Sound Source: OSHA Hearing Conservation Violations

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Sound Source: OSHA Hearing Conservation Violations
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What parts of OSHA’s Hearing Conservation regulations are cited most frequently in compliance inspections?

With the assistance of OSHA’s Office of Information and Technology, we analyzed OSHA compliance actions for the five-year period from 2000-2004. During this period, more than 10,000 violations were cited in reference to OSHA’s Hearing Conservation standard (§1910.95), with accompanying initial penalties over $7.5 million*.

For our analysis, each paragraph of the OSHA Hearing Conservation regulation was grouped into one of six subject areas: general hearing conservation, noise monitoring, audiometric testing, hearing protection, employee training and recordkeeping. The violations under each area were totaled, and the most commonly cited sections are described below:

Violation

Explanation

Recommended Solution

Employee Training

(1,351 violations)

OSHA’s requirement for an annual training program in hearing conservation is described in only three paragraphs, yet it was cited 60% of the time as a serious violation.

Workers exposed to 85 dBA TWA must receive annual training in the effects of noise, the proper use and care of hearing protectors, and the purpose and procedures of audiometric testing.

The employer can choose the method of training: classroom, one-on-one, brochure, video, etc.

Hearing Protectors

(1,168 violations)

Although cited less frequently than other paragraphs, the lack of appropriate hearing protection was deemed to be a serious violation more often (72%) than any other provision in the regulation.

The specific subsections most frequently cited by OSHA were requirements for the employer to provide “a variety of suitable hearing protectors” (231), provision of hearing protectors to newly-hired employees who have not yet obtained their baseline audiogram (159), and the requirement for the employer to “ensure proper initial fitting and supervise the correct use of all hearing protectors” (114).

OSHA cites employers who do not select hearing protectors that provide adequate noise reduction for exposed workers. OSHA advises subtracting a 7 dBA correction from the published Noise Reduction Rating (NRR) of a hearing protector, and then subtracting that difference from the measured A-weighted noise levels to estimate the protected noise exposure level (must be 90 dBA or below for OSHA compliance).

 Provide at least two types of earplugs and at least one type of earmuff to your noise exposed workforce.

Ensure proper usage by individually checking the fit of each wearer. Take advantage of fitting posters available from Howard Leight.

Recordkeeping

(870 violations)

Employers who don’t believe the rumors of OSHA citations for bulletin board deficiencies should take note: nearly three-fourths (622) of the recordkeeping violations were for simply not having a copy of the hearing conservation standard posted in the workplace.

Other common citations included lack of employee noise exposure and audiometric records.

Maintain records of all noise monitoring and employee exposure measurements, as well as audiometric test results.

Copies of OSHA’s Hearing Conservation Amendment, suitable for posting,

Based upon this analysis of OSHA citations for hearing conservation from 2000-2004, the simple message to employers appears quite evident: Do the basics! OSHA compliance actions are not focused on technicalities or peculiarities of the hearing conservation regulations. Instead, the best hearing protection for a noise-exposed worker (and the best defense against OSHA citations) is simply in implementing the basic components of a Hearing Conservation Program: noise monitoring, audiometric testing, suitable hearing protection, employee training, and recordkeeping.

Footnote:

*Report: OSHA Federal/State Standards Cited by Standard (1910.095), July 2005, OSHA Office of Management Data Systems, Washington D.C