Best Practices in Implementing a Successful

Hearing Conservation ProgramOSHA 29 CFR 1910.95

Though the language of OSHA’s Occupational Noise Standard (29 CFR 1910.95)may appear convoluted, its dictates are rather straightforward: employers whohave work areas with noise levels above 85 dBA TWA (Time Weighted Average)must implement a Hearing Conservation Program. Workers exposed to thoselevels must undergo annual audiograms; hearing protectors must be madeavailable when noise reaches 85 dBA and are required to be worn at 90 dBA.And while implementing an OSHA-approved Hearing Conservation Programmay appear complicated, it is not as daunting as it seems. There are a numberof “best practices” safety managers can employ that not only help ensurecompliance with regulations, but also promote positive employee hearing safety.

Table of ContentsNoise Monitoring 1

Audiometry 2

Hearing Protectors 3

Training 4

Recordkeeping 5

OSHA 29 CFR 1910.95 / 1

OSHA Requirement Best Practices

� Area Noise Sampling – Utilizing a sound level meter, take a generalmeasurement of each section of yourfacility. These measurements can bedocumented in a noise map or atable showing the exposures in eacharea. This method is most accuratewhen noise levels are fairly steady.

� Personal Noise Sampling –Also called dosimetry, workers don a device with a microphone mountednear the ear. The dosimeter records a worker’s complete noise exposureover an extended time, and determinesthe Time-Weighted Average. Not allemployees are required to participatein dosimetry, though a representationof employees from every area andshift should be included. This methodis most accurate when noise levelsare intermittent or fluctuating.

� Document Changing Conditions –Noise levels should be re-monitoredand updated whenever a change inequipment or work processes affectsnoise exposures.

� Notify Employees – As employeesmust be notified of any changes innoise level, post a noise map of yourfacility in common areas, such asyour break room or safety stations.

� Track Worker Exposure –Document each employee’s TWAnoise exposure in his/her safety profileor personnel file. This can help anaudiologist better understand theemployee’s audiogram.

NOISE MONITORINGOSHA requires employers to perform noise monitoring when employeenoise exposure “may equal or exceed an 8-hour time-weighted average(TWA) of 85 dB.” OSHA defines two methods for monitoring noise levels.

/ 2 Audiometry

� Baseline Audiogram – All employeesexposed to 85 dBA TWA must undergoa baseline audiogram within six monthsof first exposure to determine currenthearing levels. This includes bothnew hires and existing employees.

� Audiogram Evaluation – Problemaudiograms must be reviewed by an audiologist, otolaryngologist or physician.

� Standard Threshold Shift (STS) –If the annual audiogram demonstratesa shift in hearing of 10 dB average or more at 2000, 3000 and 4000 Hz in either ear compared to baseline,the employee must be notified inwriting within 21 days. If the loss isdetermined to be occupational, theemployer must evaluate the employee’scurrent hearing protectors, andretrain the employee on use and fit.

� Retain Records – Noise damagecan only be determined whenaudiograms are compared serially.Make certain your testing serviceprovides the required comparison to baseline, with understandable follow-up reports.

� Review Results With Employees –Research has documented a positiveimpact on employees who receivedetailed feedback regarding audio -metric results immediately aftertesting. This helps the employeesunderstand the effectiveness of their hearing protection device (HPD)fit and provides another opportunityto promote a healthy hearing culture.

AUDIOMETRYAnnual audiometric testing (hearing tests) must be made available to allemployees exposed to 85 dBA TWA. Testing must be performed by aprofessional or qualified technician.

OSHA Requirement Best Practices

OSHA 29 CFR 1910.95 / 3

HEARING PROTECTORSOSHA mandates that “a variety of suitable hearing protectors” – earplugsand/or earmuffs – be made available at no cost to workers exposed to an“8-hour time-weighted noise level of 85 dB,” known as the “Action Level.”

� Action Level 85 dBA – If yourfacility has an area with a noise level of 85 dBA or above, hearingprotectors must be made available at no cost to your employees.

� Permissible Exposure Limit 90dBA – Hearing protectors arerequired to be worn by employeeswho work in areas where noise levels exceed 90 dBA TWA.

� Standard Threshold Shift (STS) –Employees who have a significantshift in hearing (STS) shall beretrained and refitted with hearingprotectors, and are required to use them for noise exposures above the 85 dB Action Level.

� New Employees – New employeesmust wear hearing protectors prior to taking their baseline audiogram.

� Offer aTrueVariety – While the OSHAregulation does not state a firm quantity,as a best practices, employers shouldoffer at least one style of single-use,multiple-use and banded earplugs,and an earmuff. Everyone’s ears aredifferent, and one earplug or earmuffstyle may not be comfortable for anentire workforce.

� Verify the Training – Effective fit of hearing protectors can be measuredin the field. Verify the protection youremployees obtain, and recheck theirPersonal Attenuation Rating (PAR) at least annually to ensure properprotection.

� Make Hearing ProtectorsAccessible – One of the mostfrequent complaints by workersrequired to wear HPD is “I’d wearthem if we had them.” Compliancebegins with access. Simple actions,such as placing single-use earplugdispensers by the time clock, in thecafeteria, in the locker room or at asupervisor’s station, facilitate workerprotection and compliance. Also,keep Purchasing in the loop toensure an adequate supply.

� Set a Positive Safety Culture –Simple acts — such as praising workerswho wear their HPDs properly — makea difference. Workers who are publiclyrecognized on the job are more likelyto wear their earplugs/earmuffs andset a standard for other employees.

OSHA Requirement Best Practices

/ 4 Training

TRAININGEmployers must provide annual hearing conservation training to all workersexposed to noise levels at or above the Action Level (85 dBA TWA).

� Effects of Noise Exposure –Annual training must include theeffects of noise on hearing.

� Use, Selection and Fitting ofHPDs – All employees in theHearing Conservation Program mustbe educated on different types ofearplugs and earmuffs, how to selectthe most appropriate protector andhow to properly fit that HPD.

� Audiometric Testing Procedure –Annual training shall also include an explanation of the purpose of audiometric testing, and anexplanation of the test procedures.

� Acceptable Materials – Group andone-on-one presentations, videos,brochures, computerized trainingmodules and outside speakers areacceptable Hearing ConservationProgram training aids.

� One-on-One Training – Researchhas documented that one-on-onetraining, coupled with a worker’sannual audiogram, have a positiveimpact and are more effective thangroup training. According to onestudy, workers who demonstrated apoor fit with their earplugs showed a 14 dB improvement in protectionafter brief one-on-one training.

� Provide Ongoing Education –Hang motivational and informationalposters in common areas or nearhearing protection sources. Thesecan include fitting instructions, noisethermometers and posters visuallyshowing the effects of hearing loss.Howard Leight offers severalmotivational posters in both Englishand Spanish forHearing Conservation.

OSHA Requirement Best Practices

OSHA 29 CFR 1910.95 / 5

RECORDKEEPINGEmployers must retain all employee records, including exposuremeasurements and audiometric tests.

� Exposure Measurements – Area andpersonal sound measurements mustbe kept on file for at least two years.

� Audiometric Tests – Employersmust maintain audiometric recordsof their employees for the duration of their employment.

� OSHA Form 300 – As of January 1,2004, employers must record allemployees who 1) demonstrate aStandard Threshold Shift (STS) inhearing in one or both ears and 2)demonstrate average hearing levelsover 25 dB above audiometric zero(also averaged at 2000, 3000, and4000 Hz) in the same ear(s) as theSTS. The OSHA Form 300 can befound at:http://www.osha.gov/recordkeeping/new-osha300form1-1-04.pdf.

� Access to Records – All recordsmay be accessed upon request by“employees, former employees,representatives designated by theindividual employee,” and by OSHArepresentatives.

� Transfer of Records – If theemployer closes business or isacquired by a new organization, all records must be transferred to the subsequent organization for the required periods of time.

� Track Employee Exposures –Noise damage can only be determinedwhen audiograms are comparedserially. Make certain your testingservice provides understandablefollow-up reports.

� Post OSHA Hearing ConservationAmendment – Employers arerequired to post a copy of OSHA 29 CFR 1910.95 in a visible locationwithin a facility. A PDF of theamendment is available atwww.howardleight.com under “Best Practices” menu. Posters are available through SperianProtection Customer Care or Territory Sales Manager.

OSHA Requirement Best Practices

HLI. 502 3/08 © 2008 Sperian Hearing Protection, LLC

Sperian Hearing Protection, LLC7828 Waterville Road, San Diego, CA 92154

ph. 800/430-5490 fax 401/232-3110www.howardleight.com

From our beginnings as a one-man operation more than 30 years ago, Howard Leight®

has grown into one of the largest global manufacturers of hearing protection in theindustrial market and the recognized innovator in protection and people-oriented fit.Utilizing Bilsom® Technology, Howard Leight earmuffs raise the bar on innovative design,performance and comfort, with features like padded wire headbands, unique soundmanagement technologies and multi-level attenuation options. Howard Leight is abrand of Sperian Protection, a world leader in personal protection equipment. Visit usonline at www.howardleight.com.

FOR MORE INFORMATION

• OSHA Hearing Conservation Amendment 29 CFR 1910.95 – www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9735

• National Institute of Occupational Safety & Health (NIOSH) Hearing Loss PreventionProgram – www.cdc.gov/niosh/topics/noise

• Council for the Accreditation in Occupational Hearing Conservation (CAOHC) – www.caohc.org

• National Hearing Conservation Association (NHCA) – www.hearingconservation.org