HSE has been made aware of a potential issue regarding the testing of boots to an American Standard; ASTM F2412-18A.  

The ASTM Standard contains a single test procedure representative of a very restricted working environment. In many cases, these limitations have not been made clear on the packaging or the product instructions. This may result in the wearer believing the product has been tested to protect them in circumstances where it doesn’t. 

Footwear tested to this Standard is not suitable for live electrical working. 

The Standard specifies the footwear is subjected to a test of up to 18,000v AC although the manufacturer is responsible for determining the exact voltage resistance capabilities of the footwear.  

Footwear tested to this Standard has not been tested against direct current (DC) voltages. 

The Standard does not include tests for use in wet or damp environments and therefore the footwear should not also be marked to offer claims of waterproof, water resistant, water resistant upper, or other similar claims.  

The footwear will not offer protection from electric shock if the outer sole has been penetrated by a nail or other sharp object and therefore should not be marked with claims of penetration/perforation resistance.  

The Standard does not test the upper of the product and therefore may not be suitable for use where there is a risk of direct ground contact, “earthing” of the upper, such as: soft lose ground, (gravel, sand, soil, grass or mud), ladders, steps and gantries.

Action to take

Regulation 2016/425 which relates to the design and manufacture of PPE requires that any PPE that claims protection against electrical shock should be regarded as a Category III item and requires independent ongoing quality assurance of production control by an approved/notified body.  

You should check the Declaration of Conformity that accompanies the footwear to ensure it has been subjected to the third party approved/notified body assessment required for Category III PPE.  

The footwear will be marked with 4 digit number next to the UKCA/CE mark identifying the approved/notified body responsible for ongoing production control. 

If you provide electrical hazard protective footwear to your workers, you should revisit any relevant risk assessments to check that it is suitable for the purposes it is being provided. 

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