Safety footwear risk assessment
The use of safety footwear in the workpace can often be seen as a tricky issue for employers, but it really doesn’t need to be if risk assessments are carried out and applied.
It’s common in the workplace to hear employees saying that their safety footwear is “uncomfortable”, and a good employer will take this seriously and see what they can do to help ease the discomfort.
As an employer, or a safety and health professional, you should be asking the employee why the footwear is uncomfortable. It could be that you’ve provided the wrong type of footwear for the job which is why it is important to carry out a risk assessment before deciding which type of footwear is appropriate for the task.
The footwear needs to protect against a variety of hazards, including chemicals, oils and acids, sharp objects and water. You also need to consider whether the footwear needs to be non-slip, or anti-static, or whether it needs to guard against extremes of temperature. Finally, you should always look again and ask whether safety footwear is actually required?
For instance, in a factory office there is still a risk of something dropping onto an employee’s foot, but safety footwear may not be necessary. However, for a task on the shop floor where objects of some weight could be dropped and potentially cause significant injury, safety footwear is not just a good idea, it is a requirement.
There should be no excuse for failing to wear safety footwear when it is required. Manufacturers have a full range of shoes, trainers and boots in a range of fashions which should suit most workers. It makes sense for employers to have an ‘approved range’, which allows individuals to choose a style of footwear that they prefer and are happy to wear.
It’s also worth bearing in mind that safety footwear may not actually be the cause of discomfort.
Some people could have a medical issue which makes wearing certain types of footwear uncomfortable. In these instances, you should be referring the individual to an occupational health practitioner for advice.
The type of sock worn can also be an issue and create discomfort. Socks can sometimes be too thick, but stockings or tights can be too thin. To solve this, provide instruction on the type of socks to be worn for maximum comfort when the footwear is issued.
If the footwear is laced too tightly, or not tightly enough, that can also cause discomfort. The provision of an innersole might rectify the problems.
What if the employee refuses to wear the footwear?
If the employer has identified safety footwear as necessary, via a risk assessment process, then it is a safety precaution and as such, the employee cannot refuse to wear it.
Employers should consult with their staff during risk assessment and provide an approved range of footwear. Then, if an employee fails to wear their safety footwear, they are failing to comply with the safety policy of the organisation and are therefore liable to disciplinary procedures. An employer could also be open to claims of failing to adhere to its own risk assessment and safety policy if they allow the individual to work without the safety footwear.
If safety footwear is mandatory and identified as a risk control measure, the employer must supply it free of charge to the employee, and this includes free maintenance, even including laces.
Claims and disclaimers
When an employee complains about the safety footwear provided, it is prudent for the employer or safety and health practitioner to do everything possible to rectify the problem – otherwise the employee could have grounds to claim for injury.
However, if the employee doesn’t tell their employer, then how does the employer know there is a problem? It is important, therefore, that a known procedure is put in place by the employer for staff members to follow if they have difficulties with any safety equipment.
Even with normal footwear, it needs to be remembered, there is a possibility of rubbing until the footwear has been “broken in”. Explain this to employees – if the footwear is unsuitable it will become apparent very quickly.
Some employers have tried to implement “disclaimers” into their workplace, but these aren’t worth the paper they are written on. It is like saying: “I know there is a significant risk of injury, I’ve made suitable arrangements to reduce this risk, and the wearing of safety footwear is necessary to further lower this risk. However, in your case, I’ll make an exception so long as you promise not to sue me if I cut your toes off.”
Safety footwear is like any other form of Personal Protective Equipment (PPE) – it is either needed or it is not, no exceptions.
If an employer identifies a specific requirement to wear personal protective footwear, then it is up to the employer to enforce this decision.
It is difficult to get safety footwear right every time, but if you identify the need, consult your employees and provide advice to them, and enforce the wearing of the footwear properly, most of the problems you will come across should be resolved.
Key aspects of safety critical testing
Defective footwear products can lead to an increased potential for accidents due to slips, trips and falls. It is therefore essential for footwear manufacturers to assess their designs and ensure they are fit for purpose LYNNE BRENT reports on the key aspects of safety critical testing in footwear.
Various areas of the world have different methods of protecting the consumer. In Europe, for instance, footwear is covered by the European General Product Safety Directive, which is designed to ensure that all consumer products placed on the market in the European Union are safe. In the USA, the U.S. Consumer Product Safety Commission is charged with protecting the public from unreasonable risks of serious injury or death from more than 15,000 types of consumer products including footwear.
The public are increasingly aware of their rights through articles in newspapers, consumer programmes on TV and information on the Internet. Changes in law and reported cases bring with them media publicity and draw the consumer’s attention to their right to complain.
In addition, the public are more familiar with product recalls and solicitors advertising “no win no fee” services. This has resulted in a compensation culture and encouraged more people to complain.
Obviously returns and complaints increase costs to the retailer and manufacturer. There is not only the cost of the footwear to consider but also the high risk of expensive court cases and compensation in the event of the footwear causing a personal injury.
As a world leading research and technology organisation for the footwear and leather goods industry, SATRA has developed many tests and performance guideline criteria suitable for evaluating footwear for ‘fitness for purpose’. There are basically six main safety critical areas which need to be considered.
Slipping, tripping and falling remain potentially the most likely cause of accidents. Although these accidents will never be totally eliminated, they can be significantly reduced by using soles which have been fully evaluated for their slip resistance properties. SATRA is a world leader in slip technology and has developed a performance standard and test equipment that is the accepted industry standard. Most of the testing is carried out on our standard clay tiles wet and dry although this is often supplemented with other floorings such as carpet, polished wood and vinyl tiles. Interestingly of the number of samples we test each year, roughly 25% are considered unsatisfactory in this respect.
Sole bond failures are still a major reason for customer complaints. When a sole bond starts to separate, tripping stumbling and falling can occur. Successful sole bonding depends on adequate upper and sole preparation, together with the correct choice and use of a suitable adhesive system. SATRA toe load and peel strength, together with ageing tests, will fully evaluate the bonds and show any weaknesses.
Heel attachment is the second most common safety related complaint we see at SATRA and the potential injuries are serious. The failures are a result of either one impact or gradual fatigue. The attachment of a heel is a major feat of engineering and relies on the various component qualities as well as production techniques.
Top piece detachment and heels breaking are also serious problems. SATRA has a suite of tests to fully evaluate all the components in the shoe back part as well as the attachment strength of the heel in the finished shoes.
Straps and fastenings
Strappy sandals and shoes remain popular for all seasons. Some straps are purely decorative, most are functional – in either case, a broken or detached strap will ruin the footwear, could cause injury to the wearer and have the potential for a personal injury claim against the retailer.
The number of straps, their width and position will vary with each design but the strength of the strap and its attachment are always the most important aspects to consider.
Strap to sole attachment (cemented constructions)
The attachment of wider straps can be reinforced with staples or tacks but narrow straps normally rely on adhesion strength alone to prevent them pulling out in wear. It is therefore important to ensure that these straps are prepared correctly prior to the adhesive being applied.
SATRA normally uses a peel test, to assess the attachment strength of straps. However this method is not suitable for narrow straps. The preferred test here is to apply an increasing force to the strap until failure occurs.
Testing the attachment strength of individual straps to the sole/insole is vital since the strength can vary significantly. Ideally, alternate straps are tested on a pair of shoes.
Safety critical testing of children’s footwear also needs to cover any foreseeable abuse and specific hazards relating to children. The most appropriate standard for assessing the hazards associated with children’s wear is the Toy Safety Standard EN71. Although there are eight parts to this standard, generally the first three cover the necessary areas. These are mechanical and physical properties, flammability and toxicity.
The list of subjects covered in this article is not exhaustive and a full risk assessment is advisable on any new style or construction.
SATRA would strongly recommend that all safety critical properties, are fully evaluated to demonstrate due diligence on behalf of the manufacturer and retailer. As well as testing at sample stage, it is advisable that safety critical properties are subject to on-going testing to ensure standards are maintained.
As well as offering routine testing of safety critical properties, our team of experts can offer constructive interpretation of results and advice on any remedial manufacturing/production action necessary.
Back in 1989, the European Union issued its Directive covering most types of PPE. The objectives were to facilitate the free and fair trade of goods throughout the (now) twenty seven countries in the EU as well as ensuring that any equipment which claimed to offer the wearer or user protection conformed to the Directive and thus they would receive the protection relevant to the proposed use. In order to achieve this, a number of notified bodies were recognised throughout the EU and these became the ONLY organisations empowered to assess the product and confirm its acceptability. Products which achieved this standard must then display the CE mark. SATRA Technology Centre, based in the UK, is one of the leading test and certification organisations within the EU, and is a Notified body for virtually all types of PPE, including safety, protective and occupational footwear.
The PPE Directive refers to specific health and safety requirements and has a number of supporting standards which define exactly how each type of product must be tested, what standard the test result needs to achieve and what information is necessary to be provided to the customer to explain the performance and care of the product. These standards are generally revised every five years to reflect changing market conditions, new materials and technology, and to include new products.
Safety footwear European standard
In the case of safety footwear, the current European standards are:
- EN ISO 20344 test methods.
- EN ISO 20345 safety footwear (200J toe cap)
- EN ISO 20346 protective footwear (100J toe cap).
- EN ISO 20347 occupational footwear (no toe cap). These standards replaced the EN 344 series of standards in 2004
EC type examination certificate
Since the introduction of the PPE Directive, the use of test certificates and CE marking of safety footwear has become a key aspect of trade, and has undoubtedly raised the overall standard of protection offered to the customer. Buyers should not consider purchasing products without seeing a copy of the EC type examination certificate. Whilst most companies follow the rules to legitimately CE mark their products, there are a number who do not (either by mistake or otherwise) and apply the mark without undertaking the necessary procedures. If buyers are unsure, they should check the authenticity of the EC type examination certificate with the issuing Notified Body.
SATRA is one of Europe’s foremost European Notified Bodies for certifying protective clothing, and it is able to carry out testing and EC type examination work using established European standards or in house developed test specifications.
SATRA Technology Centre Wyndham Way, Telford Way Industrial Estate, Kettering, Northants NN16 8SD
Tel: +44 (0)1536 410000 Email: [email protected]
For more information on Safety Footwear click here http://www.osedirectory.com/product.php?type=health&product_id=18
Published: 10th Sep 2007 in Health and Safety International