Westminster, Colo – Responding to OSHA’s withdrawal of workplace hearing loss prevention cost guidelines, the National Hearing Conservation Association (NHCA) has sent a letter to OSHA (the United States Occupational Safety and Health Administration) requesting that it review its “feasibility” interpretation.
In January 2011, OSHA withdrew its proposal to interpret guidelines emphasizing the use of engineering and administrative controls to mitigate occupational noise. In its original proposal, OSHA identified the need to implement such noise controls when “economically and technologically feasible” in work environments that expose employees above the permissible exposure limit.
"NHCA is committed to minimizing risk of noise-induced hearing loss in the workplace," said Dr. Tim Rink, NHCA president, in a press statement.
In its letter to OSHA, NHCA highlighted some advantages of noise control, including: the reduction of potential user error, negligence, or deliberate non-compliance regarding the use of hearing protectors such as earplugs or earmuffs; improved hazard awareness and perception of safety alerts and warnings; reduction of the risk of life-altering hearing loss, tinnitus, and other effects of excessive noise exposure; and the cost effectiveness of noise controls as a long-term strategy for addressing the hazard of excessive workplace noise.
In its letter, NHCA says that OSHA has not updated its loss prevention regulations since 1981.
The letter continues, “While the rest of the industrialized world moves forward to more effective protective policies for their workers, we continue with a 30-year old standard which we have known for decades to be inadequate in preventing hearing loss. This comparatively less stringent standard has been reduced further in its efficacy by the implementation of a policy to disregard the requirement for noise controls until 10 decibels (dB) beyond the stated permissible exposure limit (or 10 times the sound energy and subsequent potential to do harm), and only then when noise controls are proven to be economically more feasible than a hearing conservation program.”
The letter further states that OSHA’s failure to enforce hearing conservation requirement unless 8-hour time-weighted average exposures reach 100 dBA is perpetuating the misconception that exposures up to 100 dBA is not hazardous.
The organization recognizes that economic feasibility concerns are valid, but says that recent assessments of the cost of hearing conservation programs versus noise controls indicate that noise controls may provide return on investment within a matter of years.
NHCA further recommends that the “feasibility” of implementing hearing prevention programs and noise controls should be defined in terms of both economic impact and technological capability if it is felt that implementation of engineering controls would seriously impair a company’s economic viability.
The full NHCA’s letter to OSHA can be downloaded here.
