Although recognized as one of the top global occupational hazards, noise-induced hearing loss (NIHL) is one of the least visible illnesses. Unlike other occupational injuries, noise-induced hearing loss causes no immediate pain or trauma, leaves no scars or bruises, and is unnoticeable at its
earliest stages.

NIHL accumulates over time with each additional over-exposure, the damage caused is permanent, and incidence is on the rise. However, it is also completely preventable.

According to the World Health Organization, NIHL is the most common, permanent and preventable injury in the world.

Noise-induced hearing loss is “the number ne hidden disability” and most common occupational illness in North America, according to the Centers for Disease Control.

Individuals aged 45-64 experienced a 26 percent increase in hearing problems between 1971 and 1990, and OSHA estimates that more than 10 million U.S. workers have lost part of their hearing and as many as 30 million more may be at risk today1.

OSHA’s Occupational Noise Exposure Standard and Hearing Conservation Amendment (29 CFR 1910.95) outlines a rigorous, worker-oriented program to mitigate risks of noise exposure in the workplace.

OSHA’s first line of defense involves engineering and administrative controls on equipment or manufacturing processes to abate noise. If these fail, the OSHA standard mandates that “personal protective equipment” be provided and that employers “shall administer a continuing, effective
hearing conservation program” when worker exposure levels “equal or exceed an eight-hour time weighted average sound level (TWA) of 85 dBA.”

So what is an “effective hearing conservation program,” and how is one implemented? Following is a look at the five main components of an OSHA-approved hearing conservation program and
the employer’s responsibilities for implementation.

Noise Monitoring

OSHA requires noise monitoring when exposure levels in the workplace “may equal or exceed” the 85 dBA Action Level. How do you know when noise reaches this level? A common rule of thumb is that if you have to shout over the background noise to communicate with someone at an arm’s length away, the noise level is probably hazardous.

Monitoring requires sound level meters that sample area noise levels, and dosimeters, which record an individual’s noise exposure. While area sampling provides a good understanding of general noise levels throughout a facility, personal sampling documents a worker’s complete exposure during the course of the work day. As workers may move about during the course of a workday, and are exposed
to a variety of noises and noise levels, dosimetry provides the best indication of an individual’s TWA.

Monitoring can be performed in-house, as long as the equipment is properly calibrated to ensure accuracy. However, many companies contract with outside monitoring firms or even utilize their own liability insurers to perform this service, and make appropriate recommendations.

However you decide to go, here are several points to keep in mind:
• Noise monitoring is not required annually, however it must be performed any time there is a noticeable change in machinery or manufacturing processes.
• Identify noisy areas and any changes in noise levels. Posting a “noise map” of a facility in an easy-to-access location can help give workers a visual reference to sites where hearing protection devices
(HPDs) must be worn, and areas where it’s a good idea to keep HPDs handy.

Posting specific decibel levels in work areas is also an effective way to identify the need for HPDs and help workers select the right protector for their application.
• Include the TWA of an employee’s noise exposure in their job description and/or their employment file. This can help an audiologist better understand a worker’s occupational noise history
when interpreting audiograms.

Audiometric Testing
Per OSHA, all new employees must undergo an audiometric test within six months of employment, and all noise-exposed workers must be tested on an annual basis.

Individual results are compared from year to year to determine if hearing has remained stable.
Audiometric testing must be conducted by a trained professional, and can be done in-house or outsourced to industrial clinics and audiology practices. Many practices offer mobile testing services that are very economical, and can work around employees’ schedules—especially if a company works
three shifts—to minimize worker downtime.

One source list of competent mobile testing services is maintained by the National Hearing Conservation Association. A good idea is to use an audiometric testing provider who can combine required employee training with the annual audiometric test. One-on-one training at the time of
testing is often more effective than group training. Also, make certain your testing service provides the required baseline comparisons, and that the follow-up reports are understandable.

While audiometric technicians can administer an audiogram, only audiologists, otolayrnologists and physicians may interpret the test results. Often these providers can send out any notifications
as required by the OSHA standard. Research has shown that when employees receive copies of their audiograms or explanations of the results at the time of testing, rates of noise-induced hearing loss
in that workforce decrease.

Hearing Protection
OSHA requires employers to provide employees with a “variety of suitable hearing protectors”—earplugs or earmuffs—whenever noise levels meet or exceed the 85 dBA TWA. Workers with normal hearing are required to wear HPDs when exposure levels reach 90 dBA, while workers
with an identified impairment (a Standard Threshold Shift or STS) must wear HPDs when noise exposure reaches 85 dBA.

While OSHA does not define the term “variety,” it is a good practice to provide a robust selection of HPDs. Everyone’s ears are different, and one earplug or earmuff style may not be comfortable for an
entire workforce. A wide variety of HPDs are available to meet specific applications and/or worker preferences, ranging from earplugs packaged in paper bags for process industries to banded
earplugs that can be inserted quickly during intermittent noise to dielectric and cap-mounted earmuffs.

Offer workers several different styles, including single- and multiple-use earplugs, as well as earmuffs. Also, include a group of workers from different areas in the selection process to improve worker buy-in and compliance. Here are some other thoughts:
• Make hearing protectors accessible. Compliance begins with access; if workers cannot easily obtain a pair of earplugs or earmuffs on the jobsite, they will most likely go without. Simple actions, such as
placing single-use earplug dispensers by main entrances to the jobsite, by the time clock, in the cafeteria or locker room, or keeping earmuffs at a supervisor’s workstation, make access to HPDs more convenient and encourage compliance. Also, keep purchasing agents in the loop to ensure
an adequate supply. If HPDs aren’t available, they can’t be worn.
• Praise workers who always wear their HPDs. Workers who are publicly recognized are more likely to wear their earplugs or earmuffs—and wear them properly—than those chastised for improper
use.
• Encourage workers to take extra earplugs home. Noise-induced hearing loss is not solely a workplace issue: it can also happen off the job. Many workers use power tools, attend loud rock concerts or sporting events, or participate in shooting sports—all opportunities for exposure to
hazardous noise levels. Prevention is the key, on the job and off.
• Set a good example. Include all levels of management in the audiometric testing program and make sure managers/supervisors are pro-active in wearing protection, even if they are only running out to
the shop for a few minutes. When employees see the higher-ups taking their hearing seriously, it sends a positive message throughout the workforce.

Training
As noted above, research has confirmed that one-on-one training is more effective than group training. After all, there is no better time to motivate workers to use hearing protection than immediately after their audiometric test, and the subsequent explanation of results. Mobile audiometric services
often request that workers bring their hearing protectors at the time of testing, so that an individual fit check can be performed.

Training must include information on the effects of noise exposure; the use, selection and fitting of hearing protectors; and audiometric testing procedures. Audiologists, audiometric technicians, occupational hearing conservationists (OHC) or even videos are good resources to perform
this training, but it is the safety officer’s responsibility to see that training occurs in a timely manner.

And although only workers exposed to the Action Level and above are required to participate,
everyone in the organization can benefit from hearing conservation training. While some workers may not be exposed to hazardous noise levels on the job, they may still be at risk elsewhere. Hearing conservation training helps them recognize hazardous noise situations at work and at
home, and encourages them to protect themselves appropriately.

There are a number of resources available that can be utilized for training. Ideally, a training program will include motivational materials to help make the case that workers are susceptible to noise damage, demonstrate the future risk of hearing loss, and encourage workers to wear hearing protectors.

In addition to formal training, a good idea is to hang motivational and informational posters in common areas or near hearing protection sources. These can include fitting instructions,
noise thermometers and posters visually demonstrating the effects of NIHL. Many HPD manufacturers offer such posters for free, and they can provide additional reinforcement on the importance of hearing protection and conservation.

Recordkeeping
No self-respecting governmental regulation would fail to require adequate recordkeeping, and CFR 29 1919.95 is no exception. But it also makes good sense: without accurate records, you have no way
of assessing progress or rectifying problems.

Thus, accurate records must be kept of noise exposure levels and of all audiometric tests. And don’t forget to post a copy of OSHA’s hearing regulations at the worksite. Nearly three-fourths of OSHA’s recordkeeping violations in hearing conservation in the past five years were for simply not having a copy of the hearing conservation standard posted in the workplace. (Posters of the standard are available from several manufacturers, including Howard Leight/Bilsom at 800-430-5490.)

While the language of OSHA’s Occupational Noise Standard may appear convoluted, its dictates are rather straightforward: employers who have work areas with noise levels above 85 dBA must implement a Hearing Conservation Program; workers exposed to those levels must undergo
annual audiograms; and workers must be provided with hearing protectors and trained in their use. And while implementing an OSHA-approved Hearing Conservation Program may appear to be a long,
drawn-out process, it is not as daunting as it seems. FSM Renee S. Bessette, COHC, is a senior Marketing/Communications Specialist with-Bacou-Dalloz Hearing Safety Group. 1 John R. Franks, Mark R. Stephenson, and Carol J. Merry, eds. Preventing Occupational Hearing Loss – A Practical Guide.