Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine how to comply with hearing conservation requirements.
Do you have a hearing conservation program in place to protect your employees from workplace noise exposure? Are you taking the necessary steps to prevent noise-induced hearing loss?
Workplace noise exposures can result in Occupational Safety and Health Administration (OSHA) citations and penalties, and noise-induced hearing loss may result in workers’ compensation costs.
Noise-induced hearing loss is 100% preventable, according to the National Institute of Occupational Safety and Health (NIOSH). The institute’s recommended exposure limit (REL) for occupational noise exposure is 85 A-weighted decibels (dBA) over an eight-hour shift.
You need to provide a hearing loss prevention program with hearing protection for employees who are repeatedly exposed to noise at or above the REL.
However, NIOSH researchers have found that nearly half of workers who are exposed to hazardous occupational noise don’t use hearing protection. Industries in which noise is a well-recognized hazard but with a high prevalence of hearing protection device (HPD) nonuse include agriculture, construction, fishing, forestry, and hunting.
Researchers also found a significant association between current smoking and HPD nonuse.
A special issue last year of the journal Seminars in Hearing highlighted over 50 years of NIOSH’s hearing loss prevention efforts. The institute has conducted and supported basic and applied research into workplace noise exposures and hearing loss risks and has promoted interventions that include hearing conservation and surveillance. NIOSH also has issued recommendations for noise exposure regulation.
NIOSH first issued its “Criteria for a Recommended Standard: Occupational Exposure to Noise” in January 1972 and released an updated criteria document in June 1998.
One of NIOSH’s more recent noise-related efforts is a “Buy Quiet” initiative, part of its Prevention through Design (PtD) program. Adopting and implementing a Buy Quiet program can reduce or eliminate workplace noise exposure. It involves checking equipment specifications for information on noise levels before purchase, asking the manufacturer for noise data it hasn’t already provided, and measuring noise levels before purchase whenever possible.
According to NIOSH, a Buy Quiet program can prevent employee hearing loss and reduce the long-term costs of audiometric testing, personal protective equipment (PPE), and workers’ compensation.
Other recent NIOSH research and intervention efforts include the following:
- The NIOSH Sound Level Meter App, an iOS mobile app for measuring and characterizing occupational noise exposure;
- An online campaign with the World Health Organization (WHO), Cochrane, and other professional associations to expand and improve Wikipedia content related to hearing; and
- The joint NIOSH and OSHA information bulletin Preventing Hearing Loss Caused by Chemical (Ototoxicity) and Noise Exposure.
In addition to noise exposure, hearing loss can be caused by workplace exposure to ototoxic chemicals, such as certain antineoplastic (chemotherapy) drugs, pesticides, and solvents.
Ototoxic chemical exposure can occur in many industries, including chemical manufacturing and petroleum, fabricated metals, plastics, and rubber products. Firefighters and workers in construction, fueling aircraft and vehicles, and pesticide spraying may be exposed to both excessive workplace noise and ototoxic chemicals.
NIOSH recommends addressing ototoxic chemical hazards using the industrial hygiene “hierarchy of controls”: elimination, substitution, engineering controls, administrative controls and work practices, and PPE.
OSHA regulations
OSHA’s occupational noise exposure standard (29 Code of Federal Regulations (CFR) §1910.95) requires a hearing conservation program, exposure monitoring, baseline and annual employee audiometric testing, hearing protection, training, and recordkeeping.
OSHA requires a hearing conservation program when noise exposure is at or above 85 decibels averaged over 8 working hours, or an 8-hour time-weighted average (TWA). Hearing conservation programs are intended to both prevent initial occupational hearing loss and preserve and protect remaining hearing.
OSHA also has construction industry occupational noise exposure and hearing protection standards (§§1926.52 and 1926.101).
You must reduce noise exposure through engineering controls, administrative controls, or HPDs.
OSHA may open health inspections for noise exposure while conducting safety inspections, and employers have been cited for workplace noise violations along with safety violations.
For example, OSHA cited a Sandusky, Ohio, pork processing facility this summer with 43 violations that included workplace noise exposure. The agency proposed penalties totaling $528,441.
Last fall, an El Paso, Texas, machine shop found itself facing $596,221 in OSHA fines for 58 workplace safety and health lapses, including not developing and implementing a noise monitoring program.
In two OSHA inspections of a Palatka, Florida, shipbuilder in 2020 and 2022, agency inspectors found noise exposure violations.
There’s no national emphasis program (NEP) for noise-induced hearing loss or hearing conservation; however, there are regional emphasis programs (REP) in all of OSHA’s regional offices except regions 9 and 10.
On October 1, 2019, OSHA’s Region 1 office in Boston issued a region-wide (Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, and Vermont) local emphasis program (LEP) for noise in the workplace. The LEP targets occupational noise exposure in several manufacturing industries and covers programmed and unprogrammed inspections, as well as referrals. Inspection procedures include a review of injury and illness logs and facility noise monitoring.
Region 2 (New Jersey, New York, Puerto Rico, U.S. Virgin Islands) also issued its noise hazards REP on October 1, 2019. Region 2’s REP targets employers in dozens of manufacturing industries, as well as air transportation. Inspection procedures include facility noise monitoring, interviews, and a review of injury and illness logs or workers’ compensation forms.
On October 1, 2023, OSHA’s Region 3 office in Philadelphia replaced an earlier REP with one for high noise levels. The updated REP applies to all federal OSHA area offices in Delaware, Pennsylvania, and the District of Columbia. (Maryland and Virginia have their own state workplace safety and health programs of law, regulation, outreach, inspection, and enforcement.)
The Region 3 REP targets a dozen manufacturing industries, including plastic and metal products and sawmills. Inspection procedures include reviewing injury and illness logs and the employer’s hearing conservation program. Determining employee noise exposure involves sound level readings, full-shift noise dosimetry, and a review of any third-party noise sampling at the facility.
OSHA’s Region 4 office in Atlanta issued a noise hazards REP on October 1, 2023, replacing a 2019 REP. The REP applies to federal area offices in Alabama, Florida, Georgia, and Mississippi. (Kentucky, North Carolina, South Carolina, and Tennessee have their own state programs.) The Region 4 REP targets employers in boat building, concrete products manufacturing, fabricated metal products, motor vehicle parts manufacturing, planing mills, plastic products manufacturing, poultry slaughtering, sawmills, surgical appliance and supplies manufacturing, and the wood pallets and skids manufacturing industries.
Inspections under the REP are partial health inspections, but the compliance safety and health officer (CSHO) may make a referral for any safety issues observed during the inspection. Procedures include evaluations of workplace noise levels and any engineering controls.
The Region 5 REP issued on June 1, 2021, for exposure to noise hazards in the workplace applies to agency area offices in Ohio and Wisconsin. (Illinois, Indiana, Michigan, and Minnesota all have their own state safety and health programs.)
The REP targets employers in dozens of manufacturing industries. Inspection procedures include a review of the employer’s hearing conservation program and a facility walkaround with sound-level meter readings, including full-shift noise monitoring.
The Region 6 January 1, 2023, REP for high noise in manufacturing applies to workplaces in Arkansas, Louisiana, Oklahoma, and Texas and workplaces in New Mexico under federal OSHA jurisdiction. New Mexico has its own state safety and health program, but federal OSHA retains authority on Native American reservations.
The REP targets employers in the nonmetallic mineral product manufacturing, plastics and rubber products manufacturing, and wood product manufacturing industries. Inspections are focused on the potential for high noise exposures, but CSHOs may evaluate other safety and health hazards, such as exposure to respirable crystalline silica.
The February 28, 2022, Region 7 REP for workplaces with noise hazards applies to federal area offices in Kansas, Missouri, and Nebraska. (Iowa has its own state safety and health program.) The REP targets construction, manufacturing, and transportation employers.
Inspection procedures include a review of injury and illness logs and a workplace walkaround with full-shift noise monitoring.
The February 15, 2022, Region 8 REP for noise-induced hearing loss applies to federal area offices in Colorado, Montana, North Dakota, and South Dakota. (Utah and Wyoming have their own state safety and health programs.) Targeted industries include food, fabricated metal product, primary metal, and wood product manufacturing.
Inspection procedures include a review of injury and illness logs or workers’ compensation paperwork and the safety programs for temporary workers, along with a facility walkaround and full-shift noise monitoring.
Your workplace noise compliance
You need to measure noise levels to understand what your employees’ noise exposures are. If workplace noise levels are at or above the standard’s level, you need to establish a hearing conservation program that conforms to the requirements of OSHA’s occupational noise exposure standard.
Other options for controlling noise exposures might include scheduling work so workers can avoid too much noise, installing barriers to prevent noise from reaching workers, and purchasing quieter equipment.
Putting a NIOSH-recommended “Buy Quiet” program in place could reduce workplace noise levels and net you savings on audiometric testing, protective equipment purchases, and workers’ compensation claims.