If you need Hearing Conservation Program assistance as discussed in this article, call us at 973-366-4660 or email us at info@atlenv.com for details and a free estimate.
Written By: Robert E. Sheriff, MS, CIH, CSP, President
February 3, 2020; Updated September 2021
I Need a Hearing Conservation Program – Noise Dosimetry, Noise Map, Written Hearing Program, and/or Hearing Protection
The organization that is involved with regulating Hearing Conservation and Noise Reduction in the workplace is the Occupational Safety and Health Administration (OSHA).
The specific regulations regarding noise exposure to workers in American Industry are:
General Industry 29CFR1910.95
Construction 29CFR1926.52
The specific noise regulation can be found at the OSHA website www.osha.gov.
First Step:
Get a copy of the OSHA Regulation.
Second Step:
Arrange for a noise dosimetry and noise mapping survey. Since OSHA regulation applies directly to workers, the regulations specify attaching a noise dosimeter to the noise-exposed worker for a shift. Just taking noise measurements with a hand-held sound level meter is not sufficient. Also, a noise map is essential since this identifies the locations where noise exceeds the 85 dB-A Hearing Conservation Level or the 90 dB-A regulatory limit.
Third Step:
If any of the workers full-shift exposure equals 85 dB-A for the entirety of the shift, then a Hearing Conservation Program is required.
At 85 dB-A worker-exposure levels, annual audiometric tests must be given to each employee whose job task equals or exceeds 85 dB-A. Also, hearing protection must be provided by the employer and the employee has the option to wear or not wear the available hearing protection UNLESS the employer decides to make it mandatory. The Hearing Conservation Program also requires employee education. If the worker exposure level is at 90 dB-A for a full shift, hearing protection is mandatory AND efforts must be attempted to engineer the noise -or at least reduce it where that is feasible.
Fourth Step:
A written Hearing Conservation Program must identify what tasks and conditions are included within the Program as well as a provision for audiometric tests. (Note: We do not presently offer audiometric tests but can assist you in finding a local or mobile testing source).
Where worker noise exposure levels equal or exceed 90 dB-A, such tasks have to be identified including a requirement and effort to reduce noise through engineering or administrative controls. The requirement for training of individuals involved in the Hearing Conservation Program must be included in the program. A Plan for noise monitoring when there is any change in equipment or configuration that may affect noise exposure is also required.
Fifth Step:
Conduct regular noise dosimetry surveys when there is a change in equipment or activities that may affect the noise levels. Also, it is recommended to update the noise dosimetry tests every 3 to 5 years even if no changes have occurred in the operations in the facility. (This is not required by OSHA but is highly recommended for the safety of the workers).
Some important things to remember about noise:
- Noise is energy and is cumulative. That means that two 85 dB-A sound-producing machines side-by-side will double the sound energy and increase the noise level to 88 dB-A (but not 170 dB-A) (dB-A noise levels are on a logarithmic scale – 3 dB-A is doubling the energy).
- Hearing protection is the least effective means of reducing worker noise exposure.
- The OSHA scale is set on 5 dB intervals, but the actual doubling exposure level is 3 dB. Many countries use the 3 dB scale for regulatory noise exposure. In short, this means that 85 dB-A levels may not be an adequate protection limit for all workers from potential hearing loss. 88 dB-A should be the limit for mandatory hearing protection as a more satisfactory justified level. Also, your workers’ compensation carrier may ask for a 3 dB-A assessment. (Remember that workers’ compensation insurance carriers pay for hearing loss claims).
- If engineering controls are needed, an Octave Band Analysis is essential. Different frequencies of noise are reduced by different means (damping, isolation, acoustical barriers, etc.) depending upon frequency. This must be supplied by octave band or 1/3 octave band analysis. A normal noise meter or noise dosimeter cannot identify separate frequencies. Thus where noise reduction is considered—or required—Octave Band Analysis is the appropriate step.
For more information contact Atlantic Environmental.
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