalent protection under 1918.104(b)(2).

• The inspector may request labeling, manufacturer specifications, or test reports to verify compliance.
• The inspector may also review hazard assessments showing why footwear was required in a given area per 1918.104(a).

The longshoring footwear standard 1918.104 does not specify formal training requirements, but employers should ensure employees know when footwear is required, how to wear it correctly, and how to maintain it to preserve protection.

• Providing basic instruction (fit, inspection before use, cleaning, when to replace damaged footwear) helps ensure the footwear performs as intended.
• Training practices are consistent with the employer's obligation to protect workers under 1918.104(a).

Not if soft or fabric soles cannot protect against the identified hazards of falling/rolling objects or sole-piercing objects; footwear must meet the performance requirements of the consensus standards in 1918.104(b)(1) or be demonstrated equivalent under 1918.104(b)(2).

• Where impact, compression, or puncture hazards exist, soft or fabric soles typically will not provide adequate protection unless specially engineered and tested to meet the required performance.
• Always verify footwear performance via manufacturer data or test reports before accepting nonstandard constructions as compliant.

The consensus standards referenced in 1918.104(b)(1) are incorporated by reference in 1918.3, which explains how the standards are adopted into the regulation.

• Employers can obtain copies of ASTM and ANSI standards from the respective standards organizations for details on testing and performance requirements.
• When in doubt about interpretation of the technical requirements, rely on the standard text referenced in 1918.3 and the specific clauses cited in 1918.104(b)(1).