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Course 751 - Hearing Conservation Program Management

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Hearing Conservation Programs protect your employee's hearing.
Hearing conservation programs strive to prevent initial occupational hearing loss, and preserve and protect remaining hearing.

Hearing Conservation Program

Introduction

Hearing conservation programs strive to prevent initial occupational hearing loss, preserve and protect remaining hearing, and equip workers with the knowledge and hearing protection devices necessary to safeguard themselves. Employers are required to measure noise levels; provide free annual hearing exams, hearing protection, and training; and conduct evaluations of the adequacy of the hearing protectors in use (unless changes made to tools, equipment, and schedules result in worker noise exposure levels that are less than the 85 dBA). Research indicates that workplaces with appropriate and effective hearing conservation programs have higher levels of worker productivity and a lower incidence of absenteeism.

What constitutes an effective hearing conservation program?

The positives of hearing conservation programs.
An effective hearing conservation program can prevent hearing loss, improve employee morale and a general feeling of well-being, increase quality of production, and reduce the incidence of stress-related disease.

An effective hearing conservation program can prevent hearing loss, improve employee morale and a general feeling of well-being, increase quality of production, and reduce the incidence of stress-related disease.

The employer should administer a continuing, effective hearing conservation program whenever employee noise exposures are at or above an eight hour time-weighted average (TWA) of 85 dBA or, equivalently, a dose of 50 percent.

Program Elements

As detailed in OSHA’s 1910.95 rule, the elements of an effective hearing conservation program are:

  • Monitoring Program
  • Audiometric Testing Program
  • Hearing Protection Devices (HPDs)
  • Employee Training and Education
  • Recordkeeping

There are also specific hearing conservation program requirements for agricultural, maritime, and construction worksites.

Monitoring Noise
The monitoring requirement is performance-based, as it allows employers to choose a monitoring method that best suits each individual work situation.

Monitoring Program

The employer must develop and implement a monitoring program whenever information indicates that any employee's exposure may equal or exceed the action level.

  • The sampling strategy must be designed to identify all employees for inclusion in the hearing conservation program, and enable the proper selection of hearing protectors.
  • The monitoring requirement is performance-based, as it allows employers to choose a monitoring method that best suits each individual work situation. Either personal or area monitoring may be used.

If there are circumstances that may make area monitoring generally inappropriate, such as high worker mobility, significant variations in sound level or a significant component of impulse noise, then the employer must use representative personal sampling unless it can be shown that area sampling produces equivalent results.

  • Measurement of Noise. Noise measurements must integrate all continuous, intermittent, and impulsive noise levels from 80 to 130 dBA.
  • Repeated Monitoring. Monitoring must be repeated whenever a change in production, process, equipment or controls increases noise exposures to the extent that additional employees may be exposed at or above the action level or the attenuation provided by hearing protectors used by employees may be rendered inadequate to meet the requirements described in Hearing Protection Devices (HPDs).
  • Employee Notification. The employer must notify each employee who is exposed at or above the action level of the results of the monitoring.
  • Observation of Monitoring. The employer must provide affected employees or their representatives with an opportunity to observe noise monitoring procedures.

Providing Hearing Protection Devices (HPD’s)
Management Responsibilities

Management has two primary responsibilities in ensuring that hearing protection devices protect hearing effectively: facilitation and enforcement.

Management must approve appropriate hearing protection.
Management must ensure appropriate hearing protection is approved.

Facilitation

Management facilitation involves ensuring that program implementers obtain the types of devices they need. Management can do this by making sure the procurement department does not override the implementer’s selections. Employee participation in the selection of hearing protectors should be encouraged.

Management should extend its commitment to hearing protectors by requiring all personnel, including managers and visitors, to wear protectors in designated areas, and by encouraging employees to take hearing protectors home to use whenever engaging in noisy activities.

Management should give program implementer’s the opportunity to pilot-test hearing protectors on a few employees. This will greatly facilitate decisions relating to the selection and ultimate effectiveness of these devices.

Program implementers should also be given resources and facilities to train employees in the use and care of hearing protectors.

Enforcement

Enforcing the use of hearing protectors is management's second vital responsibility

Use of personal safety equipment, such as hearing protectors, must be clearly stated as a condition of employment, and management should be prepared to deal accordingly with those who violate the policy. Those who have decided not to wear hearing protection in noisy areas also have decided not to work for the company.

Hearing Protection Devices - Basic Requirements

Employers must make HPDs available.
Employers must make HPDs available to all employees exposed at or above the action level.

Hearing protection devices (HPDs), which are a form of personal protection equipment (PPE), are considered the last option to control exposures to noise. HPDs are generally used during the necessary time it takes to implement engineering or administrative controls, or when such controls are not feasible.

  • Employers must make HPDs available to all employees exposed at or above the action level. These must be provided at no cost to employees and must be replaced as necessary.
  • Employers must ensure that HPDs are worn by employees: where feasible administrative and engineering controls fail to reduce sound levels within those listed in Table G-16 of 29 CFR 1910.95 or who are exposed at or above the action level and who
    • have not yet had a baseline audiogram established or
    • have experienced a standard threshold shift (STS).
Choose the proper hearing protection
A responsible person must be able to evaluate and select the appropriate devices for each employee.

HPD Selection and Use

It is essential to the success of the program to have someone responsible for the selection of hearing protection devices and the supervision of their use. They must be able to evaluate and select appropriate devices for each employee, based on proper fit, the employee's noise exposure, hearing ability, communication needs, personal preferences and other constraints imposed by job tasks or work environment.

Not every person can wear every hearing protector. Some people may be unable to wear certain types of earplugs because of the shape or size of their ear canals. Because of individual differences in the shapes and sizes of heads, some people will be unable to wear some earmuffs. Individual assessment of comfort and ability to tolerate prolonged use of a given device cannot be predicted and will vary widely between individuals. Also, some protectors may be incompatible with differing safety and protective devices.

Therefore, program implementer’s must make a variety of devices available. Preferably, program implementer’s should make available a set of devices that have been pilot-tested for effectiveness and employee acceptance.

Fitting HPD’s

When fitting hearing protectors, attention needs to be given to each ear. It is not uncommon for a person to have right and left ear canals that are different sizes and must, therefore, be fitted with earplugs that are separately sized for each ear. Ear canals should be inspected to assure that no physical problems, such as infections or excessive ear wax, will compromise or complicate the use of hearing protectors.

  • Employees must be given the opportunity to select their HPDs from a suitable variety. Generally, this should include a minimum of two devices, representative of at least two different types.
  • The employer must provide training in the use and care of all HPDs provided to employees.
  • The employer must ensure proper initial fitting of HPDs and supervise their correct use.

Program implementers should be alert for common pitfalls associated with use and care of hearing protectors. For example, motorcycle helmets, personal stereo headsets, swimmer's earplugs, and hearing aids cannot be substituted for hearing protectors. Program implementers should be proactive in working with employees to avoid such pitfalls.

HPD Attenuation

Attenuation refers to the damping or decrease of noise levels as a result of wearing HPDs.

  • The employer must evaluate HPD attenuation for the specific noise environments in which the HPD will be used.
  • HPDs must attenuate employee exposure to at least an eight hour time-weighted average of 90 dBA. [29 CFR 1910.95(j)(2)]
  • For employees who have experienced a standard threshold shift (STS), HPDs must attenuate exposure at or below the action level of 85 dBA-TWA (time-weighted average).
  • The adequacy of the HPDs must be re-evaluated whenever employee noise exposures increase to the extent that they may no longer provide adequate attenuation. The employer must provide more effective hearing protectors as necessary.
  • Employer needs to know and understand the methods for estimating HPD attenuation.

Hearing Protection Labeling

When OSHA disseminated its Hearing Conservation Amendment in 1983, it incorporated the EPA labeling requirements for hearing protectors (40 CFR 211), which required manufacturers to identify the noise reduction capability of all hearing protectors on the hearing protector package. This measure is referred to as the noise reduction rating (NRR). It is a laboratory derived numerical estimate of the attenuation achieved by the protector. It became evident that the amount of protection users were receiving in the workplace with the prescribed hearing protectors did not correlate with the attenuation indicated by the NRR.

OSHA acknowledged that in most cases, the NRR overstated the protection afforded to workers and required the application for certain circumstances of a safety factor of 50% to the NRR, above and beyond the 7 dB subtraction called for when using A‐weighted measurements. For example, consider a worker who is exposed to 98 dBA for 8 hours and whose hearing protectors have an NRR of 25 dB. We can estimate the worker’s resultant exposure using the 50% safety factor. The worker’s resultant exposure is 89 dBA in this case.

The 50% safety factor adjusts labeled NRR values for workplace conditions and is used when considering whether engineering controls are to be implemented.

Estimated dBA exposure = TWA(dBA) - [(25-7) x 50%] = 89 dBA

In 1997, ANSI published a new test method (subject-fit) for measuring the real ear attenuation of hearing protectors (ANSI S12.6-1997). This method provides more representative estimates of the real world performance of hearing protectors. It attempts to better approximate the protection attained in real workplaces by using untrained subjects in the test method (the only instruction they receive is the instruction that comes with the package) to closely replicate real world users.

Some manufacturers of hearing protectors are testing their products according to the subject-fit method of ANSI S12.6-1997. You may contact the manufacturer to request such data.

In the future, hearing protector manufacturers who voluntarily test their product according to the subject-fit method may choose to publish the protector's attenuation data.

Employee Training and Education

Safety Memo - Hearing Loss: Myths & Facts

The employer must institute a training program for all employees with noise exposures at or above the action level and ensure employee participation.

  • Training must be repeated annually for each employee in the hearing conservation program.
  • Information must be updated to be consistent with changes in protective equipment and work processes.

An employee’s failure to correctly insert an earplug or adjust an earmuff are arguably the chief culprits responsible for diminished real world hearing protection. Thus, even if an employee has been issued a correctly-sized hearing protector and has been trained in its use and care, it is quite possible that he or she could receive little or no effective hearing protection because of a faulty fit. Employees must resolve to wear their hearing protection correctly, or they will greatly reduce its ability to prevent harmful noise from damaging their hearing.

Willful failure to wear hearing protection should be taken seriously. Employees should consider that management is responsible for ensuring compliance with health and safety requirements. Should employees fail to wear their hearing protection, management can be held accountable and may be cited and penalized for noncompliance with health and safety regulations.

Employee Training and Education (Continued...)

Be vigilant about hearing protection
Employees must cultivate a vigilant attitude about hearing protection. Always use hearing protection when you work amongst hazardous noise.

Part of the employees’ responsibility toward wearing their hearing protector is to cultivate a vigilant attitude about hearing protection. Employees should expect their hearing protectors to slip or work lose over a period of time. Throughout their work shift, employees must periodically check to see if they need to readjust or refit their protector in order to maintain a reliable fit.

Hearing protectors break and become worn. Employees also need to check their protector regularly and to seek repair or replacement whenever necessary. Lastly, they can help each other by encouraging their co-workers to use hearing protectors and to seek help when they have problems.

Employees must guard against acquiring a false sense of safety. As the discussion and figures in this section have illustrated, it is easy to misuse hearing protectors and greatly reduce their effectiveness. Employees CAN prevail over most hearing health hazards if they: 1) properly wear their hearing protectors, 2) exercise a commitment to wear their hearing protectors consistently, and 3) maintain their hearing protectors by repairing or replacing them when necessary.

The employer must ensure that each employee is informed of the following:

  • The effects of noise on hearing.
  • The purpose of hearing protectors; advantages, disadvantages and attenuation of various types; and instructions on selection, fitting, use and care.
  • The purpose of audiometric testing and an explanation of test procedures.

Access to Information and Training Materials

The employer must:

  • Make copies of the noise standard available to affected employees or their representatives and post a copy in the workplace.
  • Provide affected employees with any informational materials pertaining to the standard that are supplied to the employer by OSHA.
  • Provide, upon request, all material relating to the employer's training and education program to OSHA.

Great job! You’re nearly halfway through the program :-)

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. What is considered the last option to control exposures to noise?

2. Employers must make HPDs available to all employees exposed at or above the action level. These must be provided _____.

3. What is the "action level" at which the employer must institute a training program for all employees with noise exposures and ensure their participation?

4. How often must training be completed for each employee in the hearing conservation program?

5. The employer must provide training in the _____ and _____ of all HPDs provided to employees.


Have a great day!

Important! You will receive an "error" message unless all questions are answered.