I am requesting that some of  you weigh in with your thoughts about our 
situation.  I already know where I stand on the subject, but as Safety 
Director I am but one voice trying to present a case.  I'm hoping your 
responses will help me better formulate my position and possibly provide 
some information that I have not yet considered.

We do service/repairs to lifting equipment.  Our technicians work on lift 
trucks and larger equipment.  Our incident logs reflect injuries to 
employee feet due to the dropping of forks, brake cylinders, steer wheels, 
and other heavy items.  We do have cranes and lift trucks available in our 
shops  to assist with such tasks.  Mechanical assistant available for our 
technicians who work at customer locations varies greatly.

Since day one of our company (45 years ago--you know where I am going with 
this!!!) our technicians have worn steel-toe work boots.  The company 
reimburses  them 25% of the purchase price.  An assessment of our 
workplace would indicate that steel toes do not provide adequate 
protection and that the top of our technicians' feel are still exposed to 
the potential hazard of heavy items falling on them.

One proposal given by management is that we continue to pay 25% of the 
cost of steel toe boots and additionally pay 50% of the total cost of 
boots that are both steel toe and provide metatarsal protection.

My interpretation of the new standard is that work boots fall under an 
exemption and employers are not required to pay for them.  Does changing 
our company policy from steel toes to steel toes w/metatarsal protection 
move us out of that exemption class?


I am aware that there are metatarsal guards worn over work boots.  Using 
either of these forms of  PPE will not be well received by our 
technicians.  Our current JSAs currently require two-man lifts or the use 
of lifting equipment when handling heavier loads--this works in our shops, 
but not for our field technicians. 

There should be some strong opinions about the above statements.  Please 
share so I can prepare the best defense.

Thank you in advance for your help.

Pat Hess
Training/Risk Management