Strap-on Foot Protectors

Virtual Advisory Committee Meeting

Beginning: Wednesday, October 20, 2012 through November 4, 2012
All comments must be received by 5:00 p.m. on November 4, 2012
OSHSB Contact: Hans Boersma

The purpose of this virtual advisory committee meeting is to consider amendments to the General Industry Safety Orders to address the use of strap-on foot protectors. This virtual advisory committee meeting will run from October 20 through November 4, 2012. The use of advisory committees is to ensure meaningful public participation during the rulemaking process to make certain the proposal is 1) necessary, 2) non – duplicative, 3) reasonable and 4) clear – understandable. Therefore, the Occupational Safety and Health Standards Board (Standards Board) relies heavily on your input to determine the need and effectiveness of the proposal.


The proposed changes to Section 3385 are in response to amendments made in 2006 and 2009 where the latest ANSI Z41-1999 and ASTM F2412-05 Standard were referenced in Section 3385. The 2006 and 2009 amendments resulted in the unintended consequence of prohibiting the use of strap-on foot protectors, because the referenced ANSI and ASTM standards exclude strap-on foot protection devices by mandating that toe caps must be an integral and permanent part of the foot wear. Additionally, ANSI Z41-1999, Section 1.4.1 states that strap-on foot protection devices are not considered acceptable foot protection. Therefore, the 2006 and 2009 changes to Section 3385(c), referencing the above ANSI and ASTM standards, subsequently necessitated granting variances to employers who had effectively used strap-on foot protectors for decades.

The proposed amendments would provide employers and employees with the option to use strap-on foot protectors under certain conditions, as an effective means to protect employees exposed to possible foot injuries from falling objects, crushing or penetrating actions. The provisions in the proposal are derived in part from conditions imposed in the Board's variance decisions regarding OSHSB Files 09-V-124, 09-V-125 and 10-V-069.

The Federal OSHA's comparable standard contained in 29CFR 1910.136(b)(1) allows employers to utilize protective footwear that is proven equally effective by the employer. Federal OSHA has reviewed the proposal and has provided guidance that will ensure federal equivalency.


Variance Decisions (OSHSB Files 09-V-124, 09-V-125 and 10-V-069) (pdf) 604kb

Federal OSHA Advisory Opinion (10/02/2012) (pdf) 40kb

The referenced ANSI Z41-1999, ASTM F2412-05 and ASTM F2413-05 standards are copyrighted and therefore are only available for review at the Standards Board Office located at 2520 Venture Oaks Way, Suite 350, Sacramento, California, Monday through Friday from 8:00 a.m. to 4:30 p.m.

  • Proposed regulation (pdf) 28kb (doc) 32kb


All comments are reviewed by the forum moderator before posting to ensure the comments do not contain improper material such as profanity or defamatory statements. The moderator will generally not respond to comments posted, but may do so if it seems appropriate. We ask you to observe the following rules when commenting during the online advisory committee meeting.

  • Please use your real name and include your affiliation or company name and a valid email address. Although your email address will not be posted, we might want to contact you to discuss your ideas further or request your in-person participation in a subcommittee meeting.
  • Keep your comments reasonably brief and related to the topic at hand.
  • Comments will be accepted until 5:00 pm November 4, 2012.
  • The purpose of the advisory committee meetings is to solicit opinions from the public regarding the proposal posted above. Therefore, your comments should relate only to the proposal that is posted.
  • Do not post defamatory material, profanity or advertisements.
  • Do not submit Cal/OSHA notifications and reportings of accidents or complaints as this is not the proper place to do so. Please contact your nearest Cal/OSHA office for guidance regarding such notifications or reportings.
  • Comments Received (pdf) 32kb