Does OSHA permit the use of steel toe slip-on covers?

OSHA’s standard on foot protection outlines the criteria for protective footwear at 1910.136(b) which requires that protective footwear comply with various consensus standards. OSHA provides some limited guidance on the use of removable toe-caps in it’s compliance directive, CPL 02-01-050- “Enforcement Guidance for Personal Protective Equipment in General Industry,” by stating that “Protective footwear that the employer demonstrates is at least as effective as footwear that is constructed in accordance with one of [the] consensus standards will be deemed to be in compliance with the requirements of this section (29 CFR 1910.136(b)(2)). The manufacturers’ instructions and the distributors’ literature may not be in themselves evidence of effectiveness.”

The directive further says, “For additional information on foot protection, see OSHA Publication 3151-12R-2003, “Personal Protection Equipment.” The following are some examples of foot (or lower leg) protection:

“Toe guards fit over the toes of regular shoes to protect the toes from impact and compression hazards. They may be made of steel, aluminum, or plastic.

“NOTE: ANSI Z41-1991, American National Standard for Personal Protection- Protective Footwear, which is incorporated by reference, requires at paragraph 1.4 that the toe box be incorporated into the footwear during construction and shall be an integral part of the footwear. An employer who chooses to provide employees with toe guards must demonstrate that they are as equally protective as the Z41-1991 standard as required by 29 CFR 1910.136(b)(1) and (b)(2).”