Health & Safety Insights

All employers, regardless of size, need to perform a job hazard assessment if work-related hazards are present in order to comply with Occupational Safety and Health Administration (OSHA) regulations. Excessive exposure to noise can cause hearing loss, in addition to physical and psychological stress. Since there’s no cure for noise-induced hearing loss, reducing employees’ exposure is the only way to prevent permanent hearing damage. This can be accomplished through hearing protective devices, proper training and other corrective actions.

Hearing Protection

According to OSHA regulations, employers shall make hearing protectors available to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater at no cost to the employees. Hearing protectors shall be replaced as necessary. It is also required that employers ensure that exposed employees are wearing hearing protection provided. Employers are required to provide the opportunity to employees to select their hearing protectors from a variety of suitable hearing protectors. In other words, the hearing protection options cannot be limited to just one. Employers must have at least one type of a hearing plug and hearing muff for employees to select from. Hearing protection options provided must be adequate to protect employees to the sound levels in which they are exposed. The Noise Reduction Rating (NRR) that represents the hearing protection device’s ability to reduce noise under lab environments. This NRR is then used to actual work environment exposures.

Employee Training

OSHA also requires training of employees with regards to occupational noise exposure. This training shall be instituted by the employer and employees must participate. Employees who are trained on the reasons for hearing conservation are more likely to be motivated to wear hearing protection. Training shall occur at initial assignment and annually thereafter for those included in the hearing conservation program. If there are any changes in the program, equipment, or work processes, then this should be reflected in the annual training. Training content must at a minimum include the following topics:

• The effects of noise on hearing
• The selection, fit, and care of hearing protectors
• The purposes 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 the test procedures
• Copies of this OSHA standard should be discussed and readily available to employees

Recordkeeping

Employers shall retain records for audiometric testing. The noise exposure measurement results must be retained for at least two years. Employee audiometric test records shall be retained for the duration of the employee’s employment. The records shall include:

• Name and job classification of the employee
• Date of the audiogram
• The examiners name
• Date of the last acoustic calibration of the audiometer
• Employee’s most recent noise exposure assessment

Corrective Action

If sampling shows results are determined to be above the regulatory occupational exposure limits, corrective actions must be taken. In order to protect employees from overexposure, OSHA requires that employers follow a hierarchy of controls to minimize such exposures to toxic and/or hazardous substances. The hierarchy is as follows: 1) Elimination/substitution; 2) Engineering controls; 3) Administrative controls; 4) Personal Protective Equipment (PPE).

Based on the job duties of employees, elimination or substitution of noise may not be feasible. Regarding engineering controls, mufflers on equipment, enclosing equipment, or other sound dampening devices may be installed to reduce noise exposures. Employers are required to at least investigate these options to see if they are possible. These must be effective in reducing employee exposure to below occupational exposure limits. Cost is not an acceptable excuse for employers to not implement such efforts.

Examples of administrative controls include restricting access to area or job rotation. Personal Protective Equipment (PPE) such as ear plugs or muffs may be acceptable. However, OSHA considers this a last resort and should only be implemented after attempting to use other options in the hierarchy of controls. If equipment used on-site in the production areas is changed, added, or retrofitted, this could impact the noise levels and additional sampling is recommended.

Hearing Conservation Program

According to OSHA 29 CFR 1910.95, the employer shall administer a continuing, effective hearing conservation program, whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level (TWA) of 85 decibels measured on the A scale (slow response). For purposes of the hearing conservation program, employee noise exposures shall be computed in accordance with appendix A and Table G-16a (referenced below), and without regard to any attenuation provided by the use of personal protective equipment.

Representative employee exposure samples must be collected and compared to Occupational exposure limits (OELs) in reference to regulations set forth by the OSHA. These samples will determine if any of these exposures are in excess of occupational exposure limits. If OELs are exceeded, then employers are required to implement means of protecting employees from unwanted exposure as appropriate. Employees must be notified of the results of the noise exposure sampling. In addition to initial sampling, if there is a change in production or equipment is added, employers must repeat monitoring to determine if these changes increase employee exposures.

An employee’s hearing over time is monitored by audiometric testing. This also provides a chance for employees to be educated by employers of the risk of exposure to occupational noise. An audiometric program must be established and maintained for all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels TWA. Elements of the program include baseline audiograms, annual audiograms, training, and follow up procedures. 

TABLE G-16 - PERMISSIBLE NOISE EXPOSURES (1)

Reference: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95

Occupational noise exposure can be a hazard that is not always anticipated as the focus is often more on safety related issues. If you have concerns about occupational noise at your site, a sound level meter should be used for screening and a full work shift sample may need to be collected. Consider utilizing consultative support as an unbiased independent third party to meet your needs. They have the tools, resources, and skills to assist you with staying in compliance and minimizing the potential for employees have work related hearing loss.