October 27, 2021

The Basics of an OSHA Compliant Hearing Conservation Program

worker cutting metal with sparks flying

When we think of hearing damage, most of us think of things like loud music, standing too close to the stage speakers, or fireworks. But one of the biggest sources of hearing damage is occupational.

OSHA reports nearly 22 million workers “are exposed to potentially damaging noise at work each year.” 

Whether you work in construction or manufacturing, on a tarmac or shop, in a club or stadium, hearing loss in the workplace is completely preventable. 

For Workers

If you’re on the shop floor and find yourself raising your voice in order to speak to someone an arm’s length, or three feet, away, you need a hearing program. Other signs include ringing ears, a humming in your ears after you go home, or experiencing any kind of temporary hearing loss. If you’re questioning whether or not you’re experiencing hearing damage, or are even just curious about what the decibel levels might be, the National Institute for Occupational Safety and Health (NIOSH) has an app  available to download onto your phone that allows you to test the sound levels in your workplace, providing immediate data to allow you to take to your foreman or manager to ensure that any occupational noise exposure will be addressed before it results in hearing loss. 

worker on site

You have the right to a safe workplace. OSHA requires a company to implement a hearing conservation program when the noise exposure level is at or above 85 decibels averaged over 8 working hours, or an 8 hour weighted time average. If you have suspicions that might be the case, or the NIOSH app shows this, it’s important to make sure management is aware. 

Exposure to loud noises may not feel like it is damaging your hearing, but exposure will kill the nerve endings in your inner ear--a process that can be completely painless but result in irreversible damage, and will impact your relationships and mental health

For Managers

One of the primary responsibilities of a plant or workplace safety manager is to protect the wellbeing of your employees and ensure compliance with OSHA. The goal of these programs is to ensure that your workers do not experience occupational hearing loss, to “preserve and protect” what hearing remains, to provide the right equipment and training in order to accomplish those goals. A workplace with a robust safety culture has lower employee absenteeism and higher levels of productivity. 

If possible, the noise source should be isolated and worker exposure limited. For workplaces with machinery or equipment, incorporating safety measures can be done through engineering controls, administrative controls, hearing protection devices or a combination of some or all three. 

Program Requirements

Implementing a hearing conservation program is a fairly straightforward process. Once the initial testing has been completed, and it’s determined that a safety program must incorporate hearing conservation, there are a few steps to ensure employees ongoing safety. 

Annual testing to measure noise exposure is a required component of any program. Typically, a contractor will come out and set up devices to measure the decibel levels throughout the course of a normal workday. They frequently do this with a small attachment to employees' collars or shirts, as this gives the best data as to what employees are actually experiencing. This data is then collected and delivered into a report, showing you the areas where hearing controls are required and the noise levels are unsafe. 

In addition to noise level testing, employers are required to provide annual hearing exams. These hearing tests are quick and easy. You can have an audiologist visit the site, test each employee in a short session, and provide records for the safety manager’s documentation, as well as documentation to each employee if any follow-up care is needed. Any shifts in hearing thresholds for employees will require a review of the current safety plan. 

Once any possible engineering or administrative controls are implemented, proper individual hearing protection measures will need to be installed. In order to ensure that employees are comfortable and find it easy to comply with the safety standards of wearing hearing protection, you should work with your employees to choose a comfortable, long wearing earplug with filters that lower harmful decibels while still providing the clarity of hearing for employees to be able to communicate easily. If the hearing protection you choose inhibits employees' abilities to talk, they will be pulling out their earplugs all day long and forgetting to put them back in. Choosing the right earplugs and having them fit tested means you employees are much more likely to wear them, communication will be uninhibited and you will lower your risk of a recordable incident or any changes in employees hearing thresholds. 

With the implementation of new controls and hearing protection requirements, you will need regular training. Routine training is part of your safety culture and records, making sure that your employees understand the risks and signs of hearing damage, how to wear and care for their hearing protection properly. 

There is no job more important than your health and hearing. The impacts of hearing damage can be permanent loss or painful ringing (tinnitus). Beyond the physical injuries, the psychological impacts of losing hearing health due to occupational injury can be devastating to an employee's life. Injuries of any kind--hearing included--are expensive for the company and can be life-altering for the employee. With proper OSHA compliance, both the company and the individual are protected and safe.

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