This article aligns with my previous article, "When are High-Vis garments no longer considered High-Vis?" It is in the same spirit of managing the PPE that so many workers rely on daily. And anyone who has been in safety for six months or longer can tell us horror stories of what they have seen with workers wearing and claiming some PPE is "protecting them."
Although OSHA does not require EH-rated safety footwear, many employers specify this rating for certain employees who may do "electrical work." If we specify that their safety footwear carries the EH (Electrical Hazard) designation, then should we not work to maintain that designation?
First, what does it mean when safety footwear has the EH designation?
ASTM F2413-rated safety footwear that carries the EH designation are constructed or manufactured with electric shock-resisting soles and heels capable of withstanding an application of 18,000 volts at 60 Hz for 1 minute, with no current flow or current leakage in excess of 1.0 milliamperes under dry conditions.
I wear EH-rated footwear and never do electrical work, as I am not qualified for such work; I do this just for added protection in many of the workplaces I visit.
But should workers who do electrical work be required to wear EH-rated footwear?
If you believe they should because they need that extra layer of protection, then shouldn't we have the means to test and measure the effectiveness of the footwear in protecting the worker from that electrical hazard?
EH footwear is intended to INSULATE the user from being a "path to ground" should they come into contact with a live circuit. This is the opposite of Static Dissipative Footwear, where we want the worker to remain well grounded so that any static charge they develop can go to the ground immediately and NOT accumulate to hazardous levels (e.g., enough to be an ignition source).
Like EH-rated footwear, the same goes for SD-rated footwear—we MUST provide a means to test/validate that the footwear provides the level of safety we desire.
Below is a video of a boot and wrist strap tester for SD-rated footwear. This device tests to ensure the worker is "grounded," and it is simple, easy, and quick. However, this device can also be used to test EH-rated footwear. As you will see in the video, if the SD footwear "passes," then when we test our EH footwear, we would want the device to "fail" (i.e., the worker is NOT grounded).
In my plant, where we required SD footwear, workers were required to test their footwear at least daily. We learned early on that limiting the footwear to be worn while ONLY working in the clean room extended its effectiveness. As soon as the soles of the footwear get "too dirty," they can fail their test. (See my other articles on failing these tests)
We will also have to be more generous in our Safety Footwear contributions as this specialty footwear will cost more, and it will rarely last a full year (e.g., it will fail its testing but otherwise be in good condition).
All of this will require an update to
- Our written PPE/Safety Footwear program,
- Our training program for the tester's use and
- The tester's maintenance program will require some validation testing and calibration, based on the manufacturer's recommendations.
