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I Need a Hearing Conservation Program – What Should I Do?

If you need Hearing Conservation Program assistance as discussed in this article, call us at 1-800-344-4414 or email us at info@atlenv.com for details and a free estimate.

Written By: Robert E. Sheriff, MS, CIH, CSP, President

September 30, 2018

The regulation that involves Hearing Conservation and Noise Reduction is the Occupational Safety and Health Administration (OSHA) under the Health Education and Welfare Department (HEW) of the Federal Government in the U.S.

The specific regulations covering 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. Also a noise map is essential since this identifies the locations where noise exceeds the 85 dBA Hearing Conservation Level or the 90 dBA regulatory limit.

Third Step:

If any workers full shift exposure equals 85 dBA for a full shift, then a Hearing Conservation Program is required.

At 85 dBA worker exposure level, annual audiometric tests have to be given to each employee whose job task equals or exceeds 85 dBA. 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 Program also requires employee education. At 90 dBA, worker exposure level for a full shift, hearing protection is mandatory AND efforts must be attempted to engineer out-or reduce-the noise.

Fourth Step:

Written Hearing Conservation Program must identify what tasks and conditions require inclusion of in the Hearing Conservation Program. It must also include a provision for audiometric tests.

Where worker noise exposure levels equal or exceed 90 dBA, such tasks have to be identified including a requirement to noise reduction efforts 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:

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.

Some important things to remember about noise:

  1. Noise is energy and is cumulative. That means that two 85 dBA sound producing machines side-by-side will double the sound energy and increase the noise level to 88 dBA (not 170 dBA) (dBA noise levels are on a logarithmic scale – 3 dBA is doubling the energy.
  2. Hearing protection is the least effective means of reducing worker noise exposure.
  3. The OSHA scale is set on 5 dB intervals, but the actual doubling exposure level is actually 3 dB. Many countries use the 3dB scale for regulatory noise exposure. In short, this means that 85 dBA may not be adequate protection of all workers potential for hearing loss and 88 dBA should be the limit for mandatory hearing protection as a more satisfactory justified level. Your workers’ compensation carrier may ask for a 3dBA assessment. (Remember that workers’ compensation insurance carriers pay for hearing loss claims).
  4. 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 which must be supplied by octave band or 1/3 octave band analysis. A normal noise meter or noise dosimeter cannot identify separate frequencies.

Our primary service areas for Hearing Conservation Programs are: NJ, NY, NYC, PA, CT, DE, (Boston) MA, RI, Wash DC, WI, MD, MI, (Chicago) IL, VA, IN, (Atlanta) GA, AL, NC, SC, TN, (Dallas, Fort Worth) TX, OK, DC, AR, we can service most other areas of the U.S. but with some added travel charges.

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