OHS Code Explanation Guide

Published Date: July 01, 2009
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Part 18 Personal Protective Equipment

Section 233 Footwear

Subsection 233(1)

The employer is not required to pay for and provide safety footwear. However, the employer is required to assess the hazards (see section 7 of the OHS Code) that the worker’s feet will be exposed to and determine if there is a danger of injury to the worker’s feet. The employer is also required to ensure that the protective footwear selected is appropriate to the work being done and the hazard(s) involved.

The employer must determine the appropriate protection required for the feet based on the work assigned to each worker. In doing so, the following factors should be considered: the potential for slipping, uneven terrain, abrasion, ankle protection and foot support, the potential for crushing injuries, temperature extremes, exposure to corrosive substances, puncture hazards, electrical shock and any other recognizable hazard.

The assessment must consider the work procedures and conditions present at the workplace. An employer may change the work procedures and workplace conditions to reduce or remove the risk. For example, an employer may limit the number of workers doing tasks that could cause foot injury. Or the employer may change the way the tasks are done. Protective footwear need only be worn while a worker is exposed to the hazard that requires it. When determining the requirements for appropriate protective footwear, worker training and supervision are not an acceptable substitute for protective footwear.

The hazard assessment to determine appropriate footwear will result in persons or activities being placed into one of three categories:

Category 1

The hazards present require footwear approved to
(a) CSA Standard Z195-02, Protective Footwear, or
(b) ASTM Standard F2413-05, Specifications for Performance Requirements for Protective Footwear.

Because safety footwear is only approved to the specific hazards listed in the standards, the employer must be aware of hazards to which workers are exposed and against which the footwear provides protection.

If a hazard requires metatarsal protection, i.e. protection to the top surface of the foot, metatarsal protectors must be an integral part of the footwear. This form of protection is typically required in foundries and heavy manufacturing where steel plate, beams or rails are handled, but it is not normally required in construction. Metatarsal protectors that only attach to the laces or are only strapped in place do not meet the requirements of the referenced CSA standards. Such protectors must not be used because there is no assurance that they will be properly supported by the toecap.

Category 2

Some hazards are present that require foot protection but not necessarily to the level of category 1. For example, it is unlikely that a lifeguard at a beach needs footwear with safety toe protection. It is much more likely that the lifeguard needs footwear offering protection against cuts from objects on the beach.

Hazards for which protection may be required include slipping, uneven terrain, abrasion, ankle protection and foot support, temperature extremes and corrosive substances. CSA Guideline Z195.1-02, Guideline on Selection, Care, and Use of Protective Footwear, helps employers assess hazards and select the most appropriate protective footwear for the situation.

Category 3

There are no hazards of foot injury for which specific protective footwear is necessary. This situation applies to most workers in an office setting.

Footwear suggestions for certain types of workers
The following situations serve as examples of the types of footwear workers should wear. Because circumstances at workplaces can vary significantly, these recommendations are general and may need to be altered. For example, an employer may arrange the work in a manner that eliminates all hazards of foot injury and therefore the need for protective footwear.

Example 1: A worker in the construction industry, or any other similar working environment where there is risk of toe injury, should wear approved safety footwear with Grade 1 toe protection (see Table 18.2 for information about the grades of toe protection available.)

Example 2: A worker in the construction industry, or any other industry with a possibility of sole puncture, should wear footwear with protective sole plates.

Example 3: A worker in any industry with a potential for electric shock, for example an electrician or powerline technician, should wear footwear with dielectric protective soles, in addition to any other protective features required by the circumstances of the work.

Example 4: A worker using high pressure washing or cutting equipment should wear footwear or footwear cover devices that protect the whole top area of the foot from accidental contact with the washing or cutting stream. Conventional safety toe and metatarsal protectors do not cover a sufficient portion of the worker’s foot to protect the foot during this type of work.

Because conventional protective footwear does not offer sufficient protection against this hazard, alternative footwear appropriate to the hazard must be used. Subsection 233(3) allows the use of protective footwear that is not approved to one of the CSA standards.

Example 5: A worker in a warehouse should wear safety footwear with Grade 1 toe protection.

Example 6: A worker in a retail store environment using pallet jacks, forklifts or other rolling equipment should wear footwear with Grade 1 toe protection.

There are activities and work environments where a heavy work shoe or boot, or a specific protective feature, might normally be required but wearing such footwear could endanger the worker or damage the work environment. These exceptions apply while the worker is performing the particular job function. When the worker is performing other job functions or walking through surrounding hazards, the worker must wear footwear appropriate to those job functions or hazards. The following practices are generally recognized as being acceptable to Alberta Human Services:

Example 7: A roofer applying asphalt shingles or similar materials that can be damaged by heavy work boots will generally wear light, soft-soled footwear such as running shoes.

Example 8: A carpet layer or similar finishing trade that requires a worker to constantly kneel down will generally not wear safety-toed footwear.

Example 9: A worker climbing or walking on skeletal steel structures will generally not wear safety-toed footwear because such footwear offers limited grip on steel surfaces. However, the worker should wear substantial footwear having leather uppers reaching past the ankles to provide ankle support and abrasion resistance.

Example 10: A worker in the logging industry walking on logs or on steep sidehills or uneven ground will generally not wear safety-toed footwear. Subsection 233(3) should be applied since the principle hazard is slipping, a hazard not addressed by the CSA standards listed in subsection 233(2). Substantial footwear having leather uppers and a heavily lugged sole is usually a better choice.

For more information
Guideline on Selection, Care, and Use of Protective Footwear, CSD Special Publication Z195.1-02. Canadian Standards Association, February 2002.

Subsection 233(2)

Footwear approved to the listed CSA standards offers protection against a limited number of hazards. If workers are exposed to one or more of these hazards, and the hazard assessment shows these to be the principle or only hazards needing to be protected against, then footwear approved to the listed standards must be used. For compliance purposes, the footwear must bear the mark or label of a nationally accredited testing organization such as CSA, UL, SEI, etc.

However, as described in Examples 4 and 10 of the explanation to subsection 233(1), if the principle hazard or hazards differ from those addressed by the CSA standards, alternative, unapproved footwear appropriate to the hazards must be used. The employer should be able to explain the reason(s) for selecting unapproved footwear based on the hazards that workers are exposed to.

Footwear approved to the CSA standards offers, alone or in combination,

(1) toe protection,
(2) a puncture resistant sole,
(3) metatarsal protection (protection to the top part of the foot),
(4) electrical protection, and
(5) chainsaw protection.

As summarized in Table 18.2, footwear approved to the new edition of CSA Standard Z195 provides three grades of toe impact protection and each grade of footwear incorporates sole puncture protection. Sole plates are designed to withstand the same puncture force, regardless of grade. Footwear that complies with the earlier version of the Standard, Z195-M92 (R2000) may continue to be used at the worksite if the footwear is in good condition.

Subsection 233(3)

Conventional protective footwear offers protection against a limited number of hazards (see explanation above). If such footwear does not offer adequate protection because the worker is likely to be exposed to a hazard other than one of those referred to in subsection 233(2), then the use of unapproved footwear is permitted. The employer must ensure that this unapproved footwear is appropriate to the hazard. The employer should be able to explain the reason(s) for selecting unapproved footwear based on the hazards that workers are exposed to.

Table 18.2 Protective footwear markings

Outside Labels

Location

Criteria

Intended Application

  The label will appear on the outer side or on the tongue of the right shoe. Green triangle indicates sole puncture protection with a Grade 1 protective toe to withstand impacts up to 125 joules. Comparable to a 10 kg weight dropped 1.3 metres. For any industry, especially construction, where sharp objects (such as nails) are present, heavy work environments.
The label will appear on the outer side or on the tongue of the right shoe. Yellow triangle indicates sole puncture protection with a Grade 2 protective toe to withstand impacts up to 90 joules. Comparable to a 10 kg weight dropped 0.9 metres. For light industrial work environments requiring puncture protection, as well as toe protection.
The label will appear on the outer side or on the tongue of the right shoe. White rectangle with orange Greek letter Omega indicates soles that provide resistance to electrical shock. For any industry where accidental deteriorates with wear and in a wet environment.
The label will appear on the outer side or on the tongue of the right shoe. Yellow rectangle with green "SD" and grounding symbol indicates soles are static dissipative. For any industry where a static discharge can create a hazard for worker or equipment.
The label will appear on the outer side or on the tongue of the right shoe. Red rectangle with black "C" and grounding symbol indicates soles are electrically conductive. For any industry where static discharge may create a hazard of explosion.
The label will appear on the outer side or on the tongue of the right shoe. White label with green fir tree symbol indicates chain saw protective footwear. For forestry workers and others exposed to hand-held chain saws or other cutting tools.

Source: CSA Special Publication Z195.1-02 Guideline on Selection, Care, and Use of Protective Footwear

Note: The ® appearing on the labels represents the mark or label of the nationally accredited testing organization that evaluated and approved the footwear.

Subsection 233(4)

The use of safety toecaps as an alternative to approved protective footwear is limited by several conditions:

(a) the affected worker must be able to provide the employer with a medical certificate, signed by a physician, indicating that the worker is unable, for medical reasons, to wear approved footwear;

(b) the safety toecaps must, at a minimum, meet the impact force test requirements for footwear of CSA Standard Z195-02, Protective Footwear. The impact force required is based on the type of foot hazard the worker is exposed to. For example, if the worker needs Grade 1 protection, then the toecap must be able to withstand the impact force required by Grade 1 foot protection. The purpose of the toecaps is to provide impact protection. Toecaps are not an acceptable replacement for, for example, protective footwear offering chain saw protection;

(c) safety toecaps are not suitable replacements for integral metatarsal protectors. If the worker is exposed to metatarsals hazards, then safety toecaps cannot be used;

(d) safety toecaps do not have soles capable of providing protection against sharp objects penetrating the soles of shoes with which the toecaps are being used. If the worker is exposed to sole penetration hazards, then safety toecaps cannot be used; and

(e) safety toecaps may present a tripping hazard, an electrical safety hazard if made of conductive materials, etc. The employer must take these factors into consideration when determining if safety toecaps can be used as a safe and effective alternative to approved protective footwear.

Subsection 233(5)

No explanation required.