Plan for hearing protection
By Mike Reichert
October 15, 2009 | 7:00 pm CDT

While many shops use guards and eye protection, if OSHA and workers' comp figures are any indication, hearing safety is often neglected. In New York State, the Workers' Compensation Board reported that for 2004, the most recent year that figures were available, occupational hearing loss was the second-highest cause of injury claims, second only to wrist injuries (presumably carpal-tunnel syndrome).

Millions at risk

It is estimated that between 1.25 and 7.5 million workers will lose their hearing due to noisy working conditions. Of those, about a third will also develop tinnitus, a ringing in the ears that leads to side effects such as concentration problems, anxiety, sleep difficulties, depression and difficulty in social interactions.

According to NIOSH, construction workers and carpenters in particular are known to develop occupational hearing loss early in their careers, becoming substantially impaired by middle age. NIOSH is working with the construction industry, labor-management organizations and the Department of Defense to test new hearing loss prevention program elements. The program combines Task-Based Noise Exposure Assessment, new training materials and methods, surveillance and a new information management system.

Employees who have hearing loss contribute to the increased risk of other occupational injuries due to misunderstood directions or failure to hear warnings, such as back-up beepers or other alerts. The shame is that occupational hearing loss is preventable.

You need a plan

Employers must have a Hearing Conservation Plan in place to protect the hearing of their employees. OSHA 29 CFR 1910.95 states that an employer "shall administer a continuing, effective hearing conservation program whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level of 85 decibels." That's roughly the noise produced by the operation of one belt sander.

It is a "best practice" to have a Hearing Conservation Plan to avoid workers' compensation claims from injured workers and the resultant increase in insurance costs, and to increase workplace safety. Most importantly, it is a matter of good employee/employer relations to protect the hearing health of your employees.

The purpose of a hearing conservation plan is to identify people who are susceptible and protect them from hearing loss, and to detect small losses before they become big losses.

Developing your plan

Hearing Conservation Plans consist of the following elements;

1. Noise exposure survey and monitoring. This determines the need for controls to be in place, i.e., what areas may be above the Permissible Exposure Level. It identifies those who may be at risk above the Action Level. It provides a protocol for informing employees about their exposure, and it requires monitoring of changes in noise exposure. This must be done whenever there is a change in equipment or production procedures.

2. Hearing protection. Some kind of hearing protection must be made available to those above the action level. It's also required for those above the permissible exposure level and for those above the Action Level when a significant "threshold shift" occurs in their hearing. The hearing protection provided must adequately reduce noise, and it's recommended there be a selection of adequate hearing protection devices available.

3. Audiometric testing. Baseline tests should be done within six months of employment if done in-house, or within 12 months if done outside. (NIOSH recommends within 30 days of employment.) Annual testing should be done for those above the Action Level. Testing determines if changes in hearing are work related. Testing must not be paid for by the employee.

4. Professional supervision. All monitoring and testing should be supervised by appropriate professionals, such as a physician, audiologist, or CAOHC-certified professional.

5. Training. As a shop owner, you need to engage employees in their own hearing loss prevention. Training should be done annually and should cover the effects of noise on hearing, the use and care of hearing protection devices, and the purpose of audiometric testing. This part of your plan should also address the format of training.

6. Record keeping. Noise exposure records must be kept for two years although other standards indicate that medical records should be kept for the employment period plus 30 years. Audiometric tests must be kept for the duration of employment.

Implementing a plan

An initial noise survey must determine whether a workplace meets the specified conditions.The cost of developing and implementing a plan depends on the size of the area to be tested and the number of employees exposed in those areas.

There can be other costs as well, since OSHA has the discretion to fine companies without a plan. Worker's comp claims can drive up insurance rates. And the gift of being able to hear your customers and co-workers, your family and the world around us for years to come is priceless.

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