General Industry (29 CFR 1910)

Foot Protection

Verified vs OSHA sources · 2026-10-05

29 CFR 1910.136

29 CFR 1910.136 requires general-industry workers to use ASTM F2412/F2413-rated protective footwear where there is a danger of foot injury from falling or rolling objects, sole punctures, or residual electrical hazards. The electrical ratings are opposites (electrical-hazard footwear insulates, while conductive footwear drains static) so the rating must match the hazard.

29 CFR 1910.136 at a glance

What it requires: Protective footwear where feet risk injury from falling/rolling objects, punctures, or electrical hazards
Who it covers: General-industry employers whose workers face foot hazards
Standard: Footwear must meet ASTM F2412/F2413 (the successor to ANSI Z41)
Key duty: Provide and require protective footwear matched to the identified foot hazard
Max penalty (2026): $16,550 per serious violation; $165,514 per willful
The #1 confusion: Employers need not pay for non-specialty safety-toe shoes allowed to be worn off the job

What 29 CFR 1910.136 requires (plain English)

29 CFR 1910.136 requires protective footwear in general industry wherever there is a danger of foot injuries from falling or rolling objects, from objects piercing the sole, or where footwear will protect against an electrical hazard, such as static-discharge or electric-shock, that remains after other protective measures. It is applied with the PPE hazard-assessment duty in 1910.132.

Modern protective footwear is certified to the ASTM F2412 (test methods) and F2413 (performance requirements) standards, which replaced the older ANSI Z41 standard OSHA originally referenced; OSHA recognizes footwear meeting the current ASTM standards or the earlier ANSI edition. Footwear can be rated for impact and compression (safety toe), puncture resistance (a puncture-resistant plate), metatarsal protection, and specific electrical properties: electrical-hazard (EH) rated to resist shock, conductive (CD) to dissipate static where a spark is dangerous, or static-dissipative (SD).

Because the electrical properties are opposites, EH insulates while conductive footwear intentionally drains static, the correct rating depends entirely on the hazard, and the two must not be confused. The employer selects footwear from the 1910.132(d) hazard assessment. Notably, OSHA's PPE payment rule does not require the employer to pay for non-specialty safety-toe footwear (or ordinary prescription safety eyewear) when the employer allows it to be worn off the job site.

The regulatory text

“The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.”

29 CFR 1910.136(a)

Key facts about 29 CFR 1910.136

Protective footwear is required for falling/rolling-object, sole-puncture, or residual electrical hazards (1910.136(a)).
Footwear must meet ASTM F2412/F2413 (or the earlier ANSI Z41) (1910.136(b)).
Ratings include impact/compression (safety toe), puncture resistance, metatarsal, and electrical (EH/CD/SD).
Electrical-hazard (EH) footwear insulates against shock; conductive (CD) footwear drains static: opposite purposes.
The correct rating depends entirely on the hazard identified in the assessment.
Employers need not pay for non-specialty safety-toe footwear allowed to be worn off the job (1910.132(h)(2)).
1910.136 is enforced together with the 1910.132(d) hazard assessment.

Scope: who 29 CFR 1910.136 applies to

Regulatory framework: General Industry (29 CFR 1910)
Citation reference: 29 CFR 1910.136
Enforcement status: In force and enforced
Jurisdiction: Federal OSHA (29 State-Plan jurisdictions may be stricter)

State-Plan states (e.g. California, Washington, Michigan) operate OSHA-approved programs that must be at least as effective as federal OSHA and frequently impose higher penalties or additional requirements. Confirm the rule as adopted in your state.

Key requirements of 29 CFR 1910.136

#	Employer obligation
1	Provide safety footwear for identified hazards
2	Use ASTM F2412/F2413-compliant footwear
3	Select appropriate type (impact, compression, metatarsal)
4	Consider electrical hazard-rated footwear near live circuits

Summarized from the text of 29 CFR 1910.136. Always read the full regulation for the binding language.

Common Foot Protection violations

Deficiencies OSHA cites under 29 CFR 1910.136 include the ones below, in no particular order. Distinct deficiencies can be cited as separate items, and each serious item carries up to $16,550 (2026). Broader per-instance stacking exists but is a discretionary, case-by-case OSHA enforcement policy, not an automatic multiplier.

No protective footwear where falling or rolling objects endanger the feet (1910.136(a)).
No puncture-resistant footwear where sole-piercing hazards exist (1910.136(a)).
Footwear not meeting ASTM F2412/F2413 or ANSI Z41 (1910.136(b)).
Wrong electrical rating for the hazard (EH where conductive is needed, or vice versa): 1910.136(a).
No metatarsal protection where heavy objects could strike the top of the foot (1910.136(a)).

Electrical-hazard footwear and conductive footwear do the opposite job

The most consequential foot-protection error is mixing up the electrical ratings. Electrical-hazard (EH) footwear insulates the wearer to reduce the risk of shock from contact with energized parts; conductive (CD) footwear does the reverse: it deliberately drains static charge to ground where a static spark could ignite explosives or flammable vapors. Using EH boots where static dissipation is needed, or conductive boots near live electrical work, is a dangerous mismatch. A second point: OSHA's payment rule does not force the employer to buy non-specialty safety-toe shoes if the worker is allowed to wear them off site, but the employer still must ensure appropriate footwear is used.

What OSHA inspectors look for

A compliance officer identifies impact, puncture, and electrical foot hazards, checks that workers wear footwear rated for them, and confirms the electrical rating matches the hazard (EH to insulate, conductive to dissipate static). Using the wrong electrical rating, or no puncture protection where sharp objects are underfoot, are common findings.

Example: how a violation is cited

A worker in a foundry wears ordinary shoes where heavy molds are moved, and a dropped mold crushes a foot. OSHA cites 1910.136(a) for the missing protective footwear where a falling-object hazard existed, with penalties from $16,550.

Illustrative example, not a specific OSHA case.

Foot Protection compliance checklist

Use this to evaluate your compliance with 29 CFR 1910.136. Each item is a key requirement OSHA may verify during an inspection.

Use the 1910.132(d) hazard assessment to identify impact, compression, puncture, and electrical foot hazards.
Select footwear certified to ASTM F2412/F2413 with the ratings the hazards require.
Match the electrical rating to the hazard: EH to insulate against shock, conductive to drain static.
Add puncture-resistant plates or metatarsal guards where those hazards are present.
Ensure footwear fits and is maintained; replace it when the protective features are compromised.
Document who must wear protective footwear and confirm it is actually used in the hazard areas.

2026 penalties for 29 CFR 1910.136

Maximums set by 29 CFR 1903.15(d). 2026 amounts unchanged from 2025 (no CPI adjustment; OMB M-26-11). Not an increase. The 2025 OSHA penalty levels remain in effect for 2026; OSHA made no inflation adjustment for 2026. 29 CFR 1903.15 identifies January 15, 2025 as the effective reference for these amounts, while OSHA's public penalties page currently references penalties assessed after Jan. 15, 2026.

Violation type	Minimum	Maximum	When it applies
Serious	$1,085	$16,550	Substantial probability of death or serious physical harm.
Other-Than-Serious	$0	$16,550	Relates to safety/health but unlikely to cause death or serious harm.
Willful	$11,823	$165,514	Intentional, knowing, or voluntary disregard of the requirement.
Repeated	$4,256	$165,514	A substantially similar violation cited within the last 5 years.
Failure to Abate	None	$16,550/day	up to $16,550 per day; total capped at 30x the daily amount (FOM Ch.6)

Foot-protection citations follow foot injuries and PPE inspections. Serious violations reach $16,550 and willful or repeat violations $165,514; missing footwear and wrong electrical ratings are the usual findings.

Maximums and the willful minimum are set by 29 CFR 1903.15(d); the serious and repeated minimums are OSHA policy floors from its annual penalty adjustment memo. OSHA applies gravity-based and size, good-faith and history reductions (FOM CPL 02-00-164 Ch.6). Estimates only, not legal advice.

The business case for Foot Protection compliance

Feet are exposed to crushing, punctures, and electrical hazards in most industrial settings, and the injuries are disabling. Matching the footwear rating to the hazard (safety toe, puncture plate, or the correct electrical rating) prevents injuries that ordinary shoes cannot.

Free compliance tools for 29 CFR 1910.136

PPE Selector Job Hazard Analysis Builder

Foot Protection penalties by state

Penalties and enforcement vary by state. State-Plan states may impose higher penalties and additional requirements beyond federal 29 CFR 1910.136.

Alabama Arkansas Colorado Connecticut Delaware District of Columbia

View all 50 states + DC →

Frequently asked questions about 29 CFR 1910.136

When is protective footwear required under OSHA?

Under 1910.136(a), an employer must ensure each affected employee uses protective footwear where there is a danger of foot injuries from falling or rolling objects or from objects piercing the sole, or where footwear will protect against an electrical hazard that remains after other measures. The specific hazards (impact, puncture, or electrical) determine the ratings the footwear must carry.

What standard must safety shoes meet?

Protective footwear must meet ASTM F2412 and F2413, the test-method and performance standards that replaced the older ANSI Z41 standard OSHA originally referenced under 1910.136(b). Compliant footwear is marked with the ASTM rating, which identifies the impact and compression levels and any added protections such as puncture resistance, metatarsal guards, or electrical ratings.

What is the difference between electrical-hazard and conductive footwear?

They serve opposite purposes. Electrical-hazard (EH) footwear insulates the wearer to reduce the risk of shock from contact with energized parts. Conductive (CD) footwear does the reverse, draining static electricity to ground where a static spark could ignite explosives or flammable atmospheres. Because the ratings are opposites, the correct one depends entirely on the hazard, and using the wrong type can be dangerous.

Does the employer have to pay for safety shoes?

Not always. OSHA's PPE payment rule generally requires employers to pay for required PPE, but 1910.132(h)(2) carves out an exception: the employer need not pay for non-specialty safety-toe protective footwear (or ordinary prescription safety eyewear) if it is allowed to be worn off the job site. Specialty footwear, and situations where off-site wear is not permitted, remain the employer's cost.

Regulatory history of 29 CFR 1910.136

1910.136 was updated in 1994 (59 FR 16360) as part of OSHA's revision of the PPE subpart, originally referencing ANSI Z41. OSHA later recognized the ASTM F2412 and F2413 standards that succeeded ANSI Z41 when that standard was withdrawn. The employer-payment framework for foot protection, including the non-specialty-footwear exception, was set by OSHA's 2007 PPE payment rule (1910.132(h)).

Related glossary terms

Key terms that appear in 29 CFR 1910.136, each with a full plain-English explainer.

Personal Protective Equipment (PPE)Hierarchy of Controls Engineering Controls

Related guides & articles

Personal Protective Equipment (PPE) Construction Guide OSHA PPE Fit Rule (Construction, 2024): 1926.95

Related OSHA standards

29 CFR 1910.132

PPE General Requirements

29 CFR 1910.133

Eye & Face Protection

29 CFR 1910.135

Head Protection

29 CFR 1910.138

Hand Protection

Primary sources

OSHA figures on this page are imported from HazComFast's verified regulatory module (verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register).

This page is an educational summary, not legal advice. OSHA standards and penalty amounts change; confirm requirements against the current regulation and your applicable State-Plan before acting.

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