12 replies to this topic

[Miss Frankie]

I'm having a minor argument with my boss over footwear.
She insists that everyone in production wears steel toed boots as it's a health & safety requirement and mandatory on the production floor.

We will be processing meat alternatives.

I have worked in a few plants and nobody has had to wear steel toed boots. 
I'm about to go search the OSHA site for their requirements.

Am I wrong on this?

 

[SQFconsultant]

Steel protection would only be for production if there is a good possibility of toe/foot injury in the event of impact.

 

If there is a good likelihood of impact to the toe box area of the foot only then is it suggested for "health" reasons.

 

You might only be able to avoid this by running a risk analysis.

 

Because frankly if there is no reason to have them they can actually cause a "health"issue by making peoples toes and feet hurt and cause fatigue.

Edited by SQFconsultant, 22 March 2024 - 12:37 AM.

[MOHAMMED ZAMEERUDDIN]

If it is a health and safety requirement then better to follow this practice. All is depend on the risk assessment.

[MDaleDDF]

I highly doubt it's an OSHA requirement.  I've worked some pretty hard core jobs, and it wasn't required.   I also agree with Glen, they can do more harm than good.

I also don't see why a risk assessment is needed.    If it's not a requirement,  you don't need a risk assessment.  (Sometimes I think the food safety crowd won't take a dump without writing a risk assessment first....)

If you're working with heavy stuff and they're likely to drop something on their foot, then do it.   If not, it's probably not needed.   There are plenty of scenarios where it's worse to have them, ie, something smashes right thru the steel toe and the steel cuts your toes off, etc.   

I once worked as a mechanic and there was a no rings rule, but me being me, I had a titanium ring on anyway.    One day a motor fell and caught my finger between the transom and the motor.   Titanium ring saved my finger.   If I'd have had no ring on, I'd be playing guitar a lot crappier today....

[ChristinaK]

This is the OSHA standard on protective footwear that I'm aware of: https://www.osha.gov...r/1910/1910.136

 

Generally, if there is a risk of objects falling onto the foot, piercing the sole of a regular shoe, or in electrical areas, you will want steel-toe shoes. The risk has to be there after the employer has already taken all other measures to prevent the risk. So yes, risk analysis is still involved somewhat; just personnel safety rather than food safety.

 

In my experience, it's only been maintenance personnel and machine operators who were required to wear ST shoes based on the nature of their work. QA Techs and temps were usually just required to wear closed-toe non-slip shoes or boots when working in production areas.

[Miss Frankie]

If it is a health and safety requirement then better to follow this practice. All is depend on the risk assessment.

This is what I'm trying to determine. Is it an actual requirement for our type of processing.  

 

Steel protection would only be for production if there is a good possibility of toe/foot injury in the event of impact.

 

If there is a good likelihood of impact to the toe box area of the foot only then is it suggested for "health" reasons.

 

You might only be able to avoid this by running a risk analysis.

 

Because frankly if there is no reason to have them they can actually cause a "health"issue by making peoples toes and feet hurt and cause fatigue.

 

Agreed!  I tried on a pair and just wearing them a few minutes, they were uncomfortable.

[jfrey123]

At one of the meat processors under our umbrella, I think storage/shipping crews have to wear steel toes but not the production employees nor the QA.  Management does not have to wear them.  I wear a set when I visit the plants because they're the only shoes I own with slip resistant soles.

[Miss Frankie]

At one of the meat processors under our umbrella, I think storage/shipping crews have to wear steel toes but not the production employees nor the QA.  Management does not have to wear them.  I wear a set when I visit the plants because they're the only shoes I own with slip resistant soles.

 

This makes sense.

 

I just need to find something official that CLEARLY says, "XXX workers shall wear steel toe...."   or "ZZZ workers are not required to wear...."  

It shouldn't be that hard to find, but it is proving to be rather difficult. 

[jfrey123]

As with anything the Fed puts out, it's worded broadly enough to let them penalize you at will without actually telling you whether you needed to be compliant beforehand.

 

From the link ChristinaK posted:  "The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures."

 

Lots of companies read that declare any time employees handle items heavy enough to injure a foot, or if the drop is sufficient to hurt a foot below, they require the steel toes.  Others will ignore the hazard until something happens and OSHA cites them for not requiring protective footwear.  Just like many of our food safety codes, clear as mud 

[GMO]

There is no way if you were in the UK that any public body would mandate this or be that prescriptive, I have no idea if it's different in the US.  It would always be based on risk assessment and the way the legislation is written in the UK is you have to do what is "reasonably practicable" to reduce the risks to the member of staff.

 

BUT that said, in the UK steel toe caps in food manufacturing is ABSOLUTELY the norm.  If they're uncomfortable, you've probably got the wrong size on.  You certainly get used to them.  I've been wearing similar for over two decades.  

I know the health and safety culture and legislation is vastly different in the UK vs. the US but if you have any pallet movements (e.g. hand pump trucks) or risk of heavy items falling (e.g. if you use rack movements or hand tools), I can't see why you'd not have them.  They're available in easy to clean versions, wellies etc.  

Sometimes as I've got older I've been more inclined to think "is this the hill I'm going to die on?"  As long as they're food safe, i.e. cleanable, if the health and safety team want them, I wouldn't see it as an issue and I'd be supportive.  I'd just rope them in to support when I want something later.... 

[Ryan M.]

Personally, I've always worn them...they've saved my tootsies a number of times.  As for the OP, you need to get with your personnel safety (EHS) person to determine risk and get their input.  It is a PERSONNEL SAFETY issue, and not a health issue.

All those who say they do more harm than good are not using the appropriate footwear for their feet.  It took me 10 years to find footwear that met my needs and I went through a myriad of iterations, but I've finally found them.  To all those with foot problems go find the footwear that works best for you...your feet, and rest of your body will thank you.

 

I'll also say that losing a lot of weight helped immensely...not calling anyone fat here, but take this into consideration because every pound makes a significant difference to your overall body, back, knees, feet.  And generally on the footwear the lighter the better...pay the premium to get a light shoe with a composite toe (if safety toe needed).

[MDaleDDF]

As with anything the Fed puts out, it's worded broadly enough to let them penalize you at will without actually telling you whether you needed to be compliant beforehand.

 

 

This is gospel right here, amen brother!   Lol...
 

[LostInTheWoods]

This makes sense.

 

I just need to find something official that CLEARLY says, "XXX workers shall wear steel toe...."   or "ZZZ workers are not required to wear...."  

It shouldn't be that hard to find, but it is proving to be rather difficult. 

 

It may also be an insurance requirement that's being misattributed to OSHA. Sometimes your insurance costs can vary based on your internal policies.