Does Your Employer Have to Pay for Steel Toe Boots? What OSHA Says

Posted by Gaurav Sethi on

Kiwi Premium Wheat Nubuck 6" Composite Toe Waterproof Cap-Toe Work Boots [69000]

Under federal OSHA rules, your employer usually does not have to pay for steel toe boots. OSHA makes employers pay for most required PPE, but 29 CFR 1910.132(h)(2) exempts non-specialty safety-toe footwear, steel toe boots included, as long as the employer lets workers wear them off the job site.

Specialty footwear, such as boots with built-in metatarsal guards, stays on the employer's bill. Any employer can choose to pay for more than the rule requires, and a union contract or a state rule can require it.

Kiwi tactical boots in sand suede and black lined up on a pickup tailgate

Who pays for PPE under OSHA?

The general rule is simple. Under 29 CFR 1910.132(h), employers must pay for the protective equipment their workers are required to use, with a short list of exceptions.

What counts as "required" comes from the employer's hazard assessment under 1910.132(d). For feet, 29 CFR 1910.136 requires protective footwear where there is a danger of foot injury from falling or rolling objects, objects piercing the sole, or electrical hazards. OSHA accepts footwear built to ASTM F2413 (or F2412) or an equivalent. Today's edition is ASTM F2413-24, and a boot rated I/75 C/75 has passed its 75 ft-lb impact and 2,500 lb compression tests for the toe.

So the employer decides whether safety-toe boots are required. Whether the employer must also pay for them is a separate question, and that's where the exception comes in.

Does an employer have to pay for steel toe boots under OSHA?

Not if two conditions hold. The boots must be non-specialty safety-toe footwear, which covers ordinary steel toe and composite toe work boots. And the employer must permit workers to wear them off the job site. When both are true, 1910.132(h)(2) says the employer is not required to pay.

In practice, an ordinary safety-toe boot goes home with the worker and often gets worn off the clock too. The same paragraph treats non-specialty prescription safety eyewear the same way.

Flip either condition and the exception falls away. If the employer requires boots to stay on site, the off-site condition isn't met. If the hazard assessment calls for specialty footwear, the exception doesn't cover it in the first place.

Composite toe and alloy toe boots

The exception is written around safety-toe footwear, with steel toe given as an example. A composite toe boot rated to ASTM F2413 is safety-toe footwear too, so the same reading applies. If you're choosing between toe materials, our composite toe vs steel toe vs alloy toe guide covers the differences.

What counts as specialty footwear?

OSHA's clearest example is metatarsal protection. Boots with metatarsal guards built in are specialty footwear, and the employer pays. Paragraph (h)(4) covers a common workaround: if the employer provides clip-on metatarsal guards and lets a worker choose boots with built-in metatarsal protection instead, the employer still pays for those boots.

None of our current boots carry a metatarsal (Mt) rating. If your hazard assessment calls for met protection, you need footwear or guards rated for it, and that cost belongs to the employer under the federal rule.

Is the rule different for construction?

Construction has its own parallel provision at 29 CFR 1926.95(d), with the same exception for non-specialty safety-toe footwear worn off site. A general contractor and a warehouse operator are working from the same basic payment rule.

Footwear situation Who pays under the federal rule Where it's written
Non-specialty steel or composite toe boots the worker may wear off site Employer not required to pay 1910.132(h)(2); 1926.95(d) for construction
Non-specialty safety-toe boots the employer keeps on site Employer pays (the off-site condition isn't met) 1910.132(h)(2)
Boots with built-in metatarsal guards Employer pays 1910.132(h)
Built-in met boots chosen instead of employer-provided met guards Employer pays 1910.132(h)(4)
Any footwear, when a union contract or state rule says the employer pays Employer, per that contract or rule The contract or state rule

This is general information, not legal advice. Read the regulation text, check your own hazard assessment, and confirm whether a state rule or labor agreement goes further than the federal standard.

Why some employers pay for safety boots anyway

The federal rule sets a floor. Paying for boots, in full or in part, gives an employer control over what shows up on site. When the company buys or reimburses, it can require a specific rating instead of hoping every new hire walks in wearing an ASTM F2413-24 boot with EH and SR. It also takes cost off the table as a reason to keep wearing a worn-out pair.

Replacement is part of this. Kiwi's instructions for use say to replace boots after any significant impact to the protective toe, even if no damage is visible. A boot program that only buys the first pair leaves that replacement up to the worker's wallet. Our guide on how long work boots last covers the inspection triggers.

How to set up a boot allowance program

Employer-paid programs tend to follow one of these models.

  • Fixed allowance. Each worker gets a set amount per year to spend on boots that meet the spec.
  • Reimbursement. Workers buy their own boots and turn in a receipt. The boots have to meet the spec to qualify.
  • Company-purchased boots. The employer orders from an approved list and issues boots directly, often with a replacement schedule tied to inspection.
  • Split cost. The employer covers part of an approved boot and the worker covers any upgrade beyond it.

Whatever the model, write the spec as ratings, not just "steel toe." A useful line reads something like: ASTM F2413-24 I/75 C/75, EH, SR, plus PR if nails and screws are part of the job. Waterproof is worth specifying separately for wet sites.

Standardize on a few boot styles

An approved list with two to four styles is easier to buy and reorder than a free-for-all. A practical starting point is one waterproof safety-toe boot for outdoor and wet work, one water resistant safety-toe boot for dry indoor work, and either a steel or composite option to cover site preferences. Composite toe is lighter than steel toe, which matters on a long walking shift.

The Rugged black composite toe waterproof boot is a good anchor for a list like this: DryVault waterproofing, a YKK zipper on the inner side, Nubora cushioning, and ASTM F2413-24 I/75 C/75 with EH and SR. Browse the rest of our safety toe footwear to fill out the list, or put styles side by side on the footwear compare page.

How to size a crew for safety-toe boots

A safety toe cap doesn't stretch, so a boot that's a half size short stays short. Collect sizes from each worker before you order, and check each boot family's own chart on our Sizing and Care page, since charts differ by family. Tell workers to lace the boot fully when trying it on. Fit and ankle support depend on it.

A printable checklist for a crew boot program:

  • Confirm the hazard assessment and list the ratings each role needs.
  • Decide whether boots may be worn off site, and put it in writing.
  • Check for union contract or state requirements that go beyond the federal rule.
  • Pick two to four approved styles and write the spec as ratings.
  • Collect sizes per worker, using each boot family's size chart.
  • Set a replacement rule: after any significant toe impact, or when tread is worn smooth, the sole separates or the toe is exposed.
  • Note who orders replacements and how fast.

Frequently asked questions

Does OSHA require employers to provide steel toe boots?

OSHA requires protective footwear where a hazard assessment finds a danger of foot injury from falling or rolling objects, objects piercing the sole, or electrical hazards. Requiring the boots and paying for them are separate questions. For non-specialty safety-toe boots that workers may wear off site, the federal rule does not require the employer to pay.

Does my employer have to reimburse me for safety shoes?

Under the federal rule, not for ordinary safety-toe shoes or boots you're allowed to wear off the job site. Your employer may still choose to reimburse you, and a union contract or state rule may require it. Ask HR or your safety manager how your company handles it.

What if my employer won't let me take my safety boots home?

The exception in 1910.132(h)(2) applies only when the employer permits the footwear to be worn off the job site. If boots must stay on site, that condition isn't met, and the general rule that employers pay for required PPE applies.

Who pays for metatarsal boots?

The employer. Boots with built-in metatarsal guards are specialty footwear, so the safety-toe exception doesn't apply. If the employer provides separate met guards and a worker chooses built-in met boots instead, the employer pays for those too, under 1910.132(h)(4).

Ordering boots for your company

For a company boot program, send us your approved styles and size counts through the request a quote page and we'll price the whole order. If you buy on a regular schedule or resell boots to your own customers, ask about a wholesale account at sales@kiwiworkwear.com.

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