While the language of OSHA's Occupational Noise Standard (CFR 29 1910.95) may appear convoluted, its dictates are rather straightforward, according to Renee Bessette, a Certified Occupational Hearing Conservationist and Marketing Manager, Sperian Hearing Protection, LLC. "Implementing an OSHA-approved Hearing Conservation Program is not as daunting as it seems," said Bessette in recent remarks. "There are a number of 'best practices' that safety program managers can employ that not only help ensure compliance with regulations, but also promote positive employee attitudes towards hearing safety."
"The first of these is to know what you're dealing with," said Bessette. "While area and personal sound level monitoring is required by OSHA, it's also important to document changing conditions and to notify employees whenever new equipment, processes or other changes affect noise hazards." Bessette recommends posting "noise maps" in readily accessible areas to let workers know where hearing protection devices (HPDs) are required. Bessette also suggests tracking occupational noise exposure histories in employee personnel records to help audiologists interpret employee audiograms.
In selecting hearing protectors, OSHA mandates that a "variety of suitable hearing protectors" be provided. Quite often a safety manager will interpret this to mean offering one earplug, in corded and uncorded styles. However, Bessette suggests offering a wider variety. "Everyone's ears are different," she said, "and one earplug or earmuff style may not be comfortable for the entire workforce. There is a wide range of HPDs available, designed for specific applications and/or worker preference, ranging from high-visibility, ultraslim and cap-mounted earmuffs to earplugs that adapt to the unique contours of each ear canal and banded earplugs that can be quickly inserted during intermittent noise. Employers should offer workers several different styles, including single- and multiple-use earplugs, as well as earmuffs. Bessette added, "Safety managers should always include a group of workers from different areas of their facility in the selection process to improve worker acceptance and compliance."
Workers must also be trained in identifying hazardous noise; methods to prevent noise exposure; and proper HPD use, as protection can be dangerously reduced with improper insertion. "Praise workers who always wear their HPDs," said Bessette, "and encourage workers to take extra earplugs home. Many workers use power tools, attend loud rock concerts or sporting events, or participate in shooting sports--all opportunities for exposure to hazardous noise levels. Prevention is the key, on the job and off."
But the best practice, Bessette concluded, is to make hearing conservation a team effort. "Assemble a cross-departmental team for your Hearing Conservation Program to enhance support, provide input, and help implementation in a variety of areas," she said. In addition to Safety Management, include a committee of workers in the HC program, and additional staff from Human Resources, Purchasing, Engineering, and of course, the company audiologist to make sure all aspects of the program are in place. "And get buy-in from senior management," she said. "Top down compliance has a positive influence on the overall program," said Bessette. "It sends a clear signal to the entire company that management cares about everyone's hearing safety."