Be Aware Safety Tips Have You Heard About OSHA’s Hearing Conservation Requirements? By Laura Helmrich-Rhodes, CSP, Ed.D.
here are many written programs required by the OccupaT tional Safety and Health Administration (OSHA) and a formal, written, hearing conservation program (HCP) is one of
them. During my on-site safety audits, I have found the HCP is often missing. This is not surprising, considering in 2019 OSHA issued 168 citations for just the written program portion of the HCP standard to manufacturing companies. More citations were issued for other parts of that same standard (see graph on page 16). Protecting employee hearing is built on engineering controls and the implementation of a well written program. Many spring manufacturing companies, or portions of the manufacturing buildings, are operating at a time weighted average (TWA) of 85 decibels (dB) over an eight hour day. This is called the “action level,” according to OSHA. This is when employers must make hearing protection available at no cost to its employees. Usage does not have to be enforced at this level. It is up to the employee to decide; however, everyone exposed to 85 dB must be included in the formal HCP as described in detail below. When noise levels hit 90 dB TWA, over an eight hour day, hearing protection must be worn and fully enforced. Noise Monitoring
In order to determine if exposures are at or above this level, it may be necessary to measure or monitor the actual noise levels in the workplace and to estimate the noise exposure or "dose" received by employees during the workday. Noise monitoring or measuring must be conducted only when exposures are at or above 85 dB. Factors which suggest that noise exposures in the workplace may be at this level include employee complaints about the loudness of noise, indications that employees are losing their hearing, or noisy conditions which make normal conversation difficult (see Informational Appendix in Helpful Links on page 17). There are two types of monitoring necessary. One is an area survey that measures the noise around equipment and is usually reported as a map, similar to a topographical map, with sound level readings noted in the various areas of the plant. This only tells us what noise is present. It does not tell us the
Laura Helmrich-Rhodes, CSP, Ed.D., is an independent regulations compliance consultant to the Spring Manufacturers Institute (SMI). A former member of PA/OSHA Consultation, she is an associate professor in the Safety Sciences Department at Indiana University of Pennsylvania where she teaches graduate and undergraduate classes on topics such as OSHA standards, safety communications, workers’ compensation and human relations. Rhodes is available for safety advice and information. Contact SMI at 630-495-8588 or laurahrhodes@gmail.com.
dose of noise each employee is experiencing in a workday. This measurement method is generally referred to as "area" noise monitoring. These are helpful in determining where signs should be posted and which departments should have more extensive testing to determine what the employees are experiencing. To determine employee exposures, personal dosimeters must be used. A dosimeter is a device attached to the employee’s clothing, usually near the shoulder, with a sturdy clip. The device measures the noise levels while they carry out their daily tasks. It then averages the noise exposure over the workday. The results are analyzed and a dose is determined. These tests should be done by a trained professional. Preferably, a certified industrial hygienist (CIH) should take the readings or overseeing those who do the tests. The CIH is specially educated and trained in employee health concerns and the operation of monitoring equipment. Their expertise in these devices is paramount, since they must be calibrated prior to use. Also, strict adherence to the manufacturer’s recommendations needs to be followed to assure accuracy. Both CIH and certified safety professionals (CSPs) would be able to make valuable recommendations for the elimination of noise through engineering and administrative controls too. Your workers’ compensation carrier may conduct these tests for little or no cost and have CIHs and CSPs on staff. If testing was done in the past and no hazard found, it is likely those readings have changed. Production has significantly increased in some spring and wireforming companies, and therefore it is highly recommended that new results be obtained to assure employees are being properly protected. If machinery has been added or reconfigured, then re-monitor. Many companies choose to re-monitor periodically (once every year or two) to ensure that all exposed employees are included in their hearing conservation programs (see Informational Appendix). Written Program: The Nuts and Bolts
It is not enough to download a sample written program and stick it in a binder. The written program is meant to be a living document that actually assures that important events happen. For example, who will be purchasing the correct hearing protection, with the correct noise reduction rating (NRR)? Who will conduct training and where will employees go to have annual audiometric testing? These are just a few key elements. All written safety and health programs should outline the responsibilities, authorities and accountabilities of everyone dedicated to help prevent employee noise-induced hearing loss. Most written programs are to be reviewed annually to assure they are working. OSHA’s “Recommended Practices for Safety and Health Programs” suggest three steps in assuring programs work as expected. First, monitor the performance and progress; verify the program is implemented and operating; and last, correct the program shortcomings and identify opportunities to
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