Setting Up Your Workplace's Hearing Conservation Program
Workers in the transportation industry face several safety hazards in the course of a normal workday, but one of the most dangerous and the most overlooked is hearing damage. Employees working in the air and rail industries are often exposed to high levels of noise for an extended period of time, and without the appropriate safety equipment, the damage caused by this prolonged exposure may be severe.
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, especially if there is only one safety manager.
Protect Your Workers
More than 22 million workers are exposed to dangerous levels of noise in the workplace in the US alone, and it is estimated that “$242 million is spent annually on workers' compensation for hearing loss disability” (OSHA 2017). In order to ensure employee compliance, OSHA recommends developing a Hearing Conservation Program (HCP) specific to your employees and workplace. This program will track noise reduction over the span of an employee’s career, and consists of 7 steps:
1. Noise monitoring
2. Administrative Policies and Enforcement
3. Audiometric Evaluation
4. Hearing Protection Offering
5. Employee Education/Training
6. Record Keeping/Tracking
7. 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 the different types of noise exposures 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 maybe even more importantly 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 try to eliminate as much noise as possible.
Audiometric Evaluation: The best way to evaluate your workplace’s HCP’s effectiveness is to have 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, which makes it easier to measure against that baseline for the length of their employment to make sure their hearing is not being damaged.
Hearing Protection Offering: When it comes to hearing protection, your employees should have at least three options to choose from. These include ear plugs, ear muffs, and ear bands.
Employee Education and Training: Regularly scheduled training - OSHA requires training to occur at least annually - not only creates engagement and buy-in from your employees, 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 2 years, and must maintain audiometric testing records for each employee for the entire duration of their employment at your company. “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 are 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 to be work related.
Program Evaluation: When evaluating your workplace’s HCP, there are 2 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.
ORR Safety Experts are Ready to Help
Workplace safety and OSHA compliance are important parts of building any workplace safety plan, but they are especially important in addressing safety issues that are frequently overlooked, like hearing damage. There are so many things to consider when setting up your workplace’s hearing conservation program that it may feel daunting to begin. Our ORR Safety experts are ready and waiting to assist you in setting up a program unique to your workplace, advise on the best hearing protection equipment and instrumentation to measure noise hazards at your worksites, or to answer any other questions you have. Contact us today!
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