Personal protective equipment (PPE) is a necessary part of laboratory safety in addition to engineering controls (i.e., laboratory ventilation and laser interlocks) and good work practices. When properly selected and used, personal protective equipment can be effective in minimizing individual exposure. Always inspect personal protective equipment prior to use, and if found to be defective, replace gear as appropriate. PPE is often used to augment engineering or administrative controls or is used as a stand-alone control when the other controls are not feasible.
It is the policy of Stanford University to maintain a safe and healthy work environment. Managers and supervisors are responsible for the establishment and maintenance of good health and safety practices. Cal/OSHA standards require that employers perform a hazard assessment of the workplace to determine the nature of the hazards and ensure that appropriate PPE is available to employees. Employers should use either the General Work Area PPE Assessment Tool or Laboratory PPE Assessment Tool to complete this assessment. The standards require that employees be trained in the proper use, care, and limitations of PPE.
Supervisors have the primary responsibility for implementing the PPE Program in their work area by ensuring that workplace hazards have been evaluated, that the appropriate PPE is available, and that employees have received the necessary training.
The PPE user is responsible for following the requirements of the PPE program. This involves:
- Wearing PPE as required per the PPE Assessment Tool;
- Attending site-specific PPE training sessions;
- Cleaning and maintaining PPE as trained
- Informing the supervisor of the need to repair or replace PPE
To determine the appropriate PPE to wear based on chemical and physical hazards encountered, consult with the PI or lab supervisor and review standard operating procedures (SOPs), safety fact sheets, and other hazard information.
For more information, contact the EH&S Occupational Health and Safety Program at (650) 723-0448.
Purpose
Stanford University is committed to providing a safe and healthy workplace for all faculty, staff, and students.
Controls to eliminate or minimize personal exposure to hazardous materials or physical hazards in the workplace include engineering controls, administrative controls, and the use of Personal Protective Equipment (PPE). PPE is often required to augment engineering or administrative controls, or is used as a stand-alone control when engineering and administrative controls are not feasible. When properly selected and used, personal protective equipment can be effective in eliminating or minimizing individual exposures to hazardous materials and physical hazards encountered in many different work environments.
This PPE program is designed to:
- Establish requirements for workplace PPE assessments, training, provision, use, and maintenance/replacement/disposal of PPE.
- Assign responsibilities for program implementation to all stakeholders regarding PPE management.
- Comply with California Occupational Safety and Health (Cal/OSHA), 8 CCR 3380, Personal Protective Devices, and other regulations seen in the Applicable Regulations & Guidelines tab.
Scope
This program applies to faculty, staff, and students who perform tasks involving hazardous materials and/or physical hazards or are potentially exposed to hazardous materials and/or physical hazards in either laboratory or general work areas.
Department Chairs, Lab Directors, and Department Health & Safety Coordinators
Department Chairs, Lab Directors, and Department Health & Safety Coordinators, as appropriate for the unit, are responsible for:
- Communication: Communicating and promoting this Program within their units.
- Department Requirements: Each department may promulgate and enforce more stringent PPE requirements than those identified by the laboratory or unit’s work area PPE assessment (e.g., requiring lab members to don lab coats and safety eyewear at the threshold of labs).
- Departmental Support: Supporting the Supervisor/Principal Investigator (PI)/Lab Supervisor, or his/her designee by implementing department-wide programs and/or services (e.g., acquisition of lab coat laundering services).
Supervisors, Principal Investigators (PIs), Lab Supervisors
The Supervisor or PI/Lab Supervisor (as applicable) is responsible for:
- Performing Hazard Assessments to Identify PPE: See the Workplace PPE Assessment tab.
- Local PPE Requirements: The Supervisor or PI/Lab Supervisor may establish more stringent PPE requirements than those as described in Section 6.1 (e.g., requiring lab members to don lab coats and safety eyewear at the threshold of labs).
- Providing site-specific PPE Training: See the PPE Communication and Training tab.
- Provision, Maintenance, Replacement, and Disposal of PPE: See the Provision and Maintenance of PPE tab.
- Enforcement: Ensuring the PPE identified in the Laboratory PPE Assessment Tool or General Work Area PPE Assessment Tool is worn, maintained, replaced, and disposed of properly.
- Recordkeeping:
- Maintain current written certification that the PPE assessment has been conducted in Section II of either the Laboratory PPE Assessment Tool or the General Work Area PPE Assessment Tool as appropriate.
- Maintain training records for at least one year. See Recordkeeping in the PPE Communication and Training tab.
The Supervisor or PI/Lab Supervisor may assign a designee to perform or assist in the above duties, but must ensure they are carried out.
Personnel Required to Wear PPE
Laboratory Personnel and General Work Area Personnel are responsible for:
- Training: Completing site-specific PPE training provided by the Supervisor, PI/Lab Supervisor, or his/her designee, which includes demonstrating the ability to use PPE properly.
- Use: Using correct and properly fitted PPE under the conditions identified by the Supervisor, PI/Lab Supervisor, or his/her designee in the PPE Assessment Tool, as well as wearing proper street clothing.
- Maintenance, Replacement, and Disposal of PPE: Maintaining, replacing, and disposing of PPE as trained. Informing Supervisor, PI/Lab Supervisor, or his/her designee when PPE is damaged or worn out.
Environmental Health & Safety
The Department of Environmental Health & Safety is responsible for the development and maintenance of the Stanford University PPE Program, including:
- Implementation Tools: Developing and distributing PPE assessment and training tools.
- Technical Assistance: When requested, assist Supervisors, PI/Lab Supervisors, or his/her designee with PPE assessments and training.
- • Quality Assurance Checks: Conducting periodic quality assurance checks of PPE compliance in work areas, which includes: (a) review PPE assessment/training records for completion; (b) evaluate PPE use; and (c) communicate those findings, as appropriate, to Supervisor, PI/Lab Supervisor, and Department Management.
Purpose
The PPE Assessment Tool is designed to: (a) determine if hazards are present or likely to be present in the workplace which may necessitate the use of PPE; and (b) select the correct PPE for the affected personnel based on the hazards identified.
Requirement to Conduct PPE Assessment
Each Supervisor, PI/Lab Supervisor, or his/her designee must assess PPE requirements for his/her work areas/activities:
- For laboratory areas:
- Use Section II of the Laboratory PPE Assessment Tool.
- For general work areas (e.g., shops, kitchens, loading docks, janitorial storage areas):
- Use Section II of the General Work Area PPE Assessment Tool.
Frequency
The PPE Assessment Tool is to be completed: (a) initially, and (b) when new hazards are introduced to the general work or laboratory area.
Recordkeeping
Maintain a written copy of the completed PPE Assessment Tool that reflects the current conditions of the general work or laboratory area.
- For laboratory areas:
Initial PPE Training
Each Supervisor, PI/Lab Supervisor, or his/her designee is required to ensure affected personnel are trained about site-specific PPE selection identified in the completed PPE assessment for that particular work area. Training must be done prior to performing work requiring the use of PPE and will include:
- When PPE is necessary
- What PPE is necessary
- Properly donning, doffing, adjusting and wearing PPE
- Limitations of PPE
- Proper care, maintenance, useful life, and disposal of PPE
Each trainee must demonstrate an understanding of the training and the ability to use PPE properly before being allowed to perform work requiring the use of PPE. Refer to the PPE Training Guidance document for more information.
Retraining
Retraining of personnel is required if there are:
- Inadequacies in the personnel’s knowledge or in the use of assigned PPE, indicating the lack of retention of the requisite understanding or skill;
- Changes in the workplace or types of PPE to be used that render the previous training obsolete.
Recordkeeping
- Document PPE training using Section III of either the Laboratory PPE Assessment Tool or the General Work Area PPE Assessment Tool, as applicable, which includes:
- Name and signature of trainee, date(s) of training, name and signature of trainer and subject of training (as described in item 1 in Section III).
- Maintain training records for personnel for at least one year.
- In the case of Radiation Safety training, the documentation is also maintained in the radioisotope journal within the laboratory for the duration of employment for each employee.
Provision of PPE
- For Employees: The Supervisor or PI/Lab Supervisor is responsible for the provision of PPE for employees.
- For Non-Employees: It is the discretion of the Supervisor or PI/Lab Supervisor to provide PPE for the non-employees. If not provided, the list of PPE required for the work assignments must be given to the individuals to acquire prior to their work assignment.
- For Students in Teaching Labs, Shops, or Field Work: It is at the discretion of the local department to provide lab coats and other PPE to students or to require them to supply their own. If not provided, the list of PPE required for the class must be given to the students prior to their class assignment.
- PPE Specifications: The PPE must meet the PPE specifications stated in applicable CAL/OSHA Title 8 standards, as well as properly fit the individual, be reasonably comfortable, and not unduly encumber the individual’s movements necessary to perform his or her work.
- Respirators and Hearing Protectors: Required respirator and hearing protector use involves EH&S assessment to identify the need and type, additional training, and medical surveillance; contact EH&S at (650) 723-0448.
- Safety Eyewear: Use ANSI-approved eyewear over prescription glasses or use prescription safety eyewear; prescription glasses do not constitute safety eyewear. See the safety eyewear tab for more information.
Where to Aquire PPE
The preferred method for all Stanford personal to acquire PPE is as follows:
- Using Stanford SmartMart
- For perscription safety glass purchases see the safety eyewear tab above
- For Lab Coat Laundering & Rental see Stanford University’s non-exclusive Cintas Merchandising & Pricing Agreement.
- For work-related use and purchase of respirators (N95, half face, & full face), you must contact EH&S for an evaluation first: (650) 723-0448.
On-Campus Physical Locations
Fisher Scientific:
- Fisher ChemStore: Lokey Laboratory (ChemBio) Building (337 Campus Drive), Room 168.
- Fisher BioStore: Herrin Biology Lab Building (385 Serra Mall), Room 80.
Your lab will need an active account with the store prior to making purchases; the account can be opened in the store.
For Lands, Buildings, and Real Estate (LBRE) Personnel Only:
- Grainger Store: 340 Bonair Siding Road, Room S112, Stanford, CA 94305 (Near Parking & Transportation Services, PT&S)
For Stanford Residential and Dining Enterprises (R&DE) employees:
- Slip-Resistant Shoes: Your direct supervisor will provide.
Maintenance, Replacement, and Disposal of PPE
- The Supervisor, PI/Lab Supervisor, or his/her designee is responsible for overseeing and providing for the appropriate care (e.g., cleaning, storage, disposal and replacement) and inspection of PPE.
- Follow manufacturer’s instructions for cleaning and maintenance of PPE. PPE must be maintained in a safe and sanitary condition. Defective or damaged PPE shall not be used.
- Laboratory coats must not be laundered in personal or public laundry facilities. The Supervisor, PI/Lab Supervisor or Department must provide for professional laundry service. See Stanford University’s campus-wide agreement on lab coat provision and laundry service.
- 8 CCR 3203 Injury Illness Prevention Program
- 8 CCR 3380 Personal Protective Devices
- 8 CCR 3381 Head Protection
- 8 CCR 3382 Eye and Face Protection
- 8 CCR 3383 Body Protection
- 8 CCR 3384 Hand Protection
- 8 CCR 3385 Foot Protection
- 8 CCR 5098 Hearing Protection
- 8 CCR 5144 Respiratory Protective Equipment
- 8 CCR 5191 Occupational Exposure to Hazardous Chemicals in Laboratories
- 8 CCR 5193 Bloodborne Pathogens
- 8 CCR 5194 Hazard Communication
- 8 CCR 5200 – 5220 Regulated Carcinogens
- 10 CFR 19 Notices, Instructions, and Reports to Workers: Inspections and Investigations
- 10 CFR 20 Standards for Protection against Radiation
- California Labor Code Section 6400-6413.5
- TITLE 17, Public Health, Division 1, Chapter 5, Sanitation (Environmental), Subchapter 4, Radiation (commencing at section 30100)
- Prudent Practices in the Laboratory, National Research Council, 2011
- Biosafety in Microbiological and Biomedical Laboratories (BMBL) 5th Edition (December 2009)
Selection
- No single material can protect against all chemical, physical (e.g., cuts, abrasions, burns, temperature extremes, etc.) or biological hazards. It is critical to select the correct glove for the hazard.
- Incorrect selection can result in a false sense of security and increased exposure. (A Dartmouth researcher died in 1997 from exposure to dimethylmercury, which penetrated her latex gloves.)
- To determine the correct glove for your laboratory chemical use, follow these steps:
- Consult Safety Data Sheets and chemical labels for general recommendations.
- Select gloves based on hazard levels (below).
- Check chemical resistance data of several glove manufacturers.
Hazard levels
Low
- Incidental chemical contact (i.e. an occasional drip or splash), except for corrosives or toxins that readily penetrate skin.
GENERAL INFORMATION
- Disposable nitrile gloves are appropriate for most laboratory tasks. Nitrile gloves generally provide better chemical resistance than latex gloves, are less likely to rip or tear, and are less likely to cause skin allergies.
- It is important to understand that disposable gloves are not designed to provide significant or prolonged chemical resistance. After contact with any chemical, remove the gloves promptly, wash your hands, and obtain new gloves.
Moderate — High
- Handling of corrosives and toxins that readily penetrate skin
- When skin contact is likely with carcinogens, reproductive toxins, and other highly toxic chemicals.
GENERAL INFORMATION
- The glove material must adequately protect the hands from chemical permeation and/or breakthrough.
- For selecting the proper gloves, review glove manufacturer information on chemical resistance. See below for information from several major glove manufacturers.
Inspections
- Inspect gloves before and after each use.
- Check for perforations by inflating gloves with air or water.
- Inspect visually for tears or rips.
- Discoloration or stiffness may indicate chemical degradation.
- Torn or damaged gloves should be replaced immediately.
Use
- For disposable gloves, replace when chemical contact occurs, or when damage is suspected.
- Wash hands after removing gloves (even when double gloving).
- Remove gloves before you leave the lab or before handling objects such as doorknobs, telephones, or computer keyboards.
- Use designated pens when wearing gloves.
Cleaning and storage
- For reusable gloves, wash after removal and air dry in lab.
- Store gloves in a clean area away from chemicals, temperature extremes, and other hazards.
Disposal
Dispose of contaminated gloves in the proper hazardous waste container.
Glove manufacturers
When employees are required to wear safety glasses AND have vision correction needs, the employer is responsible for providing the following:
Option 1: Appropriate ANSI Z87.1 – approved safety glasses that can be work over prescription lenses,
OR
Option 2: Appropriate ANSI Z87.1 – approved safety glasses with suitable corrected lenses
If you have a current prescription (less than 2 years old):
Prestige Lens Lab holds regular prescription safety glasses events on campus. A purchase order is required. (School of Engineering graduate students, staff and post docs do not need a purchase order but do need their PI’s signature on an SoE-specific form.)
3rd Tuesday of the month
Shriram Building Lobby
1:00p.m. – 2:00p.m.EH&S can assist in scheduling prescription safety eyewear events for individual departments. Contact EH&S for assistance.
Prescription Safety Eyewear Pre-Approval Form
If you do not have a current prescription:
The closest off-campus location for vision exams and prescription safety glasses is Foreyes Optical, located at Town & Country Village, 855 El Camino Real Unit 84, Palo Alto, CA 94301. Call for an appointment: (650) 329-0557.
Pre-negotiated pricing are available with Stanford ID.
For any questions, contact the EH&S Occupational Health and Safety Program at (650) 723-0448.
Laboratory coats
- Lab coats provide some dermal protection from potential hazards, including splashes from chemicals or biological agents and incidental contact from contaminated surfaces.
- Flame-resistant lab coats provide additional protection against flammability hazards, such as pyrophoric compounds and flammable liquids.
- Also wear proper street clothing, which is defined as long pants (or equivalent) that covers legs and ankles, and non-perforated, closed-toed shoes that completely cover the feet.
- Laboratory coats must not be laundered in personal or public laundry facilities. The Supervisor, PI/Lab Supervisor or Department must provide for professional laundry service. See Stanford University’s campus-wide agreement on lab coat provision and laundry service.
Specific chemical protective clothing
When chemical contact to the body is anticipated, or when extremely toxic or corrosive chemicals are handled (e.g. hydrofluoric acid), wear appropriate chemical-protective clothing (e.g. aprons or oversleeves).
Respiratory protection is not usually required during laboratory operations where work can be performed in a laboratory fume hood.
When it is not feasible to conduct operations within a fume hood, or where there otherwise may be a need for respiratory protection, contact EH&S for initial exposure assessment and respirator approval.
If respirator use is required, users must first receive a medical evaluation, then be fitted and trained for respirator use.
Hearing protection is rarely required during laboratory operations.
If a lab operation generates noise conditions such that researchers have to raise their voices to be heard, contact EH&S for an assessment. Hearing protectors (e.g. earmuffs or earplugs) may be necessary to minimize noise exposures.
These FAQs provide background information on the purpose of Personal Protective Equipment (PPE) and the requirements of Stanford University’s PPE Program. For technical consultation on PPE assessments or PPE training, please contact Stanford Environmental Health & Safety (EH&S) at (650) 723-0448. You can also download these FAQs as a PDF.
General Information About PPE
What is personal protective equipment (PPE)?
Personal protective equipment (PPE) is equipment worn to minimize exposure to workplace hazards. Main categories of PPE include:
- Protective clothing (e.g., laboratory coats)
- Eye/face protection (e.g., safety glasses, goggles, face shield)
- Gloves to match the hazard (e.g., chemical-resistant, thermal protection, cut-
- resistant)
- Protective footwear (e.g., steel-toed shoes)
- Hearing protection (e.g., earplugs, ear muffs)
- Respirators (e.g., N95 filtering face-piece, half-face negative pressure respirator)
Based on the hierarchy of controls, PPE is considered the last resort. Why is this?
Whenever feasible, hazards must be controlled through engineering and/or administrative controls, prior to implementing the use of PPE. PPE can be used to augment engineering or administrative controls or as a stand-alone control when engineering and administrative controls are not feasible. When properly selected and used, PPE can be effective in eliminating or minimizing individual exposures to hazardous materials and physical hazards encountered in different work environments.
What are hazardous materials and physical hazards?
- Hazardous Materials: Chemical and biological materials/agents that pose a health or physical hazard and unsealed radioactive materials.
- Physical Hazards: Substances, equipment, or activities that pose potential threat to physical safety. Examples of physical hazards include, but are not limited to: extreme pressures, temperature extremes, radiation (ionizing and non-ionizing), noise, and flying hazards due to machining equipment.
If I am working with multiple hazards simultaneously (e.g., physical and chemical hazards) what PPE should I wear?
Wear PPE to protect for all hazards, as determined by the hazard assessment; if you have any questions, please contact EH&S at (650) 723-0448.
Information about Stanford University’s PPE Program
What is the purpose of Stanford University’s Personal Protective Equipment (PPE) Program?
This program is designed to protect personnel from potential workplace hazards and comply with Cal/OSHA, 8 CCR 3380, Personal Protective Devices, as well as other Cal/OSHA regulations.
Who does Stanford University’s PPE Program apply to?
Faculty, staff, and students who perform tasks with hazardous materials and/or physical hazards or are potentially exposed to such hazards in either laboratory or general work areas.
What actions do Supervisors and PIs/Lab Supervisors need to take to implement the PPE program in their work areas?
- Identify PPE requirements by completing Section II of the General Work Area or Laboratory PPE Assessment Tool.
- Provide site-specific PPE training to personnel.
- Ensure the provision, maintenance, replacement, and disposal of PPE.
- Maintain records of completed PPE assessment and training.
What is a PPE assessment?
A PPE assessment is designed to: (a) determine hazards present or likely to be present in the work area/lab which necessitate the use of PPE; and (b) select the correct PPE to wear to protect the affected personnel from the hazards identified.
Who must conduct the PPE Assessment?
The Supervisor, Principal Investigator/Lab Supervisor, or his/her designee.
Must the Stanford-provided tools and forms be used for conducting PPE assessment and workplace-specific PPE training?
You may use an equivalent method that includes:
- A walkthrough of the work area to identify hazards that are present, or likely to be present, which necessitate PPE use.
- Documentation of required PPE for specific hazards or conditions.
- Written certification of the PPE assessment which documents the location of the workplace evaluation, name of person conducting the assessment, and date of assessment.
- Provision and documentation of workplace-specific PPE training.
How often must the PPE assessment be conducted and where must the documentation be maintained?
The PPE assessment must be conducted initially and when new hazards are introduced into the general work and/or laboratory areas.
The PPE assessment must be kept current and in an easily accessible location in the work area, either electronically or in a paper form.
How often must the PPE training be conducted and how long must the documentation be maintained?
- Personnel must be trained prior to performing work requiring the use of PPE.
- Retraining is required of laboratory personnel when:
- Changes in activities/operations render previous PPE training obsolete.
- Inadequacy of personnel’s knowledge or use of PPE is evident.
- The training documentation must be kept for at least one year.
Do I need to submit my PPE assessment and PPE workplace-specific training documentation to EH&S?
No. Maintain records in an easily accessible location in the work area, either electronically or in a paper form. Please note that your department/unit may request that you provide a copy to them.
Who is responsible for enforcement of PPE usage?
The Supervisor or Principal Investigator/Lab Supervisor is responsible for ensuring his/her personnel use, maintain, replace, and dispose of PPE properly.
Do supervisors need to conduct a PPE assessment if their work area does not have any hazardous materials or physical hazards?
No. However, a PPE assessment is required if hazardous materials or physical hazards are later introduced into the work area.
Provision of PPE
Who provides PPE?
The Supervisor or PI/Lab Supervisor is responsible for providing the required PPE as identified by the PPE assessment.
For non-employees, it is the discretion of the Supervisor or PI/Lab Supervisor to provide PPE as identified by the PPE assessment. If not provided, the list of PPE required for the work assignment must be given to the individual to acquire prior to his/her work assignment.
Who provides PPE for students in teaching labs?
It is the discretion of the local department to provide lab coats and other PPE for student use in teaching labs/shops and for field work. If not provided, the list of PPE required for the class must be given to the students to acquire prior to their class assignment.
Are there any special requirements for use of respirators and hearing protectors?
Respirator and hearing protector use requires an EH&S assessment to identify the need and type, additional training, and possible medical surveillance; contact EH&S at (650) 723-0448.
Must PPE meet certain specifications?
The PPE must meet the PPE specifications stated in applicable CAL/OSHA Title 8 standards, as well as properly fit the individual, be reasonably comfortable, and not unduly encumber the individual’s movements necessary to perform his or her work.
Where can I obtain information on acquiring PPE?
See Stanford University’s guidance, see the “Provision and Maintenance” tab above.
Where can I procure lab coats and have them laundered?
For information on lab coats, see Stanford University’s campus-wide agreement on lab coat provision and laundry service.
How often should lab coats be laundered?
Lab coats must be cleaned when contaminated with hazardous materials and be maintained in a safe and sanitary condition so as not to create a hazard.
Where can I get information on prescription safety eyewear?
See Stanford University’s Prescription Safety Eyewear Program in the “Safety Eyewear” tab.
PPE Use in Laboratories
What is considered a laboratory?
Locations where hazardous materials and/or equipment are used and/or stored in research laboratories, teaching laboratories, and core facilities. This also includes chemical storage rooms, waste accumulation areas, warm/cold rooms, vivaria, and machine/workshop areas within laboratories.
What PPE and street clothing are required when working with hazardous materials and/or physical hazards in laboratories?
Wear the PPE that corresponds to the specific hazard listed in Section II of the Laboratory PPE Assessment Tool.
Also wear proper street clothing, which is defined as long pants (or equivalent) that covers legs and ankles, and non-perforated, closed-toed shoes that completely cover feet.
Do Iaboratory personnel need to wear PPE if they are observing a lab operation conducted by others?
Yes. If laboratory personnel are not directly involved in a lab operation, but there is risk for potential exposure to hazardous materials and/or physical hazards, minimally wear lab coat, safety glasses, and proper street clothing. If touching any potentially contaminated surface, also wear gloves to match the hazard.
Do visitors touring a laboratory need to wear PPE?
If visitors are not directly involved in a lab operation, but there is risk for potential exposure to hazardous materials and/or physical hazards, minimally wear lab coat, safety glasses, and proper street clothing.
Do minors need to wear PPE in the laboratory?
Minors are required to use all proper PPE as identified by their PI and the lab’s PPE assessment. Please refer to the Minors in Laboratories subtopic for more information.
PPE Use in General Work Areas
What is considered a general work area?
All other spaces that do not fall under the description of laboratory (see above). This includes areas such as shops, kitchens, loading docks, visual/performing art studios, and janitorial storage areas.
What PPE is required when working with hazardous materials and/or physical hazards in facilities such as machine shops and dining kitchens?
Wear the PPE that corresponds to the specific hazard listed in Section II of the General Work Area PPE Assessment Tool for the work area.
Also, wear proper street clothing, which is defined as long pants (or equivalent) that cover the legs and ankles, and non-perforated, closed-toed shoes that completely cover the feet.