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Employer duties for protective footwear and its cost

Summary An employer asked whether the personal protective equipment standard required it to supply protective footwear without charging employees. OSHA said the employer had to assess foot hazards and ensure necessary footwear was used, but described payment as a labor relations matter under the rule then in force. OSHA's current payment rule, effective in 2008, now sets employer payment duties and footwear exceptions.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1993-09-20-0
Date issued
September 20, 1993
Status
Archived by the agency
OSHA does not label this letter archived or withdrawn. Its statement about who pays predates 29 CFR 1910.132(h), effective February 13, 2008, which now sets employer payment duties and exceptions for certain footwear.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Personal Protective Equipment
Source
View the official document

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The current status of this document is unclear
OSHA does not label this letter archived or withdrawn. Its statement about who pays predates 29 CFR 1910.132(h), effective February 13, 2008, which now sets employer payment duties and exceptions for certain footwear. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

September 20, 1993

Jerry Zebor
Senior Safety Engineer
Johnson Controls
World Services, Inc.
[Recipient address omitted]
Dear Mr. Zebor:

This is in response to your letters of May 26, June 4, and July 28 requesting an interpretation of the 29 CFR 1910.132(a) (Personal Protective Equipment, General Requirements), phrase "...shall be provided...". Please accept our apologies for the delayed response.

You are correct in your conclusion that "...the employer has responsibility to facilitate the provision of certain PPE (including footwear) and insure its use."

The current standard does not state that the employer must purchase and distribute protective footwear "...with no cost to the employee". This question has been raised several times since the inception of OSHA, and it has normally been considered a labor/management relations matter, resolved through formal or informal negotiations between the affected parties.

It is the responsibility of the employer to evaluate the workplace for hazards that could result in foot injuries. If a hazard cannot be removed by engineering, or administratively controlled in the workplace then personal protective equipment would be required.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.

Sincerely,
Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance

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