Replacing your safety boot insoles with one that has not been approved and certified for use by the boot manufacturer, can negate the safety standard.

What is the purpose of insoles?

Insoles in footwear have been used for a very long time and are a necessary part of the shoe making process. They are either glued (non-removable) or removable. The small piece of material that sits underfoot in your boots is often taken for granted but can affect and influence many things from your posture, and subsequently joint pain, through to tired legs or even how sweaty your feet get!

In this article we’ll focus specifically on over the counter insoles rather than custom-made orthotics which may be required for more advanced or serious foot conditions.

Why do people buy insoles?

You may be asking, why do people buy insoles if the boots come supplied with them? There are usually a couple of reasons people buy their own insoles. Firstly, if their boots are being provided for them by their company they are likely to have limited influence over the choice but will still want to improve the comfort, so the simplest solution is to buy a cushioned insole. Secondly, footwear often wears out inside before the upper or sole has deteriorated and the insole can become flat and begin to smell. To increase the life of the boots a new insole will bring back the cushioning and freshen them up.

“replacing your safety boot insoles with one that has not been approved and certified for use by the boot manufacturer, can negate the safety standard”

We believe supportive insoles could make the critical difference between pain… and productivity. Did you know foot-related problems affecting knees, hips and backs, are the most common work-related health problems in the UK? They account for a startling 8.8 million working days lost to sickness each year, but the solution can be simple, as outlined by Paul’s statement below:

“As clinical research has progressively proven that work productivity in labour intensive environments is increased with the provision of better health care, footwear has become an increasingly important concern. A lack of correct support leads to comfort issues and pains that result in poorer performance and efficiency. Adding a fitted insole to the footwear of employees is a cost effective tool to increasing work productivity and comfort and is something that shouldn’t be ignored.”

Paul O’Malley | Musculoskeletal Podiatrist and Clinical Biomechanist

Supportive not corrective  

It is really important to note that replacement insoles should NOT be used to correct the foot, rather to support it. If you have a serious foot condition that has persisted for more than a month, you should visit a doctor or podiatrist and they can help with custom orthotics. Corrective insoles often have a rigid plastic or fibreglass arch support and these may feel unnatural in the shoe. Wearers will also be instructed to only use them for short periods of time, whereas a supportive insole can be worn all day.

The above pressure diagram clearly shows how insoles better support the foot, reducing the high force areas (shown in red).

Is the safe zone safe?  

Safety shoes are manufactured to protect feet in the event of an accident, and have been tested and certified to EN20345:2012 with a standard insole already in place.

Replacing your safety boot insoles with one that has not been approved and certified for use by the boot manufacturer, can negate the safety standard.

The reason why the above clause is included in the user manual is because safety toecaps are tested with heavy impacts to allow a ‘safe zone’ between the toecap and the insole to prevent foot injury. If a replacement insole is thicker it will decrease this area, and if a heavy impact is encountered it could crush or shatter your toes. I liken this to someone modifying their car and reducing the bonnet length – they have just reduced the crumple zone, and if they were to have an accident it would not be as effective in absorbing impact.

In addition, your work shoes are likely to be anti-static or even ESD (Electro-Statically Dissipative), so it is important that your insoles also meet this standard. Most insoles tend to have a stitch line running across the ball of the foot to maintain anti-static properties. Over time, this stitch line can cause aggravation and discomfort. There is new technology in the market that doesn’t have stitching but is still anti-static and you could consider these for improving comfort.

Softer = better?  

One of the most common myths is that cushioning is the answer to foot problems but in fact, cushioning alone is seldom the answer. Firm but gentle support is needed to maintain the proper alignment of the foot and joints, and also help the body to absorb step impact. Excessive cushioning can increase strain on muscles and tendons, using more energy, rather like walking on sand, increasing fatigue. So, in the same way that a very soft mattress may do more harm than good to your back, a very soft insole may also do more harm than good to your feet. Most people benefit from a firm insole with moderate cushioning particularly under the heel impact area. A good test of an insole is the “pinch test”. Take the insole between fore-finger and thumb. If it can be pinched flat then the insole may be neither thick enough or have the necessary density to provide the right level of cushioning.

“the Emirates Authority for Standardization & Metrology have released new Standards and guidelines in relation to Personal Protective Equipment (PPE)”

Sweating it  

Did you know that the average pair of working feet can sweat up to half a pint a day? This gross fact highlights the importance of having a good moisture wicking insole. Insoles that absorb moisture help to reduce the temperature of the foot whilst helping to keep it dry. In the absence of moisture wicking properties, sweat will not only breed bacteria and lead to issues such as athlete’s foot but will also soften the skin increasing risk of blistering. Moisture wicking properties largely depend on the insole material. Most insoles are produced using a compressed foam and are split into two types – open cell and closed cell. Both are produced using hundreds of air bubbles in the material, much like an Aero chocolate bar. However, a closed cell will not allow moisture to pass through and will also go flat after a period of wear. For these reasons, you should consider an open cell material for optimum moisture wicking and rebound properties.

It doesn’t affect me!  

The insole issue – we are only just starting to uncover the scale of the issue with people ‘customising’ their work boots. From our research in the field, on average, we are finding 2 in 5 people in the workplace are buying their own insoles for use in their work boots. With over 85% of safety boot-wearers wearing their boots for 5-7 days a week and a staggering 67% wearing work boots for more than 8 hours a day, it comes as no surprise that they are looking to improve their comfort with insoles.

Make sure your workforce is using compliant insoles to mitigate any risk of safety standards being compromised, or anyone getting injured.

New guidelines  

The ESMA (Emirates Authority for Standardization & Metrology) have released new Standards and guidelines in relation to Personal Protective Equipment (PPE) in the United Arab Emirates (UAE).

The relevant ESMA Regulation is:

“UAE Cabinet Decision No. 34 of 2016 – UAE PPE Regulation”

This covers all PPE, which is made/to be made available in the UAE Market – this is the scope of the Regulation, which requires Notified Body involvement. Once assessment has been conducted and approval granted, will result in the application of the ESMA Mark for PPE by a Manufacturer or Importer.

PPE is classified in the UAE in a very similar manner to that by which it is classified in the EU and the UK –3 categories:

   Category I – Protection for users against minimal risk

   Category II – Protection for risks not covered by Category I and III

   Category III – Protection exclusively the risks that may cause very serious consequences, such as Death or irreversible damage to health

ESMA has determined eight ‘Product Categories’ for PPE that the products must be classified as:

   Head protection

   Eye and face protection

   Hearing protection

   Respiratory protection

   Body protective clothing

   Hand protection

   Foot protection

   Fall management protection

Conformity assessment processes  

Category I PPE can be bought to market via a Manufacturers self-declaration/marking process, which must include a Declaration of Conformity to be supplied to the Notified Body, who will then issue a certificate to the Manufacturer for the PPE – no assessment is conducted.

“category I PPE can be bought to market via a Manufacturers self-declaration/ marking process”

There are two compliance routes available for Manufacturers/Importers to place products on the UAE market under Category II and one for Category III PPE; these also require involvement by a Notified Body:

   Emirates Conformity Assessment Scheme (ECAS) – which is Mandatory for Category II PPE

   Emirates Quality Mark (EQM), which is optional for Category II PPE, but mandatory for Category III PPE

ECAS and EQM both only allow one product Group per Certificate; however, the certification for ECAS is for a 1-year period only, whereas EQM is valid for 3 years. There are limits to the number of products allowable on each certification – 45 via ECAS and 100 via EQM.

The relevant ECAS and EQM marks must be applied to the product ideally or at least to the packaging if it is not possible to apply to the product.

ECAS Requirements (Category II PPE) Mandatory:

   Technical File including relevant test results that are no older than 5 years

   Demonstration of FULL compliance to the related Standard(s) for which certification is sought

   UAE Trade or Industry licence

   Declaration Of Conformity

   User Instruction Manual in both English and Arabic

   Quality Management Scheme Manual (I.E. ISO 9001 assessed/certified)

   Quality Plan for the product(s) concerned

   If relevant, an authorisation letter from the Manufacturer or Brand owner

EQM Requirements (Category II PPE) – Optional:

   Technical File including relevant test results (no age limit set on test reports, but must be to current version of relevant standards/test methods)

   Demonstration of FULL compliance to the related Standard(s) for which certification is sought

   UAE Trade or Industry licence

   Declaration Of Conformity

   User Instruction Manual in both English and Arabic

   Quality Management Scheme Manual (I.E. ISO 9001 assessed/certified)

   Quality Plan for the product(s) concerned

   If relevant, an authorisation letter from the Manufacturer or Brand owner

   Ongoing Assessment process, needs to be certified/assessed to at least one of the following:

     o   ISO 17067 Type 5 Module H (e.g. Kitemark or similar process)

     o   Benchmark Certification (Australasian requirement)

     o   ISO 13485

   The above will be ‘desktop’ assessed, with a physical audit taking place across 50% of all manufacturing sites

EQM Requirements (Category III PPE) – Mandatory:

   Technical File including relevant test results (no age limit set on test reports, but must be to current version of relevant standards/test methods)

   Demonstration of FULL compliance to the related Standard(s) for which certification is sought

   UAE Trade or Industry licence

   Declaration of Conformity

   User Instruction Manual in both English and Arabic

   Quality Management Scheme Manual (I.E. ISO 9001 assessed/certified)

   Quality Plan for the product(s) concerned

   If relevant, an authorisation letter from the Manufacturer or Brand owner

   Ongoing Assessment process, needs to be certified/assessed to at least one of the following:

     o   ISO 17067 Type 5 Module H (e.g. Kitemark or similar process)

     o   Benchmark Certification (Australasian requirement)

     o   ISO 13485

     o   PPE Regulation Module D assessment

     o   NISOH Product assessment

   The above will be ‘desktop’ assessed, with a physical audit taking place across 50% of all manufacturing sites across a 3-year period

PPE Standards for UAE  

PPE Standards in the UAE very much follow the European requirements, with EN standards and EN ISO standards being adopted, with the addition of UAE.S in front of any EN reference, E.G. UAE.S EN 166 General Requirements for Safety Eyewear.

A listing of the UAE PPE Standards (Which includes some ANSI, ANSI/ASA, ANSI/ASSE, NFPA and DIN Standards) can be downloaded from the BSIF website:

www.bsif.co.uk/wp-content/uploads/2021/02/ESMA-PPE-Standards-List.pdf

Notified Bodies  

There are a number of Notified Bodies in the UAE who can undertake the Conformity Assessment process to ECAS or EQM requirements (as well as certifying Category I PPE), and many of them also have offices here in the UK who may be able to act as introducers to their offices in the UAE.

As with any certification or conformity process, it is important that you check that the Notified Body you are using is suitably scoped for and able to assess/certify the products that you wish to place on the market and that they are also suitably approved to do so according to the requirements of the region or countries concerned.

Further details  

Link to ESMA Website:

www.esma.gov.ae/en-us/Services/Pages/Issuance-of-conformity-certificate-for-Personal-protective-Equipment-Products-According-to-the-health-and-safety-requiremen.aspx

Notified Bodies (ESMA Website): www.esma.gov.ae/en-us/Services/Pages/Notified-Bodies.aspx