Independent Research  
 

Studies
       
St01 The ideal function of the foot during gait – a conceptual case study. R. Burke B. Sc, KIN, R. Gardiner, R. Reyes B.KIN.
“The analysis and its role in the manifestation of injury is becoming increasingly important as our population ages as the incidence of conditions such as diabetes and obesity continue to rise.”
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St02 The foot and footwear
Prosthetics and Orthotics International, 1997,1,173-182; P.K. Sethi. S.M.S. Medical College, Jaipur, India. “But the foot can no longer be viewed as a mere weight-bearing device meant only for standing. It has evolved…”
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St03 Biomechanics of the Normal and Abnormal Foot
Journal of the American Podiatric Medical Association; Kevin A. Kirby, DPM, MS. Volume 90, number 1, January 2000. “The human foot is an engineering marvel. It is designed to allow a bipedal animal, the human, to walk, run, and jump efficiently over many types of supporting surfaces without pain or injury.”
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St04 Do soft soles improve running shoes?
BioMechanics, April 1998; Steven Robbins, MD, Edward Waked, PhD, and Gad Saad, PhD. “There is evidence that amplitude of vertical impact in sports involving running and jumping account for many injuries.”
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St05 The Effects of Increasing Heel Height on Forefoot Peak Pressure
Journal of the American Podiatric Medical Association; Mark G. Mandato, DPM. Elizabeth Nester, DPM. Volume 89, number 2, February 1999. “The consensus in the medical community is that the wearing of high-heeled shoes may have adverse effects on women’s feet.”
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St06 Three-Dimensional Movement of the Foot during the Stance Phase of Walking
Journal of the American Podiatric Medical Association, Volume 89, number 2, February 1999; Mark W. Cornwall, PhD, PT, CPed, Thomas G. McPoil, PhD, PT, ATC. “The assessment of dynamic motion of the foot is extremely important for clinicians involved in the evaluation and treatment of foot and ankle pathologies.”
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St07 Biomechanical Analysis of the Three-Dimensional Foot Structure during Gait: A Basic Tool for Clinical Applications
Transactions of the ASME, 630 / volume 122, December 2000. Copyright © 2000 by ASME; A. Gefen, M. Megido-Ravid, Y. Itzchak, M. Arcan. “The foot structure, a vital connection between the human body and the ground, play a highly important role in human locomotion.”
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St08 Function of the Windlass Mechanism in Excessively Pronated Feet
Journal of the American Podiatric Medical Association, Volume 91 number 5, 245-250, 2001; Anna Aquino, BPod(Hons) and Craig Payne, DipPod(NZ), MPH. “The position of the forefoot relative to the rearfoot, subtalar joint axis position, and navicular drift/foot length ratio were significantly associated with dynamic windlass function.”
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St09 Biomechanical analysis of the stance phase during barefoot and shod running
Journal of Biomechanics 33 (2000) 269-278; Brigit De Wit, Dirk De Clercq, Peter Aerrts. “The flatter foot placement at touchdown is prepared in free flight implying an actively induced adaptation strategy.”
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St10 Differences in the Sensation of the Plantar Surface of the Human Foot
North American Congress on Biomechanics – American Society of Biomechanics; M. A. Nurse, B.M. Nigg, D.J. Stefanyshyn, W.Liu, J.E. Miller Human Performance Laboratory, University of Calgary, Alberta, Canada. “…The selection of appropriate shoe orthotics, as well as the effects of such orthotics on locomotion and related loading of the lower extremities, is not well understood.”
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St11 Can Gait be Retrained to Prevent Injury in Runners?
Joyner Sports medicine Institute, Harrisburg, PA 17111, Motion Analysis Laboratory, University of Delaware, Newwark, DE 19716; I.S. McClay, DS Williams and CA Laughton. “If a runner is able to modify his gait pattern and correct the abnormal mechanics, the risk for further injury is likely to be reduced.”
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St12 Inter-segment foot motion and ground reaction forces over the stance phase of walking
Clinical Biomechanics 16 (2001) 592-600; Adrienne E. Hunt, Richard M. Smith, Marg Torode, Anne-Maree Keenan. “Typical foot motion does not obey description of triplanar motion such as ‘pronation’ and ‘supination’.”
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St13 Potential of a commercially available orthotic device to influence lower extremity biomechanics when placed in military boots
School of Sport and Health Sciences, University of Exeter, Exeter, EX1 2LU, United Kingdom. Sharon J. Dixon and Samuel Warren. “Placement of the orthotic device in the subjects’ boots was found to have no significant influence on standing rearfoot angle or peak rearfoot angel when running (p>0005, Table 1).”
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St14 Put to the test: Orthoses reduce pressure but fall short of biomechanical correction
BioMechanics October 2000; Laurie L. Tis, PhD, ATC, Elizabeth J. Higbie, PhD, ATC, Lynn Chadwick, ATC, and Benjamin F. Johnson, EdD. “Despite this evidence, most clinicians will assess forefoot position in a nonweight-bearing, static position using goniometric techniques.”
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St15 Proficiency of Foot Care Specialists to Place the Rearfoot at Subtalar Neutral
Journal of the American Podiatric Medical Association, Volume 86, number 5, May 1996; Michael R. Pierrynowski, PhD. Steve B. Smith, Rch. Joan H. Mlynarczyk, MA, BScPT. “The proficiency of clinicians to place a rearfoot at the subtalar neutral position is important for the treatment of patents with lower extremity dysfunctions, and especially for foot orthosis prescription, fabrications, and management.”
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St16 Levels of Evidence of Articles in Podiatric Medical Journals
Journal of the American Podiatric Medical Association, Volume 90, number 6, June 2000; Michael A. Turlik, DPM, Donald Kushner, DPM, “Only 1% of the articles reviewed were randomized controlled trials. The authors concluded that if the podiatric medical profession wishes to become a participant in evidence-based medicine, greater emphasis must be placed on studies that assess hypotheses.”
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St17 Flexible Flat Feet in Children: A Real Problem?
PEDIATRICS, Volume 103 No. 6 June 1999, p. e84; Antonio García-Rodríguez, Felipe Martín-Jiménez, Manuel Carnero-Varo, Enrique Gómez-Gracia, Jorge Gómez-Aracena, and Joaquín Fernández-Crehuet. “The prevalence of flat feet was 2.7% of the 1181 children sampled, 168 children (14.2%) were receiving orthopedic treatment, but only 2.7% had diagnostic criteria of flat fleet.”
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St18 Defense Mechanisms: Biomechanics Researchers Adopt a Military Mindset
BioMechanics Magazine, Volume VIII Number 10 / October 2001. “With research dollars increasingly difficult to come by, projects funded by the armed forces offer opportunities for investigators.”
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St19 The effect of a proprioceptive insole device (the Barefoot Science Foot Strengthening System) on the foot’s structural mechanics during varying activity levels
Rob Burke B.Sc.KIN and Reggie Reyes B.Sc.KIN, May 2002. ”Previous studies have shown that a correlation exists between the ability of the hallux to dorsiflex and the structural integrity of the foot—the great the amount of hallux dorsiflexion, the more stable and structurally sound the foot’s musculosketetal arch system.”
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St20 Barefoot Science / Dynapro Wear Test - Clinical Wear Test and Evaluation
Dr. Scott Kantro, DPM, Robert Burke B.Sc.KIN, Roy Gardiner. Statistical Analysis by: Dan Wicklum, M. SC. U of Montana. ”Foot and back pain typically occur because there is an inability of muscles to deal with repetitive force or excess movement.”
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St21 A proprioceptive insole device’s (“the Barefoot Science Foot Strengthening System”) effect on the foot’s structural mechanics.
Rob Burke B.Sc.KIN and Reggie Reyes B.Sc.KIN, March 2002. ”The inventors of a proprioceptive insole device have proposed that the use of the insole product will result in a strengthening (improved structural integrity) of the foot’s musculoskeletal structure.”
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St22 Structural relationship between foot arch length and height and the relative effects on foot strength (stability) and impact loading (shock absorption) while barefoot, shod, shod with custom orthotics, and shod with a proprioceptive insole device (“the Barefoot Science Foot Strengthening System”)
Rob Burke B.Sc.KIN and Reggie Reyes B.Sc.KIN, August 2002. ”Recent research has demonstrated a clear indication that there is a direct correlation between the degree of hallux dorsiflexion relative to activity levels and improved structural alignment in the lower limbs—quite likely a defensive response to better prepare the body to reduce potentially harmful stresses.”
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Articles
       
Ar01 Barefoot running boosts foot strength & Eccentric contractions--muscle activity lengthening
Prepared by: Dr. Scott Kantro, DPM, Robert Burke, B.Sc. KIN. Roy Gardiner. Statistical Analysis By: Dan Wicklum, M. SC. U of Montana. Thursday, September 25, 1997. “What happens is, when you change the natural motion of the foot—and all running shoes do this—you being to lose the intrinsic strength of your foot muscles.”
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Ar02 Osteoporosis and Bone Remodeling
Jeffery S. Malka, M.D., F.A.C.S., F.A.A.O.S. “Bone is a living tissue and as such ahs the ability to change. In fact it constantly changes in response to a large number of varied influences.”
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Ar03 Football boot insoles and sensitivity to extent of ankle inversion movement
PhysioRoom.com, British Journal of Sports Medicine, Volume 37, Issue 2, 2003, pp. 170-175; G. Waddington and R. Adams. “While conventional boots and sports shoes, with a smooth insole, appear to mask vital sensory cues to the extremely sensitive soles of the feet…”
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Ar04 Shoe science will sell itself
BioMechanics Magazine Online; Jordana Bieze. “Athletic shoe companies, first and foremost, are in the business of selling shoes.” “Custom driven research, done properly, can be biomechanically credible as well as profitable.”
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Ar05 Why Shoes Make “Normal” Gait Impossible
“How flaws in footwear affect this complex human function”; William A. Rossi, D.P.M. “Each year, consumers spend hundreds of millions of dollars for “walking shoes” promising to help the wearer walk “right” or more comfortably.”
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Ar06 A Critical Review of the Literature on Foot Orthoses
Journal of the American Podiatric Medical Association, Volume 90, number 1, pp. 339-341, 2000; David J. Pratt, PhD. “Prevention or correction of a deformity; 2) promotion of a sound base of support; 3) facilitation of training in standing or walking; and 4) improvement in the efficiency of walking.”
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Ar07 The Windlass Mechanism of the Foot
A Mechanical Model to Explain Pathology; Eric A. Fuller, DPM. “Plantar Fasciitis may be related to how much tension is present in the plantar fascia.”
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Ar08 Dynamic Foot Orthoses
Journal of the American Podiatric Medical Association, Volume 90, number 1, January 2000. Principles and Application; David J. Pratt, PhD. “The concept of tonic reactions has now been incorporated into the design of dynamic foot orthoses to help provide improved orthotic treatment with a better functional outcome.”
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Ar09 Functional Hallux Limitus and its Relationship to Gait Efficiency
Journal of the American Podiatric Medical Association, Volume 76, number 11, November 1986; Howard J. Dananberg, ”The ability to stabilize these joints at the correct time lead to the temporary rigidity necessary for body support.”
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Ar10 Practitioners consider payerless orthoses business
BioMechanics Magazine Online, 10/22/02; Anthony R. Edwards. “One of the biggest problems that third-party payers encounter is the routine dispensing of and billing for custom foot orthotic devices by some providers.”
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Ar11 Shoe science: stepping up to market challenges
BioMechanics Magazine Online, 10/22/02; L. Rochelle Roniger. ”Practitioners have long held that customer-driven research is not necessarily the ideal way to study the biomechanics of athletic shoes and the athletes who wear them. But that may be changing.”
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Ar12 Literature Review: “Efficacy of foot orthoses: what does the literature tell us?”
Literature Review AJPM, Volume 32, number 3, 1998; Karl B. Landorf Dip App Sc (Pod), Grad Dip Ed. Anne-Mare Keenan B App Sc (Pod), M App Sc. “Foot orthoses (FOs) have been used for many years with the intention of alleviating symptoms, preventing deformity and enhancing performance.”
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Ar13 A Critical Review of the Literature on Foot Orthoses
Journal of the American Podiatric Medical Association, Volume 90, number 7, pp. 339-341, 2000; David J. Pratt, PhD. “The use of foot orthoses has been extensively described for the treatment of any biomechanical problems.”
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Ar14 Literature Reveals No Consensus on Subtalar Neutral
Biomechanics Magazine Online, 1/28/01; Melissa Miller and James McGuire, PT, DPM. “The neutral position of a joint can be defined as a position where the concave and convex surfaces are completely congruous.”
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Ar15 Alternative Techniques for the Clinical Assessment of Foot Pronation
Journal of the American Podiatric Medical Association, Volume 88, number 3, March 1998; Hylton B. Menz, BPod(Hons). “…Recent research has seriously questioned the reliability and validity of the commonly used approaches to clinical measurement and foot posture.”
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Ar16 Inexpensive off-the-shelf shoe inserts more effective in treating heel pain than custom-made arch supports.
AAOFAS Resources: Heel pain. Monday, June 18, 2001. “Heel pain affects over two million Americans annually and is the most common foot problem seen in medical practice”.
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Ar17 Magnet Therapy Update: Support for your feet, but little support from science.
FindArticles.com – A LookSmart™ Service; Kevin Christopher. “While the companies that make magnetic therapy products widely advertise claims of pain relief and other health benefits, the scientific evidence to back these statements up is scanty.”
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Ar18 Orthoses: Foot/Custom: The mechanics of foot orthoses for runners
BioMechanics 1996 Desk Reference February 1996; Joe Hamill, PhD, and Timothy R. Derrick. “A question often asked in the treatment of runners is why a device should be applied to the foot if the most frequent injuries are superior to the foot.”
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Ar19 The Many Faces of Fraud
© Copyright 1998 Maclean Hunter Publishing Ltd. Benefits Canada Magazine, November 1998; Catherine McMahon, 12/18/00. “From employees padding their benefits claims, to medical professionals milking the system, benefits fraud is out there and plan sponsors are the ones left holding the bag.”
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Ar20 Footwear: The Primary Cause of Foot Disorders
Podiatry Management, February 2001, by William A. Rossi, D.P.M. “Perhaps the single most visible difference between the shoeless and the shod foot is the elevated heel under the shoe. The numerous influences of the shoe heel n the foot and body column are not fully understood by most medical practitioners.”
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Ar21 Why Shoes Make “Normal” Gait Impossible
Podiatry Management, March 1999 by William A. Rossi, D.P.M. “Each year, consumers spend hundreds of millions of dollars for “walking shoes” promising to help the wearer walk “right” or more comfortably.”
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Ar22 Children’s Footwear: Launching Site for Adult Foot Ills
Podiatry Management, October 2002 by William A. Rossi, D.P.M. “A maze of mythologies has surrounded the foot and footwear of infants and children for generations. Medical practitioners, especially podiatrists, orthopedists and pediatricians, have been in the front lines of shaman-lie attitude and therapies concerning the foot-shoe relationship of juveniles and the hazards of the growing foot.”
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Ar23 Fashion and Foot Deformation –The need for podiatrists to deal with human nature.
Podiatry Management, October 2001 by William A. Rossi, D.P.M. “It is time for these ingenuous concepts of “fashion” and particularly fashion footwear to be exposed to the light reality.”
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Abstracts
       
Ab01 Abstracts: Papers on Barefoot Related Issues
“Lateral stability in sideward cutting movements”, Medicine Science in Sports and Exercise, 28(3), 1996, pp. 350-358; Alex Stacoff, Jürg Steger, Edgar Stüssi, and Christoph Reinschmidt. “The shoe sole increases the lever arm as a consequence the moment about the subtalar joint.”

“Ankle taping improves proprioception before and after exercise in young men.” British Journal of Sport Medicine, 29(4), 1995, pp. 242-247; Steven Robins, Edward Waked, and Ron Rappel. “While taping improves foot position sense when humans wear athletic footwear, it remains poor compared to the barefoot condition.”

“Protective Sensation of the Plantar Aspect of the Foot” Foot & Ankle, 14(6), 1993, pp. 347-352; Steven E. Robbins, Gerard J. Gouw, Jacqueline McClaran, and Edward Waked. “The results of studies examining barefoot activity have consistently shown that the unshod human foot is characterized by excellent mobility.”

“The Influence of Footwear on the Prevalence of Flat Foot” The Journal of Bone and Joint Surgery, 74B(4), 1992, pp. 525-527; Udaya Bhaskara Rao and Benjamin Joseph. “…Shoe wearing in early childhood is detrimental to the development of a normal or a high medical longitudinal arch.”

“Athletic footwear: unsafe due to perceptual illusions” Medicine and Science in Sports and Exercise, 23(2), 1991, pp. 217-224. “Wearers of expensive running shoes that are promoted as having additional features that protect (e.g., more cushioning, “pronation correction”) are injured significantly more frequently than runners employing inexpensive shoes.”

“Athletic Footwear and Chronic Overloading” Sports Medicine, 9(2), 1990, pp. 76-85, Steven E. Robbins and Gerard J. Gouw. “…Chronic overloading must be a consequence of wearing footwear and probably due to increased shock with their use.

“Running-related injury prevention through innate impact-moderating behavior” Medicine and Science in Sports and Exercise, 21(2), 1987, pp. 130-139. Steven E. Robbins, Gerard J. Gouw, and Adel M. Hanna. “A relation has been reported between barefoot activity and raising of the main longitudinal arch, presumably by increased intrinsic foot muscle tone.”

“Overload protection: avoidance response to heavy plantar surface loading” Medicine and Science in Sports and Exercise, 20(1), 1988, pp. 85-92. Steven E. Robbins, Adel M. Hanna, and Gerard J. Gouw. “…The paradoxical low incidence of similar injuries reported in barefoot populations implies that modern footwear may produce injuries that normally would not be present without their use.”

“Survey in China and India of Feet That Have Never Worn Shoes” the Journal of the National Association of Chiropodists, 49, 1949, pp.26-30. Samuel B. Shulman. “…Everyone surveyed showed a marked spacing between the first and second toes such as that found on young babies. The great toe was either pointing straight ahead or slightly abducted to provide a great weight-bearing base…”
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Ab02 Bare feet in Medicine
Sports Medicine, 9(2), 1990, pp. 76-85; Steven E. Robbins and Gerard J. Gouw. “Athletic Footwear and Chronic Overloading,” “…Reports indicating that habitually unshod humans are not subject to chronic overloading during running.”

Foot & Ankle, 14(6), 1993, pp. 347-352; Steven E. Robbins, Gerard J. Gouw, Jacqueline McClaran, and Edward Waked. “Protective Sensation of the Plantar Aspect of the Foot,” “Compared with the hairy skin of the thigh, plantar skin required approximately 600% greater abrading loads to reach pain threshold.”

The Journal of the National Association of Chiropodists, 49, 1949, pp. 26-30; Samuel B. Shulman, “Survey in China and India of Feet That Have Never Worn Shoes”. “The low incidence of dermatomycotic infection here noted might be attributed to the fact that most foot fungi require dark, warm and damp interdigital spaces for growth…”

Medicine and Science in Sport and Exercise, 392), 1991, pp. 217-224; Steven E. Robbins and Gerard J. Gouw. “Athletic footwear: unsafe due to perceptual illusions”. “Wearers of expensive running shoes that are promoted as having additional features that protect (e.g., more cushioning, “pronation correction”) are injured significantly more frequently than runners employing inexpensive shoes.”

Medicine and Science in Sport and Exercise, 28(3), 1996, pp. 350-358; Alex Stacoff, Jurg Steger, Edgar Stussi, and Christoph Reinschmdt. “Lateral stability in sideward cutting movements.” “With respect to leverage, the barefoot situation has an advantage over the shod situation.”

Medicine and Science in Sports and Exercise, 20(1), 1998, pp. 85-92; Steven E. Robbins, Adel M. Hanna, and Gerard J. Gouw, “Overload protection: avoidance response to heavy plantar surface loading.” “…The paradoxical incidence of similar injuries reported in barefoot populations implies that modern footwear may produce injuries that normally would not be present without their use.”
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Ab03 Knee Osteoarthritis and High-Heeled Shoes
The Lancet, Volume 351, pp. 1399-1401, May 9, 1998. “Measurement showed increased force across the patellofemoral joint and a greater compressive force on the medical compartment of the knee (average 23% great forces) during walking in high heels than barefoot.”
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Ab04 Functional evaluation of shoes for children based on gait analysis of children in the learning to walk stage
Entrez-PubMed. Z Orthop Ihre Grenzgeb 1998 Sep-Oct; 136(5): 457-62. “Shoes cause a significant change of loading patterns.”
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Ab05 Hazard of deceptive advertising of athletic footwear
Br J Sport Med 1997 Dec; 31(4) pp. 299-303; Robbins S, Waked E. “Athletic footwear are associated with frequent injury that thought to result from repetitive impact.”
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Ab06 Medical Research (multiple abstracts)
Lynn Staheli, MD: quoted in The New York Times on Aug 14, 1991, “Children with the healthiest and most supple feet are those who habitually go barefoot…”

Dr. Paul W. Brand: interviewed in 1976, “…The average person who walks barefoot has much healthier feet than the average person who wears shoes”.

The Pilbara Times, Australia (31 Jan 1980): “Care For Kids Then Care for Their Feet”; “[Children’s] bones are soft cartilage, easily compressible, and they don’t feel pain until the damage is done”.

Udaya Bhaskara Rao and Benjamin Joseph. “The Influence of Footwear on the Prevalence of Flat Foot”. The Journal of Bone and Join Surgery, 74(4), 192, pp. 525-527. “In Europe and American flat foot is a common reason for attendance to the development of a normal longitudinal arch”.
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Ab07 Balance and vertical impact in sports: role of shoe sole materials
Arch Phys Med Rehabil 1997 May; 7895:463-7, Robbins S, Waked E. “Athletic shoes and mats are support surface interfaces composed of relatively soft compressible material designed to protect against injuries occurring in sports through force of vertical impact”.
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Ab08 Shoes for children: a review
LT Staheli. Department of Orthopaedics, Children’s Hospital and Medical Center, Seattle, WA 98105, Volume 88, Issue 2, pp. 371-375, 08/01/1991. Copyright © 1991 by The American Academy of Pediatrics. “Optimum foot development occurs in the barefoot environment.”
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Ab09 Biomechanics of the first ray. Part II: Metatarsus primus varies as a cause of hyper mobility. A three-dimensional kinematic analysis in a cadaver model
J. Foot Ankle Surg 2000 Mar-Apr; 39(2): 68-77. Rush SM, Christensen JC, Johnson CH. “This suggests that the windlass mechanism is more efficient when the first metatarsal, sesamoid apparatus, and hallux position are properly aligned with the orientation of the plantar aponeursosis.
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Ab10 Acute and chronic adaptations of muscle proprioceptors in response to increased use
Sports Med 1992 Dec: 4(6): 406-21, Hutton RS, Atwater SW. “This short-term activation adaptation increases the excitability of the motoneuron pool, thereby potentially providing a non-voluntary increase in the excitation of subsequent contractions.”
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Ab11 Muscle Strengthening
Copyright© T.E.N.S. Health 1996. “Injury Prevention: Strengthening and toning muscles is important to injury prevention.”
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Ab12 The sports shoe as a therapeutic aid
Der Sportschuh als therapeutisches Hilfsmittel; Von B. Segesser, Praxisklinik Rennbahn (Dres. Med. Jenoure, Segesser, Lüthi, Gremion), Muttenz-Basel. “Sports shoe research discovered several possibilities of influencing the heel-to-toe walking behavior of the foot which can be made use in the construction of therapeutic shoes.”
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Ab13 Journal of Manipulative and Physiological Therapeutics
Abstracts for February 2002, Volume 25, number 2. The minimum energy hypothesis: A unified model of fixation resolution. Joseph Evans, PhD, C. Ray Hill, PhD, Robert Leach, DC, and Daniel Collins, DC. “Objective: to present a new theoretical construct, the minimum energy hypothesis which explains structural changes observed in the spine…”
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Ab14 Effect of extrinsic rearfoot posts on rearfoot position
Journal of the American Podiatric Medical Association 1993 Aug: 83 (8) 447-56. Blake RL, Ferguson HJ. “The results suggested that rearfoot posts have a somewhat limited function in foot orthotic therapy and that the choice of posting material is of limited functional value.”
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Ab15 Effects of prefabricated foot orthoses and soft insoles on postural stability in professional soccer players.
Journal of the American Podiatric Medical Association, Volume 91 2001 Apr, pp. 194-202. Percy, M.L.; Menz, H.B. “These results suggest that insoles and foot orthoses have no significant beneficial or detrimental effects on postural stability in asymptomatic subjects.
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Ab16 Measurement of dynamic pressures at the shoe-foot interface during normal walking with various foot orthoses using the FSCAN system.
Foot Ankle Int, Volume 17, no. 3, 1996 Mar, pp. 152-6. Brown, M.; Rudicel, S.; Esquenazi, A. “Foot orthoses are routinely used in clinical practice to redistribute pressure at the shoe-foot interface, although there is very little scientific evidence to support the efficacy of their use.”

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