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	Foot Safety Basics: A 10-Point Checklist Foot Safety Basics: A 10-Point Checklist How to set up a complete foot safety protection program including selection, fit testing, training, maintenance and inspection. By Andrew Mitchell The U.S. industrial market for safety shoes and boots, rubber or plastic boots, and foot and leg guards is estimated at nearly $1 billion. Approximately $70 is spent per employee on foot protection per year. To be sure, industry is doing a lot-and spending a lot-to help prevent foot injuries, to say nothing of slips and falls. On the flip side, according to the National Safety Council, in 1997 there were 180,000 foot-related workplace injuries. That's 400 cases a day at an estimated $6,000 per incident. A Bureau of Labor Statistics study of foot injuries found 75 percent of the accidents occurred when workers were not in compliance. A more programmed approach to making foot protection purchases-one that focuses as much on comfort, durability and anti-slip protection as it does on bottom line pricing- might in fact reduce industry's investment in foot protection while reducing worker injuries as well. The checklist that follows outlines the steps required to make a truly informed purchase, including the rules, the choices, the motivation factors and the industry trends in foot protection. 1) Understand the rules. The purpose of a programmed approach to foot protection is to bring your workplace up to spec, to keep your employees safe, to lower your cost of compliance and to provide a convenient way for business owners to stay legal. The emphasis should be "compliance and beyond." To begin, you must understand "The Big Three" federal safety regulations for foot protection: 1) OSHA 1910.132 (d) - hazard assessment within your plant environment, 2) OSHA 1910.136 - Occupational Foot Protection, general requirements, and 3) OSHA 1910.132 (f) a, iv, v - employee training and fitting for protective footwear compliance There are other, more specific regulations-see sidebar-but these outline the premise of the programmed approach to safety; learn, comply and teach. To stay current with complicated OSHA guidelines and their many regulations is understandably difficult. When you set out to evaluate your foot protection program, employ the expertise of companies and representatives whose primary business is supplying OSHA-approved safety footwear. 2) Understand the scope. There are two major categories of work-related foot injuries. The first includes foot injuries from punctures, crushing, sprains, and lacerations. The second group of injuries includes those resulting from slips, trips and falls. Taken together, the two categories represent nearly 25 percent of all disabling injuries. In addition, there is a whole range of foot problems associated with workplace conditions, including calluses, ingrown toenails and tired feet. Although not occupational injuries in the strictest sense, their associated discomfort, pain and fatigue have a direct impact on productivity and can lead to further injuries. 3) Choose an auditor. A complete facility analysis is the perfect way to launch a comprehensive protective footwear program. The audit works best when a trained third party professional-either a footwear manufacturer representative or dedicated safety distributor, or both-is invited to walk through the entire plant and observe foot protection use, or lack thereof, in every area of the facility. The third party approach is ideal because you are drawing on the expertise of qualified foot protection specialists. The approach also removes bias and encourages open dialogue from employees. Safety distributors offer the experience gained from years of solving problems just like those in your facility. In addition, the safety distributor will carry multiple lines of footwear, turning "a complete line" into "many complete lines." A good place to start a safety audit is a thorough examination of the plant's injury rate. By working together to analyze these records, plant safety professionals and auditors can develop objectives for the rest of the survey. 4) Engineer problems away. Remember the fundamental principle of occupational health and safety: occupational hazards should be eliminated at the source. Through careful observation of plant or worksite processes, the auditor will be able to recognize potential foot injury or slip hazards and plan for their elimination. If a hazard can be engineered out of the process, protection in that case becomes unnecessary. Tips that may improve workplace design include: - Regulate areas where pedestrian traffic and mobile equipment meet to help avoid crushed feet and toes. Consider installing safety mirrors and warning signs. Also consider designated pedestrian pathways. - Check that proper guarding is in place on chain saws, rotary mowers and other power equipment and machinery that can cause cuts or severed feet or toes. - Improved housekeeping can prevent loose nails and other sharp objects from causing puncture injuries as well as slips and falls. - Stairs, ramps and passageways are hot spots for trips and falls. Use color contrast and angular lighting to improve depth of vision. 5) Ask the people who know. The next step in the process is to get down to the plant floor. Talk to the workers who face a facility's hazards every day. Discuss the types of hazards they face, and then address comfort, sizing, distribution, training and other issues affecting compliance. When workers are part of a solution, they will be more likely to support the implementation of any change in the program. Because cost is almost always a factor, the analysis should include input from the purchasing department as well. 6) Pick the protection. Safety footwear includes steel toe, non-metal toe, metatarsal guarded, slip resistant, dielectric, conductive, cold environment, heat resistant, chemical resistant, bloodborne pathogen, and fatigue protection. Add style-including heavy-duty work boots and shoes, as well as dress, casual, athletic, and hiker-styled protective footwear-and the picture becomes even more complex. It's not hard to understand how choice can itself become a hazard. Although the final decision on PPE (and the responsibility for that decision) is yours, it is helpful to narrow the focus. The safety distributor or manufacturer who performed the safety audit should detail the findings in a written report and offer a plan for improving the existing situation. The plan must recommend the proper levels of protection for each job, information that only professionals familiar with a complete line of protection and their possible applications could provide. 7) Get the footwear to the feet. How the footwear gets to the worker is a matter of choice. Employer-paid distribution methods include: traditional distributors, catalog companies, shoemobiles, voucher programs (redeemable at retail stores-Sears, Penney's, Home Depot, etc.), Web-based solutions, or an on-premise store operated by a distributor or integrated supply partner. The on-site safety center is the most complete system. The centers provide support for much more than footwear, rather, they provide some companies with the answer to all safety issues, including staffing, sourcing, dispensing and record keeping. The centers carry a complete line of safety products and offer a number of personal service functions, including eyewear prescription work, footwear fitting, respirator testing and maintenance and more. In commercial terms, the centers offer nearly 100% inventory reduction, elimination of in-house processing time for purchase orders, elimination of sourcing time for spot buys, 24-hour emergency availability and supplier-provided staffing. 8) Comfort equals compliance. The old adage is too often true, "When your feet hurt, you hurt all over." While very difficult to measure, fatigue can be a contributor to accidents. Lightweight, more comfortable footwear choices means people will grow less tired during the long workday and, hence, less likely to have a fatigue-related mishap. Structurally, boots should fit snugly around the heel and ankle when laced (protective footwear should always be laced up fully; high-cut boots provide support against ankle injury). The shoe must have either no heel or a low, wide-based heel, since heels contribute to fatigue. Consider using shock-absorbing insoles where the job requires walking or standing on hard floors. As for the fit, boots and shoes should have ample toe room (toes should be about 12.5 mm from the front). Footwear that is too tight will NOT stretch with wear. Have both feet measured when buying shoes since it is normal that feet differ in size. Shoes should be purchased that fit the larger size. Finally, buy shoes late in the afternoon when feet are likely to be swollen to their maximum size. Finally, employees should own at least two pair of protective shoes or boots. The "breaking-in" process can often cause blisters and discomfort and can be avoided by rotating between old and new shoes. 9) Training is mandatory: Good training is better. Certain elements of PPE training are mandatory, including how and when to wear, the limitations of, and how to put on and remove the equipment. You must also teach the proper care, maintenance, useful life and disposal of the PPE. After training, OSHA mandates that employees demonstrate that they "get it" and that employers file written records of persons trained, the type of training provided, and the dates when training occurred. That's training. Good training requires a little more spit and polish. Timing Each lesson should be designed to take seven to ten minutes of employee time. All lessons can be taken in one session or the training can be easily broken up into multiple sessions. Any more than ten minutes and you risk losing your audience. Pre-test If this is the worker's first time taking the lesson, a pre-test will establish how much of the material they already know. It also lets the employee know where the training is going. Educate Make sure the meat of the lesson is planned in advance; the manufacturer or safety distributor with whom you've partnered may have packaged programs. Good training should encourage participation. During the lesson, the worker should participate in interest-arousing interactions, practice activities and even emergency simulations. Answer questions After the lesson, ask your workers questions. Written questions should be read aloud to help workers who might have poor reading or comprehension skills. Quizzes can take the form of crossword puzzles, multiple choice or fill-in the blanks. The quiz can be serious or fun, as long as the questions reinforce the training. Motivate Workers need to be reminded of the company's commitment to safety. Hang posters, develop incentive programs, place safety related articles in the company newsletter. Again, packaged program materials may be available; discuss with your distribution partner. 10) Keep up with the trends. Current focus is shifting from the "price" of the shoe or boot to the "value" of the protective footwear program. Companies are asking themselves what is the true full cost of the footwear solution. For example, the cost to an employer of a slip injury is conservatively estimated at over $20,000 when direct, indirect and ripple costs are considered. Therefore, saving a few pennies on footwear is significantly outweighed by the cost to an employer for just a single accident that might have been avoided. The definition of value must also include a discussion of durability. More and more buyers are considering the cost associated with 3 pairs of $45 shoes vs. 1 pair of $95 shoes or 12 pair of $10 PVC boots vs. one pair of polyurethane boots at $60. In the end, an intricate balance between protection, cost, and wearability/comfort defines value. The perfect foot protection is rarely the thickest and stiffest boot, impervious to any hazard. Nor is it the cheapest pair, despite the importance of a good price. More likely, true value is somewhere in between. Your task is to find just enough protection and comfort, factor in durability.and then start shopping. Andrew Mitchell is the Vice President of Sales & Marketing for Safety Today's Protective Products Group, Columbus, Ohio. Safety Today provides personal protective equipment and safety-related services to industrial customers as well as safety resources and supplies to the foodservice industry. For a FREE Safety Audit or information about On-Site Safety Centers, call 800-837-5900.