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Course 751 - Hearing Conservation Program Management

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

Policy Needs (Optional)

Policies Management Must Address

  1. Corporate environment should promote a safety culture where the employees are empowered to protect their own health and to facilitate the protection of the health of fellow workers.
  2. Program policies should be based on effective practices rather than on minimum compliance with government regulations.
  3. The hearing conservation program must be a functional part of the overall company safety and health program. It should not be a stand-alone, separately-budgeted operation.
  4. A key individual (referred to as the program implementer during this course) should have ultimate responsibility for the program. This person may not necessarily perform all of the functions of the hearing conservation program, but is in charge of the overall program. Experience with successful hearing conservation programs shows that a single individual often makes the crucial difference between success and failure. This person is often a nurse or an audiometric technician, but may be a safety and health officer, a supervisor, or a designated employee. This program implementer acts as the conscience and champion of the hearing conservation program. He or she focuses the attention of both management and employees on the hearing conservation program's policies and ensures that they take the necessary steps to implement them. The program implementer should also have stature in the hearing conservation program's organizational chart, with authority to make decisions, correct deficiencies, and enforce necessary actions.
  5. The program implementer should work with management and employees to develop and implement hearing loss prevention plans and policies for an effective program. As a team leader, the program implementer should be given the authority to establish hearing loss prevention provisions that meet or exceed the letter and intent of OSHA’s noise control and hearing conservation regulations.
  6. Employee and administrative compliance with the company's hearing conservation program policies and procedures should be a condition of employment.
  7. Hearing conservation program policies should clearly describe standard operating procedures for each phase of the program. Specific policy statements should be developed for the important elements of the program. For example, it should be company policy to require the participation of all noise-exposed employees in the audiometric program and to require the consistent and proper wearing of hearing protectors in posted areas, even if employees or supervisors are only passing through these areas. These requirements should be conditions of employment. Other important policy statements should be written to cover:
    1. Adopting a prescribed schedule for monitoring of employee noise exposure levels and other risks, including ensuring that equipment and personnel training are appropriate to the task.
    2. Counseling of employees immediately following each audiometric test, whether it is the initial, annual, retest, threshold-shift confirmation, or termination examination.
    3. Determining the adequacy and correct use of hearing protection devices by on-site equipment checks.
    4. Educating, training, and motivating employees to support the company's hearing conservation program provisions; assessing employee attitudes and assessing knowledge gained from periodic training.
    5. Establishing a program of quality assurance for the performance of audiometry and management of audiometric records.
    6. Reviewing audiometric data to verify the effectiveness of the hearing conservation program.
    7. Encouraging employees to use company-provided hearing protectors for off-the-job exposure.
    8. Purchasing hearing protectors, audiometers, noise measuring equipment, and quieter machinery. This policy should address the reasons why the program implementer responsible for the hearing conservation program, not the purchasing department, should have final decision about anticipated purchases.
  8. Companies may have varying needs for services which they cannot undertake with in-house staff. These can include noise surveys, employee education, audiometric testing, medical counseling, or the fitting of hearing protection devices. Outside vendors or contractors should be selected carefully so their services complement the abilities of the company staff and functional conduct of the in-house program elements. Vendors must understand and agree to abide by the company's hearing conservation program policies and standards of operation. On-site personnel must supervise contractors to make sure they carry out their obligations. Regardless of whether outside vendors or contractors are used, responsibility for the program stays with the program implementer.

Companies that issue clearly defined hearing loss prevention policies, and then adhere to these policies consistently, will have smoothly running hearing conservation programs. Employees will be fully informed, will comprehend their functional role, and will know what is expected of them. Equipment will be appropriate, hearing protection will be used by the right people in the right places, and the program elements will be implemented in a timely fashion.

Setting up training sessions

Management must emphasize the importance of the educational phase of the hearing conservation program by setting a high priority on and requiring attendance at regular hearing loss prevention training sessions. Training sessions should be mandatory not only for noise-exposed employees, but also for the supervisors and managers responsible for noisy production areas. A manager should participate in each employee training session to outline company policies and to explain and model the company's commitment to the hearing conservation program. The training program should consist of more than films and pamphlets. It must be tailored to the company's particular hearing loss prevention needs, and should include live presentations by articulate and knowledgeable speakers and hands-on practice sessions with hearing protectors.

Hearing loss prevention presentations should be updated and presented at least annually or more frequently if there is a significant turnover in employees. In addition to training sessions focused specifically on hearing loss prevention, management should also require the inclusion of hearing health topics in regularly-scheduled general safety meetings. These general meetings may be brief "reminder" meetings held weekly or monthly that also serve to inform workers about progress made toward meeting the goals of the company's various safety programs. In this way, hearing health will become an integrated part of the overall health and safety climate of the workplace.

Management should make sure that the hearing conservation program's staff (audiometric technicians, hearing-hazard assessors, noise control experts, those who fit and issue hearing protection devices, and supervisors) have received detailed instructions in hearing loss prevention so that they are qualified to lead employee training sessions and comfortable with answering employees' questions. Individuals who make the main presentations in the formal educational programs must be carefully selected to project genuine interest in the employees' welfare, and they must be speakers capable of gaining the employees' attention and respect. Peers can be particularly influential, and should be utilized whenever possible.

For example, a senior worker who has sustained a hearing loss may be willing to share stories about his/her frustrations with communication difficulties in day-to-day activities.

Setting up training sessions (Continued...)

A powerful testimonial and behavioral modeling from a respected co-worker can be extremely effective in convincing other workers to improve their hearing loss prevention behaviors.

The periodic hearing loss prevention training sessions are best structured in small groups. Often groups will consist of a supervisor and the employees in that production unit. Because these individuals will have common noise exposures, they will fall under a common hearing protector policy, and they often feel comfortable enough with each other to ask questions freely and make constructive comments. Management must ensure that the questions and concerns raised during educational sessions receive thoughtful and prompt follow-up.

In some situations, it may be best to arrange separate educational sessions for employees and supervisors/managers of noisy departments. This will permit each group to discuss concerns relevant to their respective needs and responsibilities. However, at some point, representatives of both groups will need to work together to resolve concerns and implement the hearing conservation program. If necessary, a neutral facilitator can be chosen to assist in the process by attending both groups' meetings. This facilitator might be the company health and safety professional or an outside consultant hired by the company to assist with the training and motivation phase of the program.

Program Implementer Responsibilities

Because the program implementer is usually responsible for planning the educational sessions, and in some instances, may be the appropriate person to conduct sessions, it is extremely important that the program implementer have training that is current and relevant to the hearing conservation program. The type of training that the program implementer will need is often available at state, regional, and national conferences sponsored by safety or hearing conservation associations.

The program implementer should plan sessions that are limited in content to short, simple presentations of the most relevant facts. When stressing health promoting behaviors (such as consistently wearing hearing protection while working in noise) research suggests that the focus should be on the real-life losses employees might expect if they don't act to protect their hearing. They might not be able to hear children's voices. They might not understand speech at a party, enjoy music and the sounds of nature, or perceive sounds that may convey other critical information—such as danger or equipment malfunctions.

Another useful approach might be to explain audiometric results so employees can see how their hearing threshold levels compare to those of non-noise exposed individuals with normal hearing in their own age group. Once employees agree upon why they need to conserve their hearing and how to monitor their audiogram results, the remainder of the program can focus on how to protect their hearing on and off the job through the effective use of hearing protection devices and good maintenance of engineering noise controls.

Program Implementer Responsibilities (Continued...)

The program implementer needs to ensure that presenters tailor education and motivation sessions to each particular group of employees and their supervisors. It is important to accurately describe the group's noise exposures, the group audiometric results, the options available to them with respect to hearing protection devices, and the engineering controls in place or planned for their department. Other topics may include progress reports on the status of specific elements of the hearing conservation program, comparisons of company-wide audiometric results, reports on the use of hearing protectors by department, and responses to questions or concerns expressed by employees. Materials should be updated every year. New multimedia materials such as interactive computer-based training may be considered for use.

Program implementers should ensure that films and pamphlets are used only as supplementary reinforcements for the live presentations, never as the whole program. Whenever possible, hands-on activities will facilitate learning. For example, workers can break into teams or small groups, and partners can help each other practice fitting various types of hearing protectors. Similarly, workers could initially break into small groups to brainstorm solutions to a particular noise problem in the plant, and then reconvene as a complete group to discuss the options and select a solution that is agreeable to the group. In this type of meeting, the program implementer would act as facilitator; guiding the workers through the various components of the meeting and coordinating the presentation of each group's suggestions.

Aside from formal educational presentations, program implementers should use every chance to remind employees and supervisors of the importance of the hearing conservation program and their active participation in it. One of the greatest opportunities to influence employee attitudes about hearing loss prevention occurs at the time of the annual audiometric test, when the program implementer or technician can compare the current thresholds to past results and check the fit and condition of hearing protection devices. Praise for employees with stable hearing and cautions for those with threshold shifts are effective if the comments come from a sincere and knowledgeable individual.

Contrary to the approach suggested above for promoting prevention behaviors, research has suggested that when faced with detecting a health problem that may have already occurred (i.e., discovering a hearing loss), workers may respond best at this time to health messages stressing what they have to gain by engaging in behaviors that will preserve their remaining good hearing. Program implementers in this situation should stress how employees can act to maintain their ability to hear music, voices, warning signals, etc.

In effective hearing conservation programs, the program implementers interact with employees more than just once a year. They ask questions and make comments about the hearing conservation program whether meeting workers on the plant floor or in the halls and cafeteria - wherever contact is made. The goal is to make the hearing conservation program a visible and ongoing concern.

Rewards and Punishments

In the past, it has been very popular to suggest that management should reward workers who wear their hearing protectors and punish those who do not. In reality, research has noted that managers are sometimes greatly disappointed with the results of this type of behavior modification approach. Sometimes reward and punishment systems can foster destructive competitiveness between workers in a group as well as bitter animosity between work groups and the managers who supervise them. Specific rewards can lose their appeal over time, sometimes requiring management to continually "sweeten the pot" to maintain the desired behaviors.

Additionally, management-designed reward systems can damage employee’s self-esteem and intrinsic motivation for performing their work well. This can lead to lowered productivity, declining quality of work, and a lack of motivation to apply oneself in that work situation. Workers who minimally follow the rules and put in their time may have simply decided that they have little personal responsibility for their contribution on the job. This type of apathy leads to negative attitudes toward work and the health programs associated with work, including hearing loss prevention.

There is a great amount of literature discussing the importance of an individual's perceptions of personal control in a wide variety of situations. It suggests that one reason why rewards sometimes fail to maintain desired behaviors is that workers perceive that they have little real control over their work and that management's system of doling out rewards and punishments controls their behavior on the job in a manipulative manner.

Similarly, there are well documented negative side effects of relying on punishment to discipline workers for infraction of safety rules. While punishment may stop or discourage undesirable behavior when the behavior is closely monitored, it does not directly encourage desirable behaviors. Furthermore, in many settings, the punisher is also the person (usually a supervisor or the program implementer) who is responsible for administering rewards. This creates a difficult situation that might seriously diminish the effectiveness of rewards.

If an incentive system is in place or desired by management and the workers, a successful program can be developed with care. Both management and employees should agree on specific goals for the program. Both groups should work together to choose the rewards and sanctions that will apply to the program. As much as possible, the affected workers should set up the system and enforce it; otherwise management may damage the motivation and morale of the workers with inappropriate and unnecessary controls. In this way, workers can be encouraged to assume as much responsibility as feasible for their health and their work environment. They will look out for and police each other. This "bottom-up" approach is more likely to build camaraderie and group commitment to safety than the traditional "top-down” management centered approaches of the past.

Record Keeping

Records quite often get the least attention of any of the hearing conservation program's components. But audiometric comparisons, reports of hearing protector use, and the analysis of hazardous exposure measurements all involve the keeping of records. Unfortunately, records are often kept poorly because there is no organized system in place, and in many cases, those responsible for maintaining the records do not understand their value. People tend to assume that if they merely place records in a file or enter them into a computer, adequate record keeping procedures are being followed.

Many companies have found that their record keeping system was inadequate at the moment accurate information was most needed. This has often occurred during the processing of compensation claims. Problems can be avoided by implementing an effective record keeping system, in which: 1) management encourages that the system be kept active and accessible, 2) hearing conservation program implementers make sure that all of the information entered is accurate and complete, and 3) employees validate the information.

Hearing conservation program records should include all items for each phase of the program: 1) hearing loss prevention audit, 2) monitoring hearing hazards, 3) engineering and administrative controls, 4) audiometric evaluation, 5) personal hearing protective devices, 6) education and motivation, and 7) program evaluation. Each phase generates its own form of records, and the information from the various records must be considered in order to evaluate the effectiveness of the hearing conservation program.

Management Responsibilities

Management should make available the facilities to store records and should provide sufficient resources to process them quickly and accurately. The forms or computer format used to gather information is the foundation of a good record keeping system. These forms should be designed so that necessary actions are triggered and then documented. If a company does not have the available resources to design a hearing loss prevention record keeping system compatible with the general safety and health record system, the company should turn to consultants for assistance.

Because hearing conservation program records can be complex, management should see that program implementers are fully trained in the record keeping system and its function. There should be working copies of records as well as archived copies. If an outside contractor keeps the records, a method should be established to ensure that original records are accurate, and are returned and entered into the company's files in a timely fashion. Hearing loss prevention records are medical records and, as such, deserve the same level of integrity and confidentiality as other medical records. The company needs to make sure that these records are accessible only to program implementers, affected employees or their designated representatives, and government inspectors.

Increasingly, companies maintain all of their employee health and safety records in a computer system. The use of computers supports easy access and storage of data, provides for automatic triggering of actions based on the data contained in the records, and generates hard copies to be maintained as archives. Prudent managers will see that original copies of records pertaining to individual audiometry and hazard exposure monitoring are retained in personal medical or industrial hygiene folders. The records should be made available at the time of audiometric testing.

Having the audiogram available will allow an instantaneous check of the new audiogram with the others on record so that checks for threshold shift can be made and so that the reliability of the new audiogram can be assessed. Having information about hearing hazard exposure, hearing protector use, and related information available will allow the tester to make an accurate and timely report to the employee of the outcome of the evaluation as well as conduct the one-on-one training that is so important to hearing conservation program success.

Management Responsibilities (Continued...)

While management may provide the record keeping system and the necessary resources, the program implementers must ensure that the system works. The most important attributes of an effective record keeping system are standardization, maintenance, integration, and documentation.

Standardization ensures commonality and consistency of data and format. Maintenance keeps records current and accurate. Integration of the recorded information allows the program implementer to assess the impact of the program on employees' hearing. Documentation of hearing conservation program elements permits analysis of long-range implications since cause-effect relationships associated with hazardous exposure levels only become evident over time.

Program implementers may wish to consider the following rule of thumb regarding how long records should be kept: Keep all records until you leave – then let the next person decide how long to keep the records. More practically, records should be kept for the length of employment plus 30 years, just as is standard practice with medical records. Thus, it is important for the program implementer to have resources for adequate records storage facilities be they computer based or in hard copies.

In addition, a working group of the American National Standards Institute has drafted guidelines for analyzing audiometric data to evaluate hearing conservation program effectiveness–ANSI S12.13, Draft Standard for Evaluating the Effectiveness of Hearing Conservation Programs. The procedures of this standard are most useful in determining that the audiometric data are consistent and lack much variability; that the database has integrity. If year-to-year audiograms show changes that are due to poor audiometry and not to changes in hearing, it will be impossible to use the audiometric data to determine whether or not the hearing conservation program is successful.

The domain of hearing loss prevention embraces many technical disciplines: hearing science, audiology, industrial hygiene, occupational health, psychology, sociology, electroacoustics, and mechanical engineering, to name a few. Each of these is a dynamic specialty. Within any of these fields, what constituted "standard practice" only a few years ago is unlikely to be today's standard. It follows that today's standards will also evolve. Because hearing loss prevention represents the integration of many vibrant elements, it too, must change.