Boots on the Fireground: An Analysis of Interagency Wildland Firefighter Boot Standards Tim Lynch Project Leader Missoula Technology & Development Center August 2008 1 Contents Page Executive Summary 3 Introduction 4 Section 1: Boot Construction 6 Traditional Wildland Firefighter Boots Sole Categories “Vibram” and “Lug” Soles Sole Construction Methods Synthetic Insoles, Orthotic Inserts and Liners Steel-toed boots Section 2: Environmental Hazards and Agency Policies 14 Wildland Fire Hazards Puncture and Cut Hazards Blisters Aircraft Fire Hazards Chain-saw Hazards What Does ‘Adequate Ankle Support’ Mean? Requirements for Wildland Firefighting Footwear in Wet Environments Flame-Resistant Materials Durability Shock Attenuation Energy Expenditure Section 3: Regulations and Measurement Standards 21 OSHA Standards Agency Standards National Fire Protection Association Standard Section 4: Summary of Significant Findings 25 Traditional Wildland Firefighter Boots NFPA 1977 Standard OSHA Standard for PPE Fireline Handbook Standard Red Book Standard Mountaineering Boots Hazards Boot Components Section 5: Some Management Options 30 Appendix A: NFPA 1977 Standard on Protective Clothing and Equipment for Wildland Fire Fighting, 2005 Edition 32 References 44 2 Executive Summary The recent trend of wildland firefighters wearing mountaineering boots has prompted questions about whether these boots provide an adequate measure of safety and whether they meet interagency wildland fire standards. The primary concern is that contact with burning vegetation has caused the soles of some mountaineering boots to detach from the uppers. A secondary concern is that these kinds of boots may not adequately protect firefighters’ lower legs and feet from external hazards, including exposure to fire. In addition, smaller sizes of some men’s and women’s mountaineering boots do not meet the minimum boot height requirement in the Interagency Standards for Fire and Aviation Operations (Red Book). The Red Book standard doesn’t allow firefighters with smaller feet to wear certain models of boots that are highly favored by some firefighters. A review of interagency wildland firefighter boot policies revealed that some interagency policy documents contradicted one another. This review also showed that interagency wildland fire boot policies are vague in some respects and do not contain clear supporting definitions. Because of this lack of clarity, fire managers are sometimes unable to determine whether firefighters’ boots provide sufficient protection and meet interagency standards. This analysis confirms that traditional logger-style lug-sole boots provide an acceptable level of protection from the external hazards regularly encountered by wildland firefighters. However, recent footwear studies have shown that the previously unconsidered hazards of impact shock and boot weight also should be factored into policy decisions pertaining to firefighter’s boots. Studies show that boot soles that do not absorb shock well increase the potential for bone, joint, and soft tissue injuries. Studies also show that wearing heavier footwear increases the amount of energy expended, which can increase fatigue. Fatigue makes firefighters more prone to slips, trips, and falls, some of the leading causes of injuries, and also may contribute to repetitive motion bone and soft tissue injuries. There is a risk tradeoff with boots that do a good job of protecting firefighters against fire and other occupational hazards but leave them vulnerable to other injuries and excessive fatigue. The order in which information is presented in this paper is by design. If you read the section on boot construction first, then the section on hazards and policies, you will develop a base of knowledge that will make the section on regulations and measurement standards easier to understand. The summary of significant findings highlights key points from the first three sections. The paper concludes by offering some management options. For additional information contact Tim Lynch at 406-329-3958 or email tlynch@fs.fed.us 3 Introduction In October 2006, the Missoula Technology & Development Center (MTDC) began a project to evaluate standards for wildland firefighter boots used by employees of the Forest Service, U.S. Department of Agriculture, and the Bureau of Land Management, National Park Service, Bureau of Indian Affairs, and Fish and Wildlife Service, U.S. Department of the Interior. The standards of State wildland fire organizations were not included in this study. This review was requested by the Federal Fire & Aviation Safety Team (FFAST) in response to the growing trend of firefighters using mountaineering style boots for wildland firefighting. The project was approved and funded through the Forest Service Technology and Development Program’s Fire and Aviation Management Steering Committee. Mountaineering Boots: A New Twist on an Old Standard Until a few years ago, it was uncommon to see wildland firefighters wearing anything besides traditional logger-style boots. That changed when some enterprising firefighters discovered that two models of mountaineering boots made by a company called La Sportiva met the basic standards required by Federal land management agencies; allleather outer construction, lug traction soles, and eight-inch minimum height (when measured from the bottom of the heel). Firefighters who have switched to the La Sportiva boots usually cite comfort and/or lighter weight as the primary reasons for their conversion. As firefighters began wearing the La Sportiva boots on wildland fires, questions arose about their suitability for firefighting. Numerous accounts indicate the sole can separate from the boot upper when boots are exposed to fire-generated heat. Fire managers also have registered concerns over whether these boots are tall enough to adequately protect the lower legs and ankles of firefighters from common wildland firefighting hazards. In June 2005, the National Fire and Aviation Executive Board (an interagency board that provides guidance on Federal wildland fire policy) issued a memorandum confirming that these boots met the basic requirements for firefighting, but with an important caveat; “smaller sized men’s and women’s La Sportiva boots are not as tall as larger sized boots and may therefore not meet the minimum eight inch height standard.” Because of this idiosyncrasy, the NFAEB memorandum ended with the statement “it is incumbent upon each supervisor to insure the footwear being worn by their subordinates meet (sic) their specific agency standard.” 4 In spite of the height requirement issue, the La Sportiva mountaineering boots quickly became popular through word of mouth, and more firefighters began wearing them. Today, many hot shot crewmembers, smokejumpers, rappellers, engine crewmembers and others wear these boots on wildland fire assignments. Many converts to the La Sportiva boots prefer them over traditional logger-style boots despite their known susceptibility to delamination of the sole from the boot. Footwear for Soldiers and Firefighters When it comes to footwear, soldiers and wildland firefighters face similar challenges. Both groups are exposed to environmental hazards while hiking long distances carrying heavy loads over varied terrain. Soldiers and firefighters can both be rendered ineffective if their footwear breaks down, or if their feet or legs are injured (Milgrom & others 1992). Both soldiers and wildland firefighters may be exposed to flames. During busy fire seasons, the military is sometimes called upon to fight wildland fires. Because so many aspects of the missions of firefighters and soldiers are similar, footwear studies conducted by the military may have value for the Federal land management agencies that manage wildland fire. Natick Soldier Center Partnership The U.S. Army’s Natick Soldier Research, Development & Engineering Center in Natick, MA, conducts footwear research projects sponsored by all branches of the United States military. The U.S. Forest Service’s T & D program and the Natick Soldier Center have been exchanging information for many years. Natick engineers and researchers provided some of the data referenced in this paper. 5 Section 1: Boot Construction Traditional Wildland Firefighter Boots The basic design of standard logger-style leather boots used by wildland firefighters has changed little since the early twentieth century. The uppers (everything above the sole/heel) are made from heavy-gauge cowhide and generally are at least 8 inches high (figure 1). Figure 1: Some descriptive terms used in boot manufacturing. Boot laces routed back-and-forth through metal eyelets on the leading edges of the quarter cinch and secure each boot to the wearer’s foot. This design permits a snug fit and provides support around the firefighter’s ankles and lower legs. A fully gusseted tongue (fully gusseted means both sides of the tongue are stitched to the inside of the eyelet strip from bottom to top, see figure 2) keeps rocks, dirt and other friction sources out of the boots. 6 Figure 2: Lug-soled Wesco logger-style boot and a cutaway view. Sole Categories Two main categories of soles are used for logger-style boots. Loggers commonly use calked (called cork) boots studded with sharpened steel spikes for better traction on logs and slippery surfaces (figure 3). Because the steel spikes on calked boots conduct heat to the bottoms of the wearer’s feet, calked boots usually are considered unsuitable for wildland firefighting. Figure 3: Calked boot sole. The other category of boot sole used by loggers is the “Vibram-type” or rubber lug sole commonly found on the leather boots used by many wildland firefighters (see figure 2). Lug-soled logger-style boots usually feature a prominent heel and deep heel breast (see figure 1). 7 The relative merits of high boot heels are difficult to quantify or prove. White’s Boots advertises that the high heel improves arch support and comfort. It would be difficult to prove or disprove this claim without performing a comparative study of nearly identical boots with varying heel heights. In the course of conducting research for this paper, no studies on the biomechanical effects of work boots with high heels were found. However, several studies of other types of footwear indicate taller heels alter the wearer’s gait, posture, and muscle movements, which may lead to long-term bone and joint problems. “Vibram” and “Lug” Soles “Vibram” is the name of an Italian company, but the term is frequently used to describe any lug-soled footwear. The term “lug” refers to the molded projections on the underside of the boot’s sole that provide traction. Vibram actually makes many different types of soles with different tread patterns using different compounds. Other manufacturers make lug soles from rubber-based compounds that are similar in appearance and performance to Vibram lug soles. To further confuse the issue, Vibram does make a lug sole that meets the National Fire Protection Association 1977 Standard on Protective Clothing and Equipment for Wildland Firefighting: 2005 edition (appendix A), but the lug soles on most boots used by wildland firefighters have not been certified as meeting this standard. Sole Construction Methods When logger-style boots are assembled, both calked boot soles and lug soles are usually stitched to the boot uppers. Two frequently used variations of stitched sole construction include the Goodyear welt and the stitchdown method (figure 4). The midsoles of these boots generally consist of two or more layers of leather, sometimes combined with a synthetic layer. A metal alloy shank affixed to the leather midsole shapes and maintains the arch. 8 Figure 4: A boot sole being attached to upper using stitchdown construction method. Contact adhesives and one or two lines of stitching attach the boot soles to the uppers. Manufacturers of lug-soled boots sometimes use metal screws to reinforce the stitch line(s) around the sole. A combination of nails and screws attaches the heel (figure 5). Figure 5: Attaching the leather heel foundation to a Vibram lug-soled boot. When new, logger-style boots are quite stiff and relatively uncomfortable. These boots require breaking in so the leather conforms to the wearer’s feet and lower legs, and develops flex lines. During the break-in period, it is not uncommon for the wearer to develop friction blisters on the feet and shins. Once a pair of boots has been broken in, they are not easily transferred to another user. Hygiene issues and the difficulty of sanitizing used boots also make it undesirable to transfer used boots. Sole and shin blisters are less of a problem for firefighters once the boots are broken in, but firefighters sometimes develop blisters on their feet after extended hiking on steep terrain and sidehills regardless of their boots’ condition. 9 Boots with cemented sole construction (figure 6) use contact cement to attach pre-cast molded rubber compound soles directly to the uppers. This method is less secure than stitched sole construction, making boots with cemented soles more susceptible to delamination after exposure to heat or wet conditions than stitched sole boots. Figure 6: La Sportiva Glacier boot with cemented sole construction. The process of injection-molded boot sole construction, which is also called the direct attachment method, begins by placing a rubber compound outsole that has already been formed (figure 7) into a special mold beneath a sewn leather and fabric upper. Catalyzed polyurethane foam is injected into the space between the upper and the outsole, attaching the two components. After the polyurethane foam midsole hardens, each boot is removed from its mold and excess foam is trimmed away (figure 8). Figure 7: Vibram outsole of Wellco military boot. 10 Figure 8: Wellco military boot with injection-molded sole. A similar process is used to create ethylene vinyl acetate (EVA) midsoles for footwear. EVA midsoles absorb shock much like polyurethane midsoles. EVA midsoles are sometimes molded separately and then cemented to the outsoles and uppers. Although injection-molded boot soles are less durable than stitched boot soles, the polyurethane (or EVA) layer between the upper and outsole provides excellent shock absorption (also known as shock attenuation). Studies conducted at the Natick Soldier Center (Hamill and Bensel 1995) have shown that harder soles transmit more shock to the wearer’s feet and legs, potentially increasing the incidence of shock-related injuries to bones, joints, and soft tissue. In addition, injection-molded boot soles typically weigh significantly less than stitched soles. There is a direct correlation between boot weight and energy expenditure; the less weight firefighters have on their feet, the less energy they will use while walking or hiking (Jones and others 1983). Unfortunately, while polyurethane foam and EVA midsoles are good at reducing weight and increasing shock absorption, they are susceptible to heat damage. Industry standard boot tests indicate that most polyurethane or EVA midsoles begin to break down and melt before they reach 500 degrees F. A recent entry in the wildland firefighter footwear market is the Haix Wildfire U.S. boot (figure 9), an injection-mold constructed boot that features a heat resistant rubber compound outsole combined with a polyurethane midsole. This boot features a Gore-Tex vapor-permeable waterproof liner and is certified to the NFPA 1977 standard. A pair of these boots weighs approximately 1 pound less than a pair of logger-style boots of the same size. 11 Figure 9: Haix Wildfire U.S. boot. Synthetic Insoles, Orthotic Inserts and Liners Many removable insoles are available today that can be worn inside a firefighter’s boots. The main function of insoles is to reduce shock (Windle and others 1998); some insoles also reduce friction or prevent foot odor. Shock-absorbing insoles such as the Sorbothane insole use a solidified gel material to cushion shock. Orthotic inserts come in many materials and forms, most of which are custom shaped to the wearer’s feet. Orthotics keep the feet correctly positioned and fill the voids beneath the arches, helping to keep the wearer’s feet from shifting around inside their boots. The less feet move inside boots the less friction, which translates into fewer blisters. Vapor permeable waterproof liners are a relatively recent development in the boot industry. In most cases, one or more layers of Gore-Tex or other synthetic water barrier fabric are used to create a permanent inner boot liner. Many work boots now include vapor permeable waterproof liners, including some boots that meet the NFPA 1977 standard. Although synthetic insoles, orthotics, and liners may melt or burn, these materials are completely enclosed within the boot, which protects them from direct exposure to high levels of radiant or conductive heat. Steel-toed boots The term “steel-toed boots” is really a generic term for boots with crush-resistant toe shields. “Safety-toe boots” is another name sometimes used for this boot type. The protective toe shields may actually be made from metal alloys, plastic, or fiber/resin compounds. Toe shields are usually covered by the boots’ outer layer and are not removable. 12 Safety-toe leather boots are recommended for many work applications. Boots with metal toe shields are not generally recommended for firefighting because metal absorbs, retains, and retransmits heat. Wildland firefighters’ feet are frequently exposed to high conductive and radiant heat levels from standing or walking in burning materials (for instance when mopping up). Boots with metal toe shields would further limit their ability to work in those conditions. Heat usually is not a problem for boots with metal shanks because the shanks are covered by layers of leather and the outsole. In addition, the sole in the arch area has less direct contact with hot materials than the rest of the sole. A 2002 Canadian study found that wildland firefighters have a low incidence of impact injuries to the feet and that boots with protective toe shields were more likely to create foot irritation and discomfort (Ault 2002). The Canadian study examined injury statistics for wildland firefighters from the provinces of British Columbia and Alberta from 1996 through 2000. Alberta wildland firefighters wear safety-toe boots; British Columbia firefighters do not. During the study period, Alberta firefighters experienced 689 injuries from all causes, with only 5 impact injuries to the feet or toes. In the same period, the British Columbia firefighters had 1,787 total injuries, and 10 impact injuries to the feet or toes, which is statistically a lower percentage of total injuries than the safety-toe boot wearing Alberta firefighters. The study concluded that proper fit and comfort of footwear outweighed the occasional exposure to impact injuries. While safety-toe boots are not recommended for wildland firefighting, some agency policy sources recommend that chain-saw operators wear safety-toe boots (see Section 2). This would seem to be a contradiction because operating chain-saws is a common wildland firefighting task. Interagency wildland fire policies do not prohibit firefighters from wearing safety-toe boots. 13 Section 2: Environmental Hazards and Agency Policies The five Federal land management agencies that support wildland fire operations (Forest Service, National Park Service, Bureau of Land Management, Bureau of Indian Affairs, Fish and Wildlife Service) endorse the Interagency Standards for Fire and Aviation Operations, better known as the “Red Book.” Other interagency policy guides, such as the Interagency Helicopter Operations Guide (IHOG), include additional restrictive policy. In addition, agency-specific policies related to firefighter’s boots are included in agency policy documents. The Red Book is the source of the basic interagency boot standard for wildland firefighters. Page 7 of chapter 7 states: “Required Fireline PPE includes: 8-inch high, lace-type exterior leather work boots with non-slip, Vibram type, melt-resistant soles. The 8-inch height requirement is measured from the bottom of the heel to the top of the boot. Alaska is exempt from the Vibram-type sole requirement. All boots that meet the footwear standard as described above are authorized for firefighting.” Although the Red Book boot definition contains no reference to the NFPA 1977 standard, the section on Clothing and Personal Protective Equipment (PPE) in chapter 1 of the National Wildfire Coordinating Group (NWCG) Fireline Handbook includes the following bullet statements: All PPE must meet or exceed NFPA 1977 Standard on Protective Clothing and Equipment for Firefighters (current edition). and Wear 8-inch laced all-leather boots with slip and melt-resistant soles and heels. Because boots are specifically identified in the section on PPE, it is assumed the persons who crafted the language in the Fireline Handbook intended for boots to be included as part of the PPE. Many wildland firefighters wear boots that meet the Red Book definition but do not meet the Fireline Handbook definition. The Fireline Handbook requirement that mandates that all PPE must meet or exceed the NFPA 1977 standard has been largely overlooked or misinterpreted by fire program leaders. Wildland Fire Hazards One of the primary functions that wildland firefighter boots provide is preventing burn injuries caused by exposure to radiant, convective, and conductive heat produced by burning vegetation. On a given fire assignment, the number and duration of exposures to this hazard can vary from no exposure to prolonged exposure to high heat levels. 14 In fuel types with heavy surface and ground fuels, the burned litter and humus (duff) layer can be hotter than 1,000 degrees F for hours or even days. Burned-out stump holes and heavy fuel concentrations also can remain red-hot for days after a fire’s passage. In the course of a “typical” fire assignment, it is not uncommon for a firefighters’ boots to touch burning fuels for brief periods, such as when mopping up. The conductive heat transmitted through their boot soles usually discourages firefighters from standing or walking in burning fuels for very long. The track record of mountaineering boots used for wildland firefighting is relatively brief; accounts from users indicate that the La Sportiva boots are susceptible to damage from exposure to heat. In most cases, the glue that attaches the soles to the uppers appears to break down, allowing the soles to detach or partially detach. It should not be surprising to discover that footwear primarily designed to withstand low temperatures can be adversely affected by the extremely high temperatures of wildland fires. It has not been determined whether this vulnerability poses a significant safety issue. Puncture and Cut Hazards The wildland fire environment is filled with objects that can slice or pierce a firefighter’s feet and lower legs. Sharp rocks can damage the boots as well as feet. Cactus, briars and other aggressive vegetation can puncture boots and skin. Sharp ends of limbs and anglecut brush become “punji” sticks that can penetrate the feet and ankles. The soles of the boots protect firefighters from countless puncture hazards. Many manufacturers use a heavier gauge of leather on the lower sections of boots to shield the top and sides of feet from cuts and impacts. The tongues, laces and quarters (see figure 1) of boots protect the firefighter’s lower legs and ankles from sharp objects and tripping hazards. Tools also present puncture hazards for wildland firefighters. Mishandled tools can cut firefighter’s feet, ankles, or lower legs. A glancing hit from a combi-tool might do nothing more than leave a scar on the wearer’s boot. A direct blow from a sharp Pulaski could easily cut through any boot and the foot inside. Although MTDC was unable to obtain statistics on these types of injuries, some level of “armoring” is desirable in firefighters’ boots to protect their feet and lower legs from hand tools, as well as inadvertent contact with rocks, sticks, etc. High-quality cowhide leather has qualities that make it suitable for wildland firefighting footwear; it is durable, heat resistant, cut resistant and puncture resistant. Thick leather absorbs and redistributes light impacts to the feet and lower legs that might otherwise cause pain or minor injuries such as bruises. 15 In contrast, the ballistic nylon and Cordura used in modern military boots also are durable, cut resistant, and puncture resistant, but these relatively thin and pliable materials do not absorb or redistribute impacts as well as heavy-gauge leather. Additionally, ballistic nylon and Cordura can be damaged by temperatures hotter than 400 F, will readily burn, and will sustain flames after the heat source has been removed. In general, the higher quality heavy-gauge leather “logger-style” boots used for wildland firefighting have a good track record of providing protection from burns, impacts, punctures and cut hazards. This type of boot has also proven to be durable, despite the physical challenges posed by sharp objects, heat, water, chemical foams, retardant, and other influences. With proper care, a good pair of leather work boots can withstand two to three busy fire seasons without repairs. Blisters Friction blisters of the feet and lower legs are a common wildland firefighter malady. On large fires, blisters are one of the most frequent fireline injuries treated by incident medical specialists (Ault 2002). In many cases, the firefighter can return to work after treatment, but occasionally severe blisters require that the injured firefighter be removed from the fireline. On rare occasions, severe or infected blisters can become a lifethreatening condition. A number of factors contribute to blisters. The type of socks worn, the type of boots, the condition of the boots, degree of wetness, terrain features, hiking surface, distance hiked, recent work assignments and other factors influence whether an individual will develop blisters. Extended hiking in steep terrain, especially on sidehills, can lead to blisters. Aircraft Fire Hazards During aviation operations, boots need to protect firefighters from aircraft fires. Aircraft often burn after crashes, so wildland firefighter PPE worn in an aircraft must provide some protection against aircraft fires. The Interagency Helicopter Operations Guide (IHOG) contains several references to wildland firefighter PPE. From chapter 9, section D: D. Fire-Resistant Clothing. The primary purpose of fire-resistant clothing is to provide the wearer with protection from flash fire burns. 3. Shirt/Trousers Combination. The use of the wildland firefighter Nomex shirt and trousers (two-piece) are authorized. The shirt sleeves and trouser legs shall have sufficient length to allow overlap of the glove cuffs and boot tops, respectively. Shirt cuffs shall be worn down and fastened. 16 The main objective for having the trousers overlap the boot tops is to prevent skin on the lower legs from being exposed (and possibly burned) after a crash. Although the odds of any individual firefighter being involved in a helicopter crash are small, PPE standards have to continue to address this possibility. Chain-saw Hazards Wildland firefighters frequently fell and buck trees, two of many tasks that pose hazards to their feet and legs. The Forest Service Health and Safety Code Handbook (Forest Service Handbook 6709.11) contains several examples of agency-specific policies or recommendations that are more restrictive than those within either the Red Book or the IHOG. The Health and Safety Code Handbook, section 22.48c (Personal Protective Equipment) says: The following PPE is required for chain saw operations: 6. Chain saw chaps. The chain saw chaps shall meet the requirements of Forest Service Specification 6170-4; it is recommended that they overlap boots a minimum of 2 inches (51 mm). 7. Heavy-duty, cut-resistant or leather, waterproof or water-repellent, 8-inch high (204 mm) laced boots with non-skid soles (hard toes are optional). For further direction refer to FSM 6716.03, Personal Protective Equipment (Condition of Hire) Policy. The combination of heavy, cut-resistant or leather boots and overlapping chain saw chaps is to ensure protection from chain saw cuts. The Bureau of Land Management’s (BLM) Job Hazard Analysis databank states: Operators should wear heavy-duty, water-proof or water resistant work boots or logger’s boots: such boots should provide some protection from contact with cutting blade, i.e., leather boots with steel reinforced toes are recommended, rubber boots with steel toes are minimally acceptable. Boots should be high enough to protect ankles from contact with saw blade, and to provide adequate ankle support for walking on uneven terrain. 17 What Does ‘Adequate Ankle Support’ Mean? The term “adequate ankle support” is used in several land management agency documents that reference footwear. Many people have interpreted “adequate ankle support” to mean that any shoe that comes up to the ankle or slightly above provides adequate ankle support. For the purposes of this paper, it is assumed that “adequate ankle support” means that a boot will provide some protection against lateral or medial ankle sprains, the most common form of ankle injury. To meet this requirement, a boot must limit range of motion from side to side. To limit range of motion along these axes, a boot quarter (figure 1) must have some inherent stiffness and rigidity, fit snugly around the ankle, and extend at least a few inches above the intersection of the talus and tibia/fibula (ankle). Under these criteria, a boot or shoe that only comes up to or slightly above the ankle joint does not provide any measurable ankle support. The combination of the upper’s rigidity, height, and snug fit around the lower leg is what limits lateral and medial ankle motion, thus providing “adequate ankle support.” Requirements for Wildland Firefighting Footwear in Wet Environments Coastal plain forests and wildlife refuges in the southern United States, tundra in the interior of Alaska, and other fire-prone yet swampy areas pose unique challenges for firefighters. Footwear used by firefighters in these areas is often selected more for its ability to keep firefighters’ feet dry than to protect the feet from fire or impact injuries. Traditional logger-style leather boots are not waterproof. Eventually, even leather boots that have been treated to repel water will become waterlogged. When a firefighter’s feet are subjected to repeated long-term immersion in water, serious medical conditions can develop. Immersion foot, sometimes known as trench foot, is a serious medical ailment that can lead to swelling, blisters, sores and eventually gangrene, if left untreated. Fire managers in wetter portions of the country generally deal with prolonged immersion issues in one of two ways; Limiting the amount of time that firefighters spend with wet feet and ensuring that their feet have enough time to dry and recover. or Permitting the use of rubber boots or other footwear that will keep firefighters’ feet dry. 18 Flame-Resistant Materials Manufacturers of PPE such as firefighter shirts and trousers use the term “Flame Resistant” (FR) to identify fabric materials and thread that will not support open flame without an outside heat source. These materials resist active burning and will stop burning when the heat source is removed. Leather is considered an FR material. Commonly used FR fabrics and thread such as Nomex and Kevlar are light and strong. Although many different weights and types of weaves of FR fabrics are available, only a small fraction of the boots worn by wildland firefighters today use all FR components. Most wildland firefighter boots sold commercially today do not come with a detailed list of components and materials. Inexpensive boots sometimes feature synthetic materials that look nearly identical to real leather. However, some of these materials readily break down when exposed to moderate levels of heat. Synthetic boot materials can become a safety issue if boots melt or deform from exposure to temperatures normally encountered on wildland fires. Durability Although boot durability is not a safety issue by itself, poorly constructed boots can create problems. When a firefighter’s boots are damaged or compromised by exposure to conditions on the fireline, that firefighter is no longer able to contribute effectively. In such circumstances, a fireline supervisor not only has to replace or do without the sidelined firefighter, but may also have to find a way to transport the firefighter off the fireline. Durability is an important issue for many wildland firefighters who purchase their own work boots. A pair of custom top-of-the-line wildland fire boots can cost more than $400 today. Firefighters sometimes purchase less expensive boots to save money. Such boots’ useful life may be much shorter than the useful life of higher quality boots. Shock Attenuation Engineers use the term “shock attenuation” to describe the relative ability of a material to absorb or redistribute the force of an impact. All boot soles absorb or reduce shock to some degree. In general, denser sole materials transmit more shock to the wearer’s feet and legs. Repeated shock can injure bones and soft tissues, leading to painful and debilitating conditions such as stress fractures and shin splints (Milgrom and others 1992). Potential shock can be reduced in several ways. Removable shock-absorbing insoles, such as Sorbothane insoles, have been shown to reduce accumulative shock and related injuries (Windle and others 1998). Polyurethane and EVA soles and midsoles also attenuate shock well compared to denser materials. 19 Energy Expenditure The weight of wildland firefighter boots needs to be considered as it relates to energy expenditure. Under the best of circumstances, firefighting is hard work. Firefighters frequently hike long distances over rough terrain to accomplish their assignments. There is a tradeoff between heavier boots that provide superior protection and durability and lighter boots that provide less protection but require less energy to pick up and put down. Fatigue contributes to repetitive motion injuries of the feet, ankles, and legs (Hamill and Bensel 1995). Fatigue also makes firefighters more susceptible to slips, trips, and falls, some of the leading causes of injuries (Ault 2002). A 1983 NATICK study (Jones and others 1983) found a direct correlation between the weight of boots and energy expenditure. As the weight of test subjects’ footwear increased, so did their heart rates and the amount of energy they expended. Edward Frederick (1985) found that an increase of 100 grams of weight per running shoe increased a runner’s energy expenditure by about 1 percent. Table 1 was created using the assumption that Frederick’s running shoe weight-to-energy expenditure ratio remains constant when applied to heavier footwear. The comparison in Table 1 applies Frederick’s ratio to four different boot types. Under these parameters, a person wearing the 5.8-pound logger-style lug-soled boots would expend about 4 percent more energy than they would by hiking the same distance and course while wearing the 4.0 pound Wellco military boots. Table 1: Weights of different boot types and estimated increases in energy expenditure for heavier boots. Boots (size 10) Weight Weight Grams Percent increase in (pounds (grams per per boot energy expenditure per pair) pair) (over the next lighter boots on the list) Wellco military 4.0 1,814 907 La Sportiva Glacier 4.2 1,905 952.5 0.5 Haix Wildfire U.S. 5.0 2,267 1,133.5 1.8 Logger-style lug soled 5.8 2,630 1,315 1.8 20 Section 3: Regulations and Measurement Standards OSHA Standards The U.S. Department of Labor Occupational Safety and Health Administration (OSHA) is the primary federal entity charged with ensuring that workplace practices do not expose employees to unnecessary risks. Under section 19 of the Occupational Safety and Health Act and Executive Order 12196, Federal agencies are required to follow 29 CFR Part 1960: Elements for Federal Employee Occupational Safety and Health Programs. OSHA addresses most aspects of wildland fire safety under the general duty clause paragraph 29 CFR 1960.8(a) "to furnish each employee employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm." Because OSHA does not have specific standards for wildland firefighting, the following sections are interpreted to determine employer responsibilities pertaining to firefighter PPE and footwear. Personal Protective Equipment 1910.132(h)(1) Except as provided by paragraphs (h)(2) through (h)(6) of this section, the protective equipment, including personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees. 1910.132(h)(2) The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site. 21 1910.132(h)(4) The employer is not required to pay for: 1910.132(h)(4)(i) The logging boots required by 29 CFR 1910.266(d)(1)(v) 1910.132(h)(4)(ii) Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or 1910.132(h)(4)(iii) Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen. Logging Operations 1910.266(d)(1)(v) The employer shall assure that each employee wears foot protection, such as heavy-duty logging boots that are waterproof or water repellent, cover and provide support to the ankle. The employer shall assure that each employee who operates a chain saw wears foot protection that is constructed with cut-resistant material which will protect the employee against contact with a running chain saw. On November 15, 2007, OSHA published a lengthy ruling in the Federal Register relating to employers purchasing PPE for employees (Employer Payment for Personal Protective Equipment; Final Rule 72:64341-64430). This ruling does not appear to alter the present interpretation that Federal employers are not required to purchase “logging boots” (1910.132(h)(4), 1910.132(h)(4)(i)) or “normal work boots” (1910.132(h)(4)(ii)) for wildland firefighters. However, if Federal land management agencies endorse adoption/enforcement of the NFPA 1977 Standard for wildland firefighter boots, OSHA would likely determine that NFPA-compliant boots are “specialty” boots, which would make employers responsible for purchasing them. 22 Agency Standards One reason fire managers have trouble determining whether a boot meets agency standards is that many of the standards are imprecise and subject to broad interpretation. Because the land management agencies do not have a process to measure and test boots and their components, subjective terms like “heavy gauge leather” and “melt resistant soles” can be interpreted widely. An aspect of the Red Book measuring standard (figure 10) that needs scrutiny is the statement that the “8-inch height requirement is measured from the bottom of the heel to the top of the boot Figure 10: Red Book height measurement standard. This definition differs from the definition used by boot manufacturers in the United States. Most lace-up boots manufactured in this country are actually about 1 inch shorter than the height identified by the manufacturer. Boot manufacturers determine height by counting the number of pairs of eyelets, which are spaced about 1 inch apart. A standard boot with 10 pairs of eyelets would be labeled as a 10-inch boot, but measured from the bottom of the heel the boot would be about 9 inches tall. The top lines of traditional logger-style boots used for wildland firefighting are nearly perpendicular to the leg (see figure1). The top lines of the La Sportiva boots and many other mountaineering boots angle downward from front to rear (see figure 6). Because the Red Book does not specify whether the top line should be measured from the highest or lowest point, many firefighters have interpreted the “top of the boot” to be the uppermost part of the topline. Measuring a boot’s height from the bottom of the heel may not be an appropriate standard for wildland firefighter boots. A boot that had a very tall heel and relatively short upper would still meet the Red Book 8-inch height definition. 23 National Fire Protection Association Standard From the standpoint of clarity, the standard for boots from the NFPA 1977 Standard on Protective Clothing and Equipment for Wildland Fire Fighting (2005 Edition) is much more precise than the Red Book standard. The sections of the NFPA 1977 standard that pertain to boots alone cover more than 12 pages (appendix A). Representatives from the Missoula Technology and Development Center contributed to development of the original NFPA 1977 standard and continue to provide input through the NFPA Technical Committee on Wildland Firefighting Protective Clothing and Equipment. Compare the Red Book standard (figure 10), where a boot’s height is measured from the bottom of the heel to the uppermost part of the boot, with the NFPA 1977 standard (figure 11): 6.4.4 Footwear height shall be a minimum of 200 mm (8 in.). 6.4.4.1 The height shall be determined by measuring inside the boot from the center of the insole at the heel up to a perpendicular reference line extending across the width of the boot at the lowest point of the top line. Figure 11: NFPA 1977 height measurement standard. Note that the measurement is from the center of the insole at the heel, which means the heel is not included in the measurement. The top line measurement is taken at the lowest point of the top line- an important factor for boots with an angulated top line, such as the La Sportiva boots. 24 The NFPA standard is precise, and it guarantees that a boot meeting the standard will be tall enough to adequately support, cover and protect the ankle and lower leg. The NFPA 1977 standard does not specify that boots must be made of leather, but does require that they meet specific standards for puncture, cut, heat, and flame resistance. The testing and certification process for NFPA-compliant boots is very rigorous. Most of the major boot manufacturers today manufacture at least one model of boots certified to the NFPA 1977 standard. Manufacturers of NFPA-certified boots must pay a fee to submit samples of their product to an independent test facility for re-certification annually. 25 Section 4: Summary of Significant Findings Traditional Wildland Firefighter Boots The standard Vibram lug-sole logger-style boots manufactured by White’s, Nick’s, Drew’s, Wesco, Danner, and other long-established manufacturers: Have a good track record of protecting the feet and lower legs of wildland firefighters from wildland fire hazards. Provide some ankle support and protection against sprains. Are capable of tolerating harsh fireline environmental conditions without breaking down prematurely, and typically withstand 2 or more years of fireline use before needing repairs or replacement. NFPA 1977 Standard White’s, Nick’s, Drew’s, Wesco, Danner, and other long-established manufacturers of firefighter boots each manufacture at least one model of boot that complies with the NFPA 1977 Standard on Protective Clothing and Equipment for Wildland Firefighting (2005 edition). NFPA 1977-compliant boots are generally more expensive than similar boots that are non-compliant because of the costs of some NFPA-mandated materials, labels, and testing/certification fees. A relatively light weight NFPA 1977-compliant wildland firefighter boot is manufactured by a European company called Haix (pronounced ‘hikes’). The NFPA 1977 standard is the only standard for wildland firefighter boots that contains detailed supporting definitions. All other standards used by the Federal land management agencies require supervisors to make subjective interpretations. OSHA Standard for PPE OSHA does not require Federal employers to purchase “normal work boots” or “logging boots” for wildland firefighters. If the NFPA 1977 standard for wildland firefighter boots is endorsed by Federal land management agencies, OSHA would probably regard wildland firefighting boots as “specialty” boots, meaning that Federal employers would be required to provide boots for firefighters. 26 Fireline Handbook Standard Under the heading of “Fireline Clothing and Personal Protective Equipment (PPE),” the NWCG Fireline Handbook states “(a)ll PPE must meet or exceed NFPA 1977 Standard on Protective Clothing and Equipment for Firefighters (current edition).” Boots are one of the PPE items identified in this section. The current NWCG Fireline Handbook requirement for NFPA 1977-compliant boots exceeds the current Red Book standard. Agencies have only required compliance with the Red Book standard. Red Book Standard This is the current Red Book standard for wildland firefighter footwear: 8-inch high, lace-type exterior leather work boots with non-slip, Vibram type, meltresistant soles. The 8-inch height requirement is measured from the bottom of the heel to the top of the boot. Alaska is exempt from the Vibram-type sole requirement. All boots that meet the footwear standard as described above are authorized for firefighting. The intent of the term “Vibram type” in the standard is unclear. The Vibram corporation makes many kinds of outsoles, most of which are not melt-resistant or designed for firefighting. Other companies besides Vibram make melt-resistant boot soles; this portion of the definition appears to preclude their use by firefighters. Changing the wording from “Vibram type” to “lug type” would make this portion of the standard more descriptive and generic. Without supporting definitions to describe what combination of features makes a sole “melt-resistant,” fire supervisors are unable to determine if a firefighter’s boots meet this portion of the standard. The La Sportiva delamination problem has demonstrated that, in addition to the sole, the material used to attach the sole to the upper also needs to be heat resistant. The height measurement portion of the Red Book standard: May not be an appropriate way to measure the height of wildland firefighter boots because it includes the heel. Does not clearly identify whether the highest or lowest point of a boot’s top line should be used to determine a boot’s height measurement. Adopting the following language from the NFPA 1977 standard would eliminate questions about boot height measurement: The height shall be determined by measuring inside the boot from the center of the insole at the heel up to a perpendicular reference line extending across the width of the boot at the lowest point of the top line. 27 Mountaineering Boots The La Sportiva Glacier is the mountaineering boot most frequently worn by wildland firefighters. A small percentage of firefighters wear other La Sportiva boots such as the Lhotse, or mountaineering boots made by Scarpa and other manufacturers. The top lines of traditional logger-style boots used for wildland firefighting are nearly perpendicular to the lower leg. The top lines of the La Sportiva boots and many other mountaineering boots angle downward from front to rear; there may be an inch or more difference in height between the front and back of the top line of such boots. When measured from the bottom of the boot heel, the lowest point of the top line on a pair of size 10 men’s La Sportiva Glacier boots is 7.50 inches. The highest point of the top line is 8.50 inches. If the NFPA 1977 standard is applied, the height of the same boot would be just 6.25 inches, 1.75 inches shorter than the minimum requirement. Smaller sizes of men’s and women’s La Sportiva boots are even shorter. Men’s La Sportiva Glacier boots smaller than size 7 and women’s La Sportiva Glacier boots smaller than size 8 are not tall enough to meet the Red Book height requirement for wildland firefighter boots. Numerous anecdotal accounts indicate that the soles of La Sportiva boots may delaminate after relatively short exposures to burning vegetation. The La Sportiva company is aware of the problem with sole delamination and is exploring improvements for future models of La Sportiva boots. Other potential modifications La Sportiva is considering include increasing the height of the Glacier model’s upper. La Sportiva does not manufacture any boot models that are compliant with the NFPA 1977 standard. The company has not indicated plans to do so in the future. The wearing of La Sportiva and other mountaineering boots on wildland fires is a recent trend, and detailed injury data on firefighters wearing these boots is not available. For these reasons, it is not clear whether mountaineering boots such as the La Sportiva Glacier boots provide an acceptable level of protection for the feet and lower legs of wildland firefighters. Because of their short track record, and because detailed injury data is not available, it is not clear whether mountaineering boots such as the La Sportiva Glacier provide “adequate ankle support” or protection from sprains. 28 Hazards The term “adequate ankle support” is used in several agency policies without supporting information describing the combinations of boot features that would provide adequate ankle support. Boots providing some level of “armoring” against rocks, sticks, and tool strikes above the ankle is desirable. Single-layer leather uppers and tongues cushion and distribute moderate impacts better than a single layer of synthetic material such as ballistic nylon, Cordura, etc. Interagency aviation and chain-saw safety policies require PPE (trousers or chaps) to overlap the boot top. These policies help ensure that employees’ lower legs are protected from flash fire or chain-saw injuries. If the required boot height is lowered, it will be more difficult to ensure that employees’ lower legs are protected in these situations. The ability of boot soles to attenuate or absorb shock is an important issue that has not been well researched in relation to wildland firefighter footwear. However, the military and others have conducted studies showing that footwear with superior shock attenuation reduced hiking-induced bone and soft-tissue injuries to the feet and legs (Milgrom & others 1992). The effects of the weight of footwear on the performance and endurance of wildland firefighters has not been well researched. The military and other organizations have conducted studies indicating that persons hiking with lighter footwear will expend less energy than those with heavier footwear (Jones & others 1983). Shock attenuation and boot weight deserve careful consideration when considering changes to wildland firefighter boot standards. Some boots provide exceptional protection from external fireline hazards yet leave the wearer prone to repetitive shock injuries and unnecessary energy expenditure. There is a large body of existing data on footwear shock attenuation and the negative effects of footwear weight. The Federal land management agencies can gain an increased understanding of these issues by benchmarking off previous studies conducted by the military and others. For fire managers in fire-prone wetlands, keeping firefighters’ feet dry may be a more important safety consideration than protecting their feet from fire hazards. The amount of exposure to wet environmental conditions is a risk factor that should be considered when determining appropriate footwear for firefighters who regularly work in fire-prone wetlands. 29 Boot Components Hundreds of footwear companies manufacture boots. Most boots do not come with a detailed list of components and materials. NFPA 1977-certified boots must be made from FR components, are certified as such, and contain an identifying label. Inexpensive boots sometimes feature synthetic materials that look nearly identical to real leather. Some of these are not FR. They may break down when exposed to moderate levels of heat. Synthetic “leather” boot materials can become a safety issue if boots melt or deform after being exposed to temperatures normally encountered on wildland fires. The Fireline Handbook and Red Book PPE standards require that materials on the outside of boots be all leather. Although NFPA 1977-compliant boots generally feature a leather exterior, the standard does not require that NFPA-certified boots be made of leather. A boot’s exterior could be made from other FR materials and meet the NFPA 1977 Standard. Unless an employee happens to own a pair of NFPA 1977-compliant boots, land management agency field supervisors do not have a way to determine whether all components of any given employee’s boots are FR. Individually testing and researching every available boot to determine its components and suitability for wildland firefighting would be an impossible task for land management agencies. 30 Section 5: Some Management Options 1. Retain existing Red Book standard. Does not resolve current inability of field supervisors to determine whether an employee’s boots may include materials that break down rapidly when exposed to heat. Does not resolve questions of the appropriateness of measuring boot height from the bottom of the heel. Does not resolve questions of the appropriateness of measuring a boot’s top line at the highest point. Does not resolve questions about the ability of mountaineering boots to protect the lower legs and feet. Does not address durability/safety issues related to delamination of La Sportiva soles and other mountaineering boot soles when they are exposed to heat. Would allow continued use of La Sportiva and other mountaineering boots by wildland firefighters who wear larger boots. The current Red Book height measurement definition prevents people with smaller feet from wearing La Sportiva and other mountaineering boots for firefighting, creating an issue of fairness for some firefighters. Banning the La Sportiva boots would bring repercussions from firefighters who have purchased and wear them. 2. Adopt language from the NFPA 1977 standard for measuring height of wildland firefighter boots that would make the Red Book standard less subjective. Still leaves questions unanswered about identification of “synthetic leathers” and other individual boot components. Adopting language from the NFPA 1977 standard for boot height measurement would eliminate La Sportiva and other similar mountaineering boots from fireline use. 3. Adopt entire NFPA 1977 standard for wildland firefighter boots as the Red Book standard. Most wildland firefighter boots do not meet this standard. Most manufacturers of logger-style boots also make a NFPA 1977-compliant model. NFPA 1977- certified boots generally cost more than similar boots that are not NFPA compliant. 31 Lighter weight NFPA 1977-compliant boots such as the Haix Wildfire U.S. may provide some firefighters a suitable alternative to traditional logger-style boots. If agencies mandate use of NFPA 1977-certified boots by wildland firefighters, OSHA would likely interpret NFPA 1977-compliant boots as “specialty” PPE under OSHA Subpart 1910.132. Such a determination would probably require agencies to purchase boots for employees. 4. Lower boot height measurement requirement to permit any firefighter to wear La Sportiva and other mountaineering boots regardless of foot size. Does not resolve current inability of field supervisors to determine whether an employee’s boots may include materials that rapidly break down when exposed to heat. Does not resolve questions about the ability of mountaineering boots to protect the lower legs and feet. Does not address durability/safety issues related to delamination of La Sportiva soles and other mountaineering boot soles when they are exposed to heat. 5. Create clear, supporting definitions or eliminate the subjective requirement “sufficient ankle support” from agency and interagency policy documents. The current definition is so subjective it serves no useful purpose. 6. Resolve conflicts between agency and interagency boot policies. Land management agencies should review handbooks, manuals, and guides to ensure that agency policies do not conflict with interagency policies related to firefighter boots. Agency policies may exceed, but should not be less than interagency standards. The NWCG Fireline Handbook requires PPE to be NFPA 1977-compliant, which conflicts with the Red Book. This conflict should be resolved. Summary While heavy leather boots do a satisfactory job of protecting firefighters from fire and other external hazards, their weight and sole composition may contribute to long term bone and joint injuries. Anyone contemplating policy changes that will affect wildland firefighter footwear should consider shock attenuation and weight along with protection from external hazards. 32 Appendix A NFPA 1977 Standard on Protective Clothing and Equipment for Wildland Fire Fighting 2005 Edition 3.3* General Definitions. 3.3.29 Footwear. See 3.3.103, Wildland Fire Fighting Protective Footwear. 3.3.30 Footwear Upper. That portion of the footwear element above the sole, heel, and insole. 3.3.90 Throat. The center of the footwear entrance area behind the gusset, from its top line to the lowest point where it attaches to the vamp. 3.3.91 Top Line. The top edge of the protective footwear that includes the tongue, gusset, quarter, collar, and shaft. 3.3.97 Wear Surface. The bottom of the footwear sole, including the heel. 3.3.99 Wildland Fire Fighting Chain Saw Protection. Items of protective equipment that provides protection to the legs, or to the lower torso and legs, excluding the ankles and feet. 3.3.103 Wildland Fire Fighting Protective Footwear. Items of protective clothing that provides protection to the foot, ankle, and lower leg. 5.4 Protective Footwear. 5.4.1 Product Label Requirements. 5.4.1.1 Each footwear pair shall have a product label or labels permanently and conspicuously attached to each boot half pair. At least one product label shall be conspicuously located on or inside each boot when the boot is properly assembled with all components in place. 5.4.1.2 Configuration of the product label and attachment of the product label shall not interfere with the legibility of any printed portion of the product label. 5.4.1.3 Multiple label pieces shall be permitted in order to carry all the statements and information required to be on the product label. 33 5.4.1.4* The certification organization’s label, symbol, or identifying mark shall be permanently attached to the product label or shall be part of the product label. 5.4.1.5 All worded portions of the required product label shall be printed at least in English. 5.4.1.6 Symbols and other pictorial graphic representations shall be permitted to be used to supplement or in place of worded statements on the product label(s) where explanations for symbols and pictorial graphic representations are explained in the user information. 5.4.1.7 The following statement shall be printed legibly on the product label, and all letters shall be at least 2.5 mm (3⁄32 in.) high: “THIS WILDLAND FIRE FIGHTING PROTECTIVE FOOTWEAR MEETS THE REQUIREMENTS OF NFPA 1977, STANDARD ON PROTECTIVE CLOTHING AND EQUIPMENT FOR WILDLAND FIRE FIGHTING, 2005 EDITION. DO NOT REMOVE THIS LABEL.” 5.4.1.8 At least the following information shall also be printed legibly on the product label, with all letters at least 2mm (1⁄16 in.) high: (1) Manufacturer’s name, identification, or designation (2) Manufacturer’s address (3) Country of manufacture (4) Manufacturer’s footwear identification number, lot number, or serial number (5) Month and year of manufacture (not coded) (6) Model or style name, number, or design (7) Footwear size and width (8) Cleaning precautions 5.4.2 User Information. 5.4.2.1 The footwear manufacturer shall provide at least the user information that is specified in 5.4.2.5 with each footwear pair. 5.4.2.2 The footwear manufacturer shall attach the required user information or packaging containing the user information to the boot pair in such a manner that it is not possible to use the boots without being aware of the availability of the information. 5.4.2.3 The required user information or packaging containing the user information shall be attached to the boot pair so that a deliberate action is necessary to remove it. The footwear manufacturer shall provide notice that the user information is to be removed ONLY by the end user. 34 5.4.2.4 Symbols and other pictorial graphic representations shall be permitted to be used to supplement or in place of worded statements where explanations for symbols and pictorial graphic representations are explained in the user information. 5.4.2.5 The footwear manufacturer shall provide at least the following instructions and information with each footwear pair: (1) Pre-use information (a) Safety considerations (b) Limitations of use (c) Boot marking recommendations and restrictions (d) A statement that most performance properties of the boots cannot be tested by the user in the field (e) Warranty information (2) Preparation for use (a) Sizing/adjustment (b) Recommended storage practices (3) Inspection frequency and details (4) Donning/doffing (a) Donning and doffing procedures (b) Sizing and adjustment procedures (c) Interface issues (5) Proper use consistent with NFPA 1500, Standard on Fire Department Occupational Safety and Health Program, and 29 CFR 1910.132, “Personal Protective Equipment” (6) Maintenance and cleaning (a) Cleaning instructions and precautions with a statement advising users not to use boots that are not thoroughly cleaned and dried (b) Maintenance criteria and methods of repair where applicable (c) Decontamination procedures (7) Retirement and disposal criteria and considerations 5.4.2.6 Manufacturers shall be required to establish and provide, upon request, a size conversion chart for each model or style of protective footwear based on toe length, arch length, and foot width as measured on the Brannock Scientific Foot Measuring Device. 6.4 Protective Footwear Item Design Requirements. 6.4.1 Footwear items shall have at least the applicable design requirements specified in this section where inspected by the certification organization as specified in Section 4.3. 6.4.2 Footwear items shall consist of a sole with heel, upper, insole, and shank. The quarter section of the boot shall be designed to provide an adjustable, snug fit for support around the ankle and lower leg. 35 6.4.3 The heel breast shall not be less than 13 mm (1⁄2 in.). The heel breasting angle shall not be less than 90 degrees nor more than 135 degrees relative to the sole and as shown in Figure 6.4.3. 6.4.4 Footwear height shall be a minimum of 200 mm (8 in.). 6.4.4.1 The height shall be determined by measuring inside the boot from the center of the insole at the heel up to a perpendicular reference line extending across the width of the boot at the lowest point of the top line. 6.4.4.2 Removable insole inserts shall not be removed prior to measurement. 6.4.5 Metal parts shall not penetrate from the outside into the inside at any point, unless covered. 6.4.6 Where used, there shall be a minimum of four metal stud hooks on each side of the eyerow, and they shall meet the requirements of 7.4.2 and 7.4.8. 6.4.7 Eyelets shall be constructed of coated steel, solid brass, brass-coated nickel, or nickel. 6.4.8 All thread used to manufacture footwear shall be made of inherently flame-resistant fiber. 6.4.9 Sizing. 6.4.9.1 Protective footwear shall be available in all of the following sizes: (1) Men’s: 7–13, including half sizes and a minimum of three widths (2) Women’s: 5–10, including half sizes and a minimum of three widths 7.4 Protective Footwear Item Performance Requirements. 7.4.1 Footwear shall be tested for resistance to heat as specified in Section 8.4, Heat and Thermal Shrinkage Resistance Test, and, excluding laces, shall have no part of the footwear melt, shall have no delamination of any part of the footwear, and shall have all hardware remain functional. 7.4.2 Footwear metal parts shall be tested for resistance to corrosion as specified in Section 8.27, Corrosion Resistance Test. Metals inherently resistant to corrosion — including but not limited to stainless steel, brass, copper, aluminum, and zinc—shall show no more than light surface-type corrosion or oxidation. Ferrous metals shall show no corrosion of the base metals. Hardware shall remain functional. 7.4.3 Footwear shall be tested for resistance to cut as specified in Section 8.23, Cut Resistance Test, and shall have a distance of blade travel greater than 25 mm (1 in.). 36 7.4.4 Footwear shall be tested for resistance to puncture as specified in Section 8.24, Puncture Resistance Test, and shall have a puncture force of not less than 59 N (13 lbf). 7.4.5 Footwear sole and heel composites, excluding the sole and heel composites of caulked boots, shall be tested for resistance to abrasion as specified in Section 8.18, Protective Footwear Abrasion Test, and shall have an abrasion resistance rating of not less than 100 NBS index. 7.4.6 Footwear shall be tested for resistance to conductive heat as specified in Section 8.28, Footwear Conductive Heat Resistance Test, and the footwear inside sole surface temperature shall not exceed 44°C (111°F). 7.4.7 Footwear sole composites shall be tested for slip resistance as specified inASTM F 489, Standard Test Method for Using a James Machine, and shall have a minimum static coefficient of friction value of 0.5. 7.4.8 Footwear eyelets and stud hooks shall be tested for attachment strength as specified in Section 8.29, Eyelet and Stud Post Attachment Test, and shall have a minimum detachment strength of 294 N (66 lbf). 7.4.9 Footwear, without laces in place, shall be tested for resistance to flame as specified in Section 8.14, Flame Resistance Test for Protective Footwear, and shall not have an afterflame greater than 2 seconds and shall not melt, drip, or ignite. 7.4.10 Footwear product labels shall be tested for legibility as specified in Section 8.31, Label Durability and Legibility Test 1, and shall not be torn, shall remain in place, and shall be legible to the unaided eye. 7.4.11 All sewing thread utilized in the construction of footwear shall be tested for resistance to melting as specified in Section 8.9, Thread Heat Resistance Test, and shall not ignite, melt, or char. 8.4.13 Specific Testing Requirement for Protective Footwear. 8.4.13.1 Samples for conditioning shall be whole boots. Footwear specimens shall include sole, heel, and upper. 8.4.13.2 Conditioning shall be performed as specified in 8.1.1. 8.4.13.3 The footwear specimen shall be size 9. 8.4.13.4 Footwear specimens shall be filled with 4 mm (3⁄16 in.) perforated soda-line glass beads. Any closures shall be fastened. 8.4.13.5 The test thermocouple shall be positioned so that it is level with the horizontal centerline of a footwear test specimen. 37 The thermocouple shall be equidistant between the vertical centerline of a footwear test specimen placed in the middle of the oven and the oven wall where the airflow enters the test chamber. 8.4.13.6 The minimum dimensions for the test oven specified in 8.4.4.1 shall be 610 mm × 610 mm × 610 mm (24 in. × 24 in. × 24 in.). 8.4.13.7 The protective footwear test specimen shall be placed in the center of the test oven with the centerline of the front of the specimen facing the airflow. 8.4.13.8 Following removal from the oven, the specimen shall be allowed to cool at room temperature for not less than 5 minutes, +15/−0 seconds. 8.4.13.9 Each tested specimen shall be reconditioned as specified in 8.1.1 and then reexamined inside and outside for separation and functionality of hardware on the footwear. The functionality of each part of the footwear shall be reported as pass or fail. Failure of any one part shall constitute failure for the entire sample. 8.4.13.10 Testing shall be performed as specified in 8.4.2 through 8.4.7. Thermal shrinkage shall not be measured. 8.14 Flame Resistance Test for Protective Footwear. 8.14.1 Application. This test method shall apply to protective footwear. 8.14.2 Specimens. Three complete footwear items shall be tested. 8.14.3 Sample Preparation. 8.14.3.1 Samples for conditioning shall be whole boots. 8.14.3.2 Specimens shall be conditioned as specified in 8.1.1. 8.14.4 Apparatus. 8.14.4.1 The test apparatus shall consist of a burner, crucible tongs, support stand, utility clamp, stopwatch, butane gas, gas regulator valve system, and measuring scale. (1) The burner shall be a high-temperature, liquefied-type Fisher burner. (2) The stopwatch or other timing device shall measure the burning time to the nearest 0.1 second. (3) The butane shall be of commercial grade, 99.0 percent pure or better. (4) The gas regulator system shall consist of a control valve system with a delivery rate designed to furnish gas to the burner under a pressure of 17.3 kPa, ±1.7 kPa (2.5 psi, ±0.25 psi) at the reducing valve. The flame height shall be adjusted at the reducing valve to produce a pressure of 0.7 kPa, ±0.07 kPa (0.1 psi, ±0.01 psi). 38 8.14.4.2 A freestanding flame height indicator shall be used to assist in adjusting the burner flame height. The indicator shall mark a flame height of 75mm (3 in.) above the top of the burner. 8.14.4.3 A specimen support assembly shall be used to support the footwear specimen above the burner flame. 8.14.5 Procedure. 8.14.5.1 The burner shall be ignited, and the test flame shall be adjusted to a height of 75 mm (3 in.) with the gas on/off valve fully open and the air supply completely and permanently off, so that the flame height is closely controlled. 8.14.5.2 The 75 mm (3 in.) flame height shall be obtained by adjusting the orifice in the bottom of the burner so that the top of the flame is level with the marked flame height indicator. 8.14.5.3 With the specimen mounted in the support assembly, the burner shall be moved so that the flame contacts the specimen at a distance of 38 mm (11⁄2 in.) at the angles in the areas shown in Figure 8.14.5.3. 8.14.5.4 The burner flame shall be applied to the specimen for 12 seconds. After 12 seconds, the burner shall be removed. 8.14.5.5 The afterflame time shall be measured as the time, in seconds to the nearest 0.2 second, that the specimen continues to flame after the burner is removed from the flame. 8.14.5.6 Following the flame exposure, the specimen shall be removed and examined for burn-through. 8.14.5.7 Each layer of the specimen shall be examined for melting or dripping. 8.14.6 Report. 8.14.6.1 The afterflame time shall be recorded and reported for each specimen. 8.14.6.2 The afterflame time shall be reported to the nearest 0.2 second. 8.14.6.3 Observations of burn-through, melting, or dripping for each specimen shall be reported. 8.14.7 Interpretation. Pass or fail performance shall be based on afterflame time and any observed burn-through, melting, or dripping. 39 8.23 Cut Resistance Test. 8.23.1 Application. 8.23.1.1 This test method shall apply to protective gloves and footwear uppers. 8.23.1.3 Modifications to this test method for evaluation of protective footwear upper materials shall be as specified in 8.23.8. 8.23.2 Specimens. 8.23.2.1 A minimum of three specimens shall be tested. 8.23.3 Sample Preparation. 8.23.3.1 Samples for conditioning shall be whole gloves or footwear uppers. 8.23.3.2 Specimens shall be tested after conditioning as specified in 8.1.1. 8.23.4 Procedure. 8.23.4.1 Specimens shall be evaluated in accordance with ASTM F 1790, Standard Test Method for Measuring Cut Resistance of Materials Used in Protective Clothing, as modified by 8.23.7 and 8.23.8. 8.23.5 Report. 8.23.5.1 The distance of blade travel shall be recorded and reported to the nearest 1 mm (1⁄32 in.) for each sample specimen. 8.23.5.2 The average distance of blade travel in millimeters (inches) shall be calculated, recorded, and reported for all specimens tested. 8.23.6 Interpretation. 8.23.6.1 The average cut force shall be used to determine pass or fail performance. 8.23.8 Specific Requirements for Testing Footwear Uppers. 8.23.8.1 Samples for conditioning shall be whole footwear items. 8.23.8.2 Specimens shall be taken from the parts of the footwear upper that provides uniform thickness, and shall not include seams. 40 8.23.8.3 Cut resistance shall be performed under a load of 400 g (14 oz). 8.24 Puncture Resistance Test. 8.24.1 Application. 8.24.1.1 This test method shall apply to protective gloves and footwear uppers. 8.24.1.3 Modifications to this test method for testing footwear uppers shall be as specified in 8.24.8. 8.24.2 Specimens. 8.24.2.1 A minimum of three specimens measuring at least 150 mm (6 in.) square shall be tested. 8.24.3 Specimen Preparation. 8.24.3.1 Specimens shall be tested after conditioning as specified in 8.1.1. 8.24.4 Procedure. 8.24.4.1 All specimens shall be tested in accordance with ASTM F 1342, Standard Test Method for Protective Clothing Material Resistance to Puncture. 8.24.5 Report. The puncture force in newtons (poundforce) shall be recorded and reported for each specimen. 8.24.6 Interpretation. 8.24.6.1 The puncture force of each specimen shall be evaluated to determine pass or fail. 8.24.6.2 Any one puncture failing this test shall constitute failing performance. 8.24.8 Specific Requirements for Testing Footwear Uppers. 8.24.8.1 Specimens shall consist of each composite of footwear item used in the actual footwear construction, with the layers arranged in proper order. Specimens shall be taken from the thinnest portion of the footwear upper. 8.24.8.2 Testing shall be performed as specified in 8.24.2 through 8.24.6. 8.28 Footwear Conductive Heat Resistance Test. 41 8.28.1 Specimens. 8.28.1.1 A minimum of three complete footwear items shall be tested. 8.28.2 Sample Preparation. 8.28.2.1 Samples for conditioning shall be whole footwear. 8.28.2.2 Specimens shall be preconditioned as specified in 8.1.1. 8.28.3 Apparatus. 8.28.3.1 The apparatus shall consist of an iron plate measuring 25 mm × 150 mm × 460 mm (1 in. × 6 in. × 18 in.) and an oven capable of heating the plate to a temperature of 500°C (932°F), a Type J or Type K thermocouple, and a meter to read the thermocouple temperature. 8.28.4 Procedure. 8.28.4.1 The thermocouple shall be affixed to the insole surface of the specimen next to the foot, directly above the ball of the foot. The thermocouple shall be taped to the surface with electrical tape to hold it onto the insole surface. 8.28.4.2 The plate shall be heated to a temperature of 500°C, ±10°C (932°F, ±18°F) and shall maintain this temperature throughout the test period. 8.28.4.3 The specimen shall be filled with 4.55 kg (10 lb) of 10 mm (3⁄8 in.) steel balls. The weight of the steel balls shall be evenly distributed inside the boot. The specimen shall be placed on the plate in the upright position for 30 seconds. 8.28.4.4 The thermocouple temperature shall be recorded 30 seconds, +2/−0 seconds, after the specimen is placed on the heated metal plate. 8.28.5 Report. 8.28.5.1 The temperature at 30 seconds of exposure shall be recorded and reported for each specimen. 8.28.5.2 The average temperature at 30 seconds of exposure for all specimens shall also be calculated, recorded, and reported. 8.28.6 Interpretation. 42 8.28.6.1 The average temperature at 30 seconds of exposure for all specimens shall be used to determine pass or fail performance. 8.29 Eyelet and Stud Post Attachment Test. 8.29.1 Application. 8.29.1.1 This test method shall apply to protective footwear eyelets and stud posts. 8.29.2 Specimens. 8.29.2.1 Specimens shall total two eyelets and two stud posts on three separate footwear items. 8.29.2.2 Specimens shall be removed from the footwear and shall be 25 mm × 50 mm (1 in. × 2 in.). 8.29.3 Sample Preparation. 8.29.3.1 Samples for conditioning shall be whole footwear. 8.29.3.2 The eyelets or stud post specimens shall be conditioned as specified in 8.1.1. 8.29.4 Apparatus. 8.29.4.1 A tensile testing machine shall be used with a traverse rate of 50 mm/min (2 in./min). Clamps measuring 25 mm × 38 mm (1 in. × 11⁄2 in.) shall have gripping surfaces that are parallel, flat, and capable of preventing slippage of the specimen during the test. 8.29.5 Procedure. 8.29.5.1 The stud post or eyelet puller shall be inserted or attached to the upper position of the tensile machine. 8.29.5.2 The traverse rate shall be set at 50 mm/min (2 in./ min). 8.29.5.3 The test eyelet or stud post shall be attached using the appropriate puller fixture. 8.29.5.4 The eyelet stay shall be clamped, but clamping the metal portion of the eyelets of stud hooks in the lower clamps shall not be permitted. 8.29.5.5 The distance between the clamps and the stud hooks or eyelets shall be 2 mm to 3 mm (5⁄64 in. to 1⁄8 in.). 43 8.29.5.6 The test shall then be started. 8.29.6 Report. 8.29.6.1 The force will reach a peak, decline slightly, and then increase to complete failure; however, the value at which the force first declines shall be recorded and reported as the detachment strength, because this is the initial failure point where separation of the material around the eyelet or the stud post occurs. 8.29.6.2 Each detachment strength force shall be calculated, recorded, and reported. 8.29.7 Interpretation. 8.29.7.1 Each detachment strength force shall be evaluated to determine pass or fail performance. 8.29.7.2 Any single detachment strength force less than 294 N (66 lbf) shall constitute failing performance. 8.31.9 Specific Requirements for Testing Footwear Labels. 8.31.9.1 For testing label legibility after abrasion, specimens shall be individual labels. 8.31.9.2 A minimum of four specimens of each type of label shall be tested for abrasion. 8.31.9.3 Two specimens shall be edge specimens. 8.31.9.4 Where labels have areas for “write-in” information, two additional specimens shall be tested that include those areas, with sample information written in. 8.31.9.5 For testing label legibility after convective heat exposure, specimens shall be complete footwear with labels attached. 8.31.9.6 Sample conditioning shall be the same conditioning as specified for the respective tests. 8.31.9.7 Specimens shall be tested separately for legibility after abrasion and heat durability tests as specified in 8.31.4.2 and 8.31.4.3, respectively. 44 References Code of Federal Regulations Title 29 Volume 9 Part 1960; Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters OSHA Regulations Part 1910; Personal Protective Equipment 1910.132 OSHA Final Rule 72:64341-64430 Employer Payment for Personal Protective Equipment Interagency Standards for Fire and Aviation Operations (Red Book) Interagency Helicopter Operations Guide (IHOG) Forest Service Manual 6700; Chapter 6716 Personal Protective Equipment USFS Health & Safety Code Handbook Bureau of Land Management Job Hazard Analysis Databank National Fire and Aviation Executive Board Memorandum (June 2006) National Fire Protection Association 1977 Standard on Protective Clothing and Equipment for Wildland Firefighting- 2005 Edition The Shock Attenuation Characteristics of Four Different Insoles When Worn in a Military Boot during Running and Marching; Carol Windle, Sarah Gregory, Sharon Dixon 1998 Prevention of Overuse Injuries of the Foot by Improved Shoe Shock Attenuation: A Randomized Prospective Study; Milgrom, Charles; Finestone, Aharon; Shlamkovitch, N; 1992 The Energy Cost and Heart Rate Response of Trained and Untrained Subjects Walking and Running in Shoes and Boots; Bruce Jones, Michael Toner, William Daniels, Joseph Knapik 1983 The Energy Cost of Load Carriage on the Feet during Running; Edward Frederick 1985 Biomechanical Analysis of Military Boots Phase 3: Recommendations for the Design of Future Military Boots; Joseph Hamill, Carolyn Bensel 1995 Assessing the need for footwear with protective toecaps for wildland fire operations in Alberta; Ray Ault 2002 Interview w/ Dick Mangan on history of MTDC relationship w/ NFPA, 2/28/2006 45 Natick Soldier Center site visit and personal communication w/ Mike Holthe, Mechanical Engineer, 4/5/2006 West Coast Shoe Company factory tour and interview w/ Kris Oman, Wesco Production Manager, 12/4/2007 About the Author Tim Lynch has been a Fire & Aviation Project Leader at MTDC since 2001. His wildland fire career includes experience as an engine supervisor, crew supervisor, smokejumper, and helicopter rappeller. He is a Division/Group Supervisor and advisor to the NWCG Safety & Health Working Team, the Wildland Fire Safety Training Annual Refresher Working Group, the Interagency Helicopter Rappel Working Group and the Interagency Helicopter Rappel Equipment & Procedures Committee. Keywords: wildland firefighter boots, personal protective equipment, steel toe boots, safety toe boots, shock attenuation, energy cost 46