Removable toe caps as foot protection

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

29 CFR 1910.132(a)

March 31, 1976

MEMORANDUM FOR: EDWARD E. ESTKOWSKI, Regional Administrator/OSHA
SUBJECT: Request for Interpretation-Roadway Express Inc. 29 CFR 1910.132(a) Protective Equipment

This is in response to Mr. Ed J. Largent's letter dated March 23, 1976, which requests clarification on the use of "Sankey Toe Caps", in lieu of safety shoes.
A review of the OSHA standards 29 CFR 1910.132(a) and 29 CFR 1910.136 has been made. If safety shoes are provided, they must meet the requirement as indicated in 29 CFR 1910.136, which is ANSI Z41.1-1967.
If "Sankey Toe Caps" are provided in lieu of safety shoes, the employer has met the intent of the standard and is providing foot protection. As indicated in 29 CFR 1910.132(a) personal protective equipment shall be provided, used, and maintained. The standard does not require specific use of safety shoes as foot protections.
It is suggested, however, that every effort be made to encourage both the employer and the employee to develop a safety shoe program which requires safety shoes as they provide a more reliable protection.
Barry J. White
Associate Assistant Secretary
for Regional Programs