Is a Hearing Conservation Program Required?

Hearing Conservation Programs: Focus of the Month

Hearing Conservation Program

The human body is remarkably resilient, recovering from a wide range of injuries with medical intervention.  Unfortunately, our bodies can’t recover from all injuries.  One of those injuries is hearing loss, leading to significant issues for the injured individual on the job and at home.  Employees who are exposed to loud noise at work have a greater risk of hearing loss.  OSHA requires employers to protect employees from hazardous noise by providing hearing protection by implementing feasible controls.  If these do not reduce noise to safe levels, then further action is required, and you may need a hearing conservation program.

When a hearing conservation program is required

There is no quick answer to this question.  According to the standards, a hearing conservation program is required “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) or, equivalently, a dose of fifty percent. For purposes of the hearing conservation program, employee noise exposures shall be computed in accordance with appendix A and Table G-16a, and without regard to any attenuation provided by the use of personal protective equipment”  (1910.95(c)(1)).  In short, there are calculations involved based on data obtained by monitoring and measuring employee exposures.  It’s also important to note that these calculations do not factor in PPE.

The only way to get this data is to perform noise monitoring based on a protocol that accounts for common employee exposures.  In places where workers tend to work in one room or location, then area monitoring is usually sufficient.  However, for jobs where employees move frequently and are exposed to greater variations in noise, then representative personal sampling may be necessary.

Protocols and calculations are best left to certified industrial hygienists, and monitoring should be conducted by personnel experience with industrial hygiene sampling and data collection.  Inaccurate or misrepresented data risks your employees’ safety, and exposes the company to citations from OSHA.

Even with all that said, it is difficult to know when monitoring should be performed.  If employees need to shout to be heard by someone standing a few feet away, or they express concerns about having trouble hearing, the noise being too loud, or developing a ringing in their ears (tinnitus), noise monitoring is recommended.  You’ll have accurate data to determine if employee noise exposures are at levels that require a hearing conservation program.

Monitoring is the only way to know for certain.

Hearing conservation program requirements

If monitoring data indicates that you need a hearing conservation program, there are additional steps that you need to take to protect your employees and comply with OSHA regulations.  The following are brief descriptions of an employer’s responsibilities for a hearing conservation program, and are not meant to be a comprehensive listing of said responsibilities.

All employees exposed to decibel levels requiring the hearing conservation program must be notified of the results of the monitoring.  They must also be allowed to observe the noise measurements that are conducted.

Audiometric Testing Program

An audiometric testing program must be made available to all employees affected by the hearing conservation program, at no cost to the employees. Testing must be performed by a licensed or certified audiologist, otolaryngologist, or other physician.

  • Baseline audiograms must be performed within 6 months of an employee’s first exposure to noise
  • Annual audiograms must be performed for each exposed employee, and evaluated against the baseline audiogram

Employees must be notified if the audiogram demonstrates a standard threshold shift.  An employee can be retested within 30 days, and the new test will be considered the annual audiogram.

In addition to noise monitoring and audiometric testing, a variety of suitable hearing protectors from which employees can choose must be provided.  They must be trained to use and care for the hearing protectors, and the employer is responsible for ensuring that the hearing protectors fit properly.  Supervisors must also ensure that employees correctly use their hearing protectors.

Employees in the hearing conservation program must be retrained annually.

Employers also have a responsibility to retain their records.  Noise exposure measurements must be kept for two years.  An employee’s audiometric test records must be kept for the duration of employment.

Do not be caught unprepared

Occupational hearing loss is a serious concern.  OSHA estimates that $242 million is spent annually on workers’ compensation for hearing loss disability.  Perform the tests, develop the program, and protect your employees’ hearing.

For more information on noise levels, hearing damage, and hearing protection, see our previous article “Noise and the Importance of Hearing Protection in the Workplace”.d