modifier 59 versus ??

The coder before I came used a modifier 59 on EVERYTHING and I'm pretty sure some of those should have been a 51 or even just the "toe" codes.

Is there a guideline for using a 59 on multiple procedures instead of a 51?

Example:

28296 RT

28310 51 RT

28285 T2

Any advice is appreciated.

modifier 59 versus ??