Q: In regard to work boots and arc flash protection, what does OSHA mean by “heavy-duty work shoes or boots” in 29 CFR 1910.269(l)(8)(v)(B)? Are boots made of synthetic material acceptable if they are work boots?
A: As with all OSHA rules, it is up to the employer to understand the risks and the necessary protections. In many cases the consensus standards give guidance that can be used to satisfy the OSHA standard. Even though NFPA 70E exempts utilities, OSHA has clearly used the NFPA as a source of material to assist utility employers in protecting employees, and the clothing standards in 70E may be a good place to start. NFPA 70E is not an adopted standard, but as OSHA stated in an October 18, 2006, letter to Michael C. Botts (see www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=interpretations&p_id=25540), “A national consensus standard … can sometimes be relevant to a general duty clause citation in the sense that the consensus standard may be used as evidence of hazard recognition and the availability of feasible means of abatement.” In Table (C)(10), NFPA 70E requires leather boots as needed.