OSHA Steel Toe Requirements: What 1910.136 Says, Word for Word

Paragraph (b)(1) lists the consensus standards that protective footwear must comply with. Any one of them is enough: ASTM F-2412-2005, “Standard Test Methods for Foot Protection”, together with ASTM F-2413-2005, “Standard Specification for Performance Requirements for Protective Footwear”; or ANSI Z41-1999; or ANSI Z41-1991. ASTM's standards replaced the ANSI ones, as OSHA's 2007 letter to the postal workers' union explains.

Paragraph (b)(2) is the route almost every boot on sale today actually uses, because the regulation, whose amendment history ends with a 2014 Federal Register notice, still names the 2005 ASTM editions rather than the 2011, 2018 or 2024 ones.

This is the question behind most searches for OSHA steel toe requirements, usually from someone whose offer letter says “steel toe boots” and who would rather wear something lighter. The short version: OSHA approves no footwear, steel or otherwise. Thorogood, a boot maker, puts it plainly in its ASTM guide: “OSHA does not test, approve, certify, or endorse any product.” OSHA's 2012 letter on footwear for a diabetic worker says the same about makers: “OSHA does not endorse or suggest any particular manufacturers.”

What OSHA cares about is whether the footwear meets the standard. A composite, carbon-fibre, alloy or aluminium cap goes through the same F2413 impact and compression tests as steel, and Thorogood's ASTM testing page states that composite toes meet the same certification as steel. A boot whose label reads, say, “ASTM F2413 M/I/C EH”, like Wolverine's Overpass composite-toe boot, has passed the same toe tests as a steel-toe boot with the same codes.

Your employer can still ask for more than OSHA does. If the written policy says steel specifically, that's a company rule, not a federal one, and the place to ask for an exception is your supervisor or safety lead. Bring the boot's rating line with you.

Paragraph (a) only switches on “in areas where there is a danger of foot injuries”. Whether your area qualifies is decided by your employer's hazard assessment, which the general PPE rule, 29 CFR 1910.132(d), requires before PPE is selected. The same paragraph says the employer must “Select PPE that properly fits each affected employee.” OSHA's December 2013 letter adds that a blanket “wear safety toes at all times” policy can be justified by that assessment.

OSHA's non-mandatory Appendix B to Subpart I gives the examples employers use to run that assessment. The table maps each hazard to the ASTM code that addresses it, using the wording OSHA and CCOHS publish. The finder at the top of the page uses the same mapping.

Construction work falls under 29 CFR Part 1926, not 1910, and its foot rule is a single sentence. Section 1926.96 reads, in full: “Safety-toe footwear for employees shall meet the requirements and specifications in American National Standard for Men's Safety-Toe Footwear, Z41.1-1967.” Its source note dates to a 1993 Federal Register notice.

That's all. The construction rule says nothing about puncture resistance or slip resistance. Thorogood's ASTM guide claims that “OSHA standards also require puncture-resistance and slip-resistance in footwear for construction workers”, but the text of 1926.96 quoted above contains no such requirement. PR can still be a sensible choice on a framing or demolition site, and Appendix B's nail example is the reason. But it comes from the hazard assessment, not from a federal construction mandate.

Construction's PPE rule, 1926.95, did gain fit wording in December 2024: PPE must be “selected to ensure that it properly fits each affected employee” (1926.95(c)(2)). A safety boot that's a size too big, or pinches at the cap, doesn't meet that test.

Appendix B lists occupations where foot protection “should be routinely considered”. Being on the list doesn't automatically mean safety toes are required for every task, and not being on it doesn't mean they aren't; it's a prompt for the hazard assessment. The listed roles include shipping and receiving clerks, carpenters, electricians, machinists, plumbers, welders, warehouse laborers, and timber cutting and logging workers.

Electricians are the case people most often get wrong. They're on the list because of dropped tools and materials, and electrical work also brings the EH question. Appendix B describes electrical-hazard footwear as “a supplementary form of protection”, and ASTM F2412-24 frames EH as protection “when accidentally stepping on live electric wires”. It's a backup, not permission to work on energized circuits.

Because 1910.136 still names the 2005 editions, a boot certified to F2413-11, -18 or -24 complies through the “at least as effective” route in (b)(2). OSHA's 2007 letter says “the burden lies on the employer” to show that equivalence. In practice, newer editions of the same ASTM standard are routinely accepted, but no federal OSHA letter we found names F2413-18 or F2413-24.

One state plan has said it in writing. North Carolina's SN 70B (2013) states that NC OSH “will consider safety footwear which is labeled as meeting the requirements of the 2011 ASTM standards as equivalent to the ANSI Z41.1 standards and the ASTM 2005 standards.” If you work in a state that runs its own occupational safety plan, check that plan's rules too; they can differ from the federal text quoted here.

Whatever the edition, what matters for your job is the codes on the label. Our ASTM F2413-18 decoder explains each one with its test value.

Nothing in 1910.136 regulates the shape of the footwear. A low-cut safety shoe, a pull-on wellington or a steel-toe sneaker meets the rule the same way a 6-inch lace-up does: by complying with the referenced standard or being shown at least as effective. Whether a low shoe is right for your job (ankle support, mud, hot slag) is a hazard-assessment question, not a 1910.136 one.

OSHA's 2012 letter on a diabetic worker is the clearest statement that the boot has to suit the wearer too. It notes that some makers market safety-toe shoes for diabetics with “extra wide fitting steel toe caps, and non-metallic toe caps”, and that protection “must not cause the employee harm”. If a standard boot hurts because of a medical condition, that's a conversation for your employer, and possibly your doctor, about a compliant alternative, not a reason to go without.