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Course 751 - Hearing Conservation Program Management

Safety guides and audits to make your job as a safety professional easier

Hearing Conservation Program Audit (Optional)


Preventing occupational hearing loss is a complex matter, but it is often entered into without first assessing the assets available, the assets required, and the expected outcome of the program. Before any program to prevent hearing loss is put into place, or before any changes in an existing program are made, an audit should be performed on the system as it exists. Many companies decline to perform an audit because they either can’t conceive of a need for it or don’t recognize its value as the foundation of a successful program. A hearing conservation program audit should be considered as important to the outcome of the program as is a business plan to the success of the company.

Program evaluation check list, can serve well.

It is best to perform the audit from the top down, with administrative issues addressed first. In the United States, occupational safety and health programs historically have been driven by regulations. Thus, it is important to assure that the regulations for hearing conservation programs are being addressed by the program. At the same time, there needs to be a corporate recognition that addressing only regulatory issues will not create an effective program. Good safety and health practices need to be followed. The company policy must be developed and all who administer or participate in the program must be aware of the policies.

Decisions need to be made as to who is responsible for providing facilities and materials for the hearing conservation program. Decisions also need to be made about whom the program implementer or key person will be and guidelines for evaluating the effectiveness of that person need to be established. The role of supervisors in the program should be established. If front-line supervisors have a role, the role must be defined and procedures to notify supervisors and train them in their role should be established.

Program evaluation check list, can serve well. (Continued...)

Hazard assessments should be addressed during the audit. The audit should determine if appropriate measurements have been taken. Methods should be developed to evaluate the results of hazard measurement. Who will notify employees and how they will be notified of the results of hazard measurement should be determined. It is important to identify the critical measurements that need to be taken and how often they should be repeated. A system should be developed to ensure that the results of hazard assessment are included in the affected employees’ health records and into shop folders. The program implementer should also be aware of the assessment results.

Since the most effective means of preventing occupational hearing loss is to remove or control the hearing hazards, engineering and administrative controls should be evaluated heavily during the audit. Hazard control priorities should be established. In the long run, addressing hazards in order from greatest to least will, over time, remove the hazards from the workplace. The cost-effectiveness of engineering and administrative controls must be considered in the audit. While it may not be feasible to control all of the hazards at once, it may be reasonable to resolve one or two situations per year until all have been addressed. Most companies will not have hazard control expertise in house and will have to rely upon outside consultants and contractors.

Provisions for the use of outside experts must be included in the audit.

Monitoring audiometry and related record keeping are critical parts of the hearing conservation program. Often, many companies assume that this is the simplest part of the program, and they are wrong. The training and experience of the supervisor of the audiometric testing program (this should be an audiologist or a physician) are important. It may be more efficient to contract out for the testing and record keeping services, but it will be necessary for the company’s program implementer to be well versed in this aspect of the hearing conservation program regardless of who conducts the testing.

Program evaluation check list, can serve well. (Continued...)

Among matters to be considered for an internally or externally managed company are quality of the audiograms, access to prior audiograms by persons performing hearing testing, training and certification of audiometric technicians, adequacy of the testing environment, methods for determining changes in hearing status, communication of test results to employees, and follow-up procedures for those employees showing shifts in hearing.

Regular testing of employees’ hearing is the most effective means of ascertaining that hearing loss is being prevented. But, there will be employees whose hearing does change for the worse. It may become necessary to refer these employees for further testing and evaluation. The audit should address no less than the following: clear referral policies; agreement between the company and consulting audiologists or physicians as to the expectations from a referral; establishment of mechanisms to ensure that employees needing evaluation or treatment actually receive the service; timely and accurate transmission of records between the company and the consulting audiologist or physician; and guidelines for providing evaluation and treatment for hearing loss or ear disease determined to be not related to hazard exposure at work.

Those employees exposed to hazardous noise will need to use hearing protectors. While seemingly simple, this can become a complicated aspect of the hearing conservation program. The audit should address the criteria for determining whether or not the use of hearing protectors is required. Types of hearing protection and sources should be addressed and if not implemented in a policy, the person(s) responsible for making the decisions should be identified.

Program evaluation check list, can serve well. (Continued...)

Hearing protectors need maintenance and replacement and how that is to be achieved should be a topic of the audit. The audit should also consider what to do about the employee who continues to show increasing hearing loss even though using hearing protection. Lastly, the audit should address the employee who refuses to use hearing protection when it is required or who wishes to use self-provided protection.

An effective hearing conservation program ensures that employees and management receive training and educational experiences. The audit should address the frequency of the training, how the training is provided, and what the training emphasis will be. For example, training may be spaced over the year with some of it given by an instructor, some by reading materials, some by video tape or interactive computer program, and some by the audiometric technician at the time of the hearing test.

The audit will help the company determine the resources needed for training, identifying those easily accessible and those that must be acquired. Plans should be made in advance to evaluate the effectiveness of the hearing conservation program. Many companies find that after a couple of years of operating a program they have no idea if their efforts are having any effect. The audit should define what metrics will be used to determine if the program is successful or not. Once the metrics have been selected, the program implementer must make sure that all data collected support the evaluation strategy selected.

The hearing conservation program audit should be reviewed annually by the program implementer and appropriate managerial personnel. As the program grows and evolves, the audit will provide a mechanism to force into review all aspect of the program. By using the audit, it will be unlikely that any portion of the program will run ineffectively or incorrectly, since problems should be identified so that they may be remediated immediately.

See these sample hearing conservation program checklists.

How does safety and health management system assistance help employers and employees?

Working in a safe and healthful environment can stimulate innovation and creativity and result in increased performance and higher productivity. The key to a safe and healthful work environment is a comprehensive safety and health management system. OSHA has electronic compliance assistance tools, or eTools, on its website that “walk” users through the steps required to develop a comprehensive safety and health program. The eTools are posted at, and are based on guidelines that identify four general elements critical to a successful safety and health management system:

  • management leadership and employee involvement;
  • worksite analysis;
  • hazard prevention and control; and
  • safety and health training.

Hearing Conservation Program Evaluation Checklist

Training and education

Failures or deficiencies in hearing conservation programs (hearing conservation programs) can often be traced to inadequacies in the training and education of noise-exposed employees and those who conduct elements of the program.

  1. Has training been conducted at least once a year?
  2. Was the training provided by a qualified instructor?
  3. Was the success of each training program evaluated?
  4. Is the content revised periodically?
  5. Are managers and supervisors directly involved?
  6. Are posters, regulations, handouts, and employee newsletters used as supplements?
  7. Are personal counseling sessions conducted for employees having problems with hearing protection devices or showing hearing threshold shifts?

Supervisor Involvement

Data indicates that employees who refuse to wear hearing protectors or who fail to show up for hearing tests frequently work for supervisors who are not totally committed to the hearing conservation programs.

  1. Have supervisors been provided with the knowledge required to supervise the use and care of hearing protectors by subordinates?
  2. Do supervisors wear hearing protectors in appropriate areas?
  3. Have supervisors been counseled when employees resist wearing protectors or fail to show up for hearing tests?
  4. Are disciplinary actions enforced when employees repeatedly refuse to wear hearing protectors?

Noise Measurement

For noise measurements to be useful, they need to be related to noise exposure risks or the prioritization of noise control efforts, rather than merely filed away. In addition, the results need to be communicated to the appropriate personnel, especially when follow-up actions are required.

  1. Were the essential/critical noise studies performed?
  2. Was the purpose of each noise study clearly stated? Have noise-exposed employees been notified of their exposures and apprised of auditory risks?
  3. Are the results routinely transmitted to supervisors and other key individuals?
  4. Are results entered into health/medical records of noise exposed employees?
  5. Are results entered into shop folders?
  6. If noise maps exist, are they used by the proper staff?
  7. Are noise measurement results considered when contemplating procurement of new equipment? Modifying the facility? Relocating employees?
  8. Have there been changes in areas, equipment, or processes that have altered noise exposure? Have follow-up noise measurements been conducted?
  9. Are appropriate steps taken to include (or exclude) employees in the hearing conservation programs whose exposures have changed significantly?

Engineering and Administrative Controls

Controlling noise by engineering and administrative methods is often the most effective means of reducing or eliminating the hazard. In some cases engineering controls will remove requirements for other components of the program, such as audiometric testing and the use of hearing protectors.

  1. Have noise control needs been prioritized?
  2. Has the cost-effectiveness of various options been addressed?
  3. Are employees and supervisors apprised of plans for noise control measures? Are they consulted on various approaches?
  4. Will in-house resources or outside consultants perform the work?
  5. Have employees and supervisors been counseled on the operation and maintenance of noise control devices?
  6. Are noise control projects monitored to ensure timely completion?
  7. Has the full potential for administrative controls been evaluated? Are noisy processes conducted during shifts with fewer employees? Do employees have sound-treated lunch or break areas?

Monitoring Audiometry and Record Keeping

The skills of audiometric technicians, the status of the audiometer, and the quality of audiometric test records are crucial to hearing conservation program success. Useful information may be gathered from the audiometric records as well as from those who actually administer the tests.

  1. Has the audiometric technician been adequately trained, certified, and recertified as necessary?
  2. Do on-the-job observations of the technicians indicate that they perform a thorough and valid audiometric test, instruct and consult the employee effectively, and keep appropriate records?
  3. Are records complete?
  4. Are follow-up actions documented?
  5. Are hearing threshold levels reasonably consistent from test to test? If not, are the reasons for inconsistencies investigated promptly?
  6. Are the annual test results compared to baseline to identify the presence of an OSHA standard threshold shift?
  7. Is the annual incidence of standard threshold shift greater than a few percent? If so, are problem areas pinpointed and remedial steps taken?
  8. Are audiometric trends (deteriorations) being identified, both in individuals and in groups of employees? (NIOSH recommends no more than 5% of workers showing 15 dB Significant Threshold Shift, same ear, and the same frequency.)
  9. Do records show that appropriate audiometer calibration procedures have been followed?
  10. Is there documentation showing that the background sound levels in the audiometer room were low enough to permit valid testing?
  11. Are the results of audiometric tests being communicated to supervisors and managers as well as to employees?
  12. Has corrective action been taken if the rate of no-shows for audiometric test appointments is more than about 5%?
  13. Are employees incurring STS notified in writing within 21 days? (NIOSH recommends immediate notification if retest shows 15 dB Significant Threshold Shift, same ear, and the same frequency.)


Referrals to outside sources for consultation or treatment are sometimes in order, but they can be an expensive element of the hearing conservation program, and should not be undertaken unnecessarily.

  1. Are referral procedures clearly specified?
  2. Have letters of agreement between the company and consulting physicians or audiologists been executed?
  3. Have mechanisms been established to ensure employees needing evaluation or treatment actually receive the service (i.e., transportation, scheduling, and reminders)?
  4. Are records properly transmitted to the physician or audiologist, and back to the company?
  5. If medical treatment is recommended, does the employee understand the condition requiring treatment, the recommendation, and methods for obtaining such treatment?
  6. Are employees being referred unnecessarily?

Hearing Protection Devices

When noise control measures are not feasible, or until such time as they are installed, hearing protection devices are the only way to prevent hazardous levels of noise from damaging the inner ear. Making sure that these devices are worn effectively requires continuous attention on the part of supervisors and program implementers as well as noise-exposed employees.

  1. Are hearing protectors made available to all employees whose daily average noise exposures are 85 dBA or above? (NIOSH recommends requiring HPD use if noises equal or exceed 85 dBA regardless of exposure time.)
  2. Are employees given the opportunity to select from a variety of appropriate protectors?
  3. Are employees fitted carefully with special attention to comfort?
  4. Are employees thoroughly trained, not only initially but at least once a year?
  5. Are the protectors checked regularly for wear or defects, and replaced immediately if necessary?
  6. If employees use disposable hearing protectors, are replacements readily available?
  7. Do employees understand the appropriate hygiene requirements?
  8. Have any employees developed ear infections or irritations associated with the use of hearing protectors? Are there any employees who are unable to wear these devices because of medical conditions? Have these conditions been treated promptly and successfully?
  9. Have alternative types of hearing protectors been considered when problems with current devices are experienced?
  10. Do employees who incur noise-induced hearing loss receive intensive counseling?
  11. Are those who fit and supervise the wearing of hearing protectors competent to deal with the many problems that can occur?
  12. Do workers complain that protectors interfere with their ability to do their jobs? Do they interfere with spoken instructions or warning signals? Are these complaints followed promptly with counseling, noise control, or other measures?
  13. Are employees encouraged to take their hearing protectors home if they engage in noisy non-occupational activities?
  14. Are new types of or potentially more effective protectors considered as they become available?
  15. Is the effectiveness of the hearing protector program evaluated regularly?
  16. Have at-the-ear protection levels been evaluated to ensure that either over or under protection has been adequately balanced according to the anticipated ambient noise levels?
  17. Is each hearing protector user required to demonstrate that he or she understands how to use and care for the protector? The results documented?


Remaining organized and current on administrative matters will help the program run smoothly.

  1. Have there been any changes in federal or state regulations? Have the hearing conservation program’s policies been modified to reflect these changes?
  2. Are copies of company policies and guidelines regarding the hearing conservation program available in the offices that support the various program elements? Are those who implement the program elements aware of these policies? Do they comply?
  3. Are necessary materials and supplies being ordered with a minimum of delay?
  4. Are procurement officers overriding the hearing conservation program implementer’s requests for specific hearing protectors or other hearing loss prevention equipment? If so, have corrective steps been taken?
  5. Is the performance of key personnel evaluated periodically? If such performance is found to be less than acceptable, are steps taken to correct the situation?
  6. 6. Safety: Has the failure to hear warning shouts or alarms been tied to any accidents or injuries? If so, have remedial steps been taken?