How to Implement an Effective Hearing Conservation Program
According to the CDC, “hearing loss is the third-most common chronic physical condition among adults after hypertension and arthritis.” For workers in the railroad, manufacturing, transportation and construction industries, noise is often considered just a part of the job. With OSHA reporting an estimated “242 million spent annually on workers’ compensation for hearing loss disability,” worksites cannot afford to overlook the damage caused by prolonged noise exposure.
Currently, OSHA requires “employers to monitor noise exposure levels in a way that accurately identifies employees exposed to noise at or above 85 decibels (dB) averaged over 8 working hours, or an 8-hour time-weighted average” (OSHA 2002). While any given workplace may be trying to stay compliant by providing hearing protection equipment and requiring that equipment be worn, it is impossible to monitor every employee on a work site throughout a shift. To ensure employee compliance, OSHA recommends developing a Hearing Conservation Program (HCP) specific to your employees and workplace.
The Purpose of a Hearing Conservation Program
A hearing conservation program is not just about equipping workers with proper hearing protection. An effective program should prevent the risk for occupational hearing loss, preserve and protect hearing, and provide workers with the knowledge and hearing protection necessary to safeguard themselves. For the program to be successful, both employees and upper management must be committed to making it work. Studies have shown that successful programs not only reduce the number of worker incidents, but they have the power to boost employee morale and productivity levels.
What Does a Hearing Conservation Program Include?
To be compliant, a hearing conservation program should measure workplace noise levels; provide free annual hearing exams, hearing protection, and employee training. Each program should also be reviewed annually for effectiveness. When setting up a hearing conservation program for your worksite, it is important to include these seven elements:
- Noise monitoring
- Administrative Policies and Enforcement
- Audiometric Evaluation
- Hearing Protection Offering
- Employee Education/Training
- Record Keeping/Tracking
- Program Evaluation
Noise Monitoring: Before you can choose the appropriate types of safety equipment to protect your workers’ hearing, you have to fully understand all of the hazards your employees will be exposed to in the course of a normal day. The best way to do this is to measure exposure types at each worksite and then record the decibel ratings. This testing can be performed by using tools such as a sound level meter or a noise decimeter.
Administrative Policies and Enforcement: Based on the recorded decibel ratings of your workplace, management should create and enforce policies that clearly outline what type of hearing protection is required in each area. This step is also a good opportunity to evaluate noise exposure areas and eliminate the hazard where possible.
Audiometric Evaluation: The best way to evaluate your workplace’s HCP’s effectiveness is to conduct regular hearing tests. Employees should have their hearing tested by an audiologist every two years. This will help you establish each employee’s baseline of hearing, allowing you to measure against that baseline throughout the duration of their employment.
Hearing Protection Offering: When selecting hearing protection for your worksite it is important to offer options that provide adequate protection and are comfortable and properly fitted. Compatibility with other PPE and the workers’ ability to communicate must also be considered. The most common types of hearing protection include earplugs, earmuffs, and ear bands.
Employee Education and Training: OSHA requires training to occur at least annually. This not only creates engagement and buy-in from your employees, but it also ensures that all employees have an up-to-date understanding of the importance of hearing protection and the proper way to use their safety equipment.
Record Keeping and Tracking: Employers must keep records of measured noise exposure for two years, and must maintain audiometric testing records for each employee for the entire duration of their employment. “Audiometric test records must include the employee’s name and job classification, date, examiner’s name, date of the last acoustic or exhaustive calibration, measurements of the background sound pressure levels in audiometric test rooms, and the employee’s most recent noise exposure measurement” (OSHA 2017).
One of the most recognized needs for setting up a hearing conservation program is threshold shifts. OSHA defines a Standard Threshold Shift (STS) "as an average 10dB or more loss in one or both ears relative to the most current baseline audiogram averaged at 2000, 3000 and 4000 Hz" (OSHA 2010). The established baseline is specific to each ear, and any hearing loss is assumed work-related.
Program Evaluation: When evaluating your workplace’s HCP, there are two basic approaches, “(1) to assess the completeness of and quality of the program’s components, and (2) to evaluate the audiometric data” (Suter and Franks 1990). Choose the method that makes the most sense for your workplace.
Workplace safety and OSHA compliance are essential parts of any workplace safety program, especially safety issues that are frequently overlooked, like hearing damage. Our ORR Safety experts are here to help you set up a custom program unique to your industry and safety needs. We can help you select the best hearing protection equipment and instrumentation to measure noise hazards at your worksite. If you have questions or would like to know more about our safety solutions or products, please contact us.
OSHA (2010) Answer 3 Questions To Determine If a Worker’s Hearing Loss Is Recordable. Retrieved from: https://www.ctdol.state.ct.us/osha/HearingLoss.pdf
OSHA (2002) Hearing Conservation. Retrieved from: https://www.osha.gov/Publications/osha3074.pdf
OSHA (2017) Occupational Noise Exposure. Retrieved from: https://www.osha.gov/SLTC/noisehearingconservation/index.html
Alice H. Suter and John R. Franks (1990) A Practical Guide to Effective Hearing Conservation Programs in the Workplace. Retrieved from: https://www.cdc.gov/niosh/docs/90-120/pdfs/90-120.pdf