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Regulatory Alert
OSHA
to Include Hearing Loss Column
on Recordkeeping Form in 2004
In conjunction with new recording criteria currently in effect, the Occupational Safety and Health Administration (OSHA) will require employers to address hearing loss on its Recordkeeping form beginning 2004. The newly added column will better enable OSHA to gather statistics on workplace hearing loss, pinpoint the location of injuries, and emphasize loss prevention programs according to OSHA Administrator John Henshaw.
The new criteria, detailed under OSHA Standard 29 CFR 1904.10, requires employers to record 10-decibel shifts from the employee's baseline hearing test when it is combined with a hearing level of 25 decibels.
In a related issue, OSHA is planning to suspend three provisions dealing with Musculoskeletal disorders (or MSDs) for a period of one year. These provisions are the rule's definition of MSDs, consideration of MSDs as privacy concern cases, and the requirement to check a MSD column on the OSHA Log. This delay does not relieve the employer from the responsibility of recording such injuries or implementing programs to prevent them. Instead, it alleviates employers from having to utilize a MSD definition to categorize injuries on the 2003 OSHA Log. For now, they would check either the column for "injury" or "all other illness" as appropriate to the situation.
OSHA also made clear three concerns relating to workplace hearing loss as related to the final rule: audiometric tests for shipbuilding industry workers; calculation of a standard threshold shift for establishing recordable hearing loss; and how OSHA plans to react to the anticipated increase in the number of recorded incidents as a result of the new Recordkeeping definitions stipulations.
Details on the delay of these provisions as well as clarification on recording workplace hearing loss are scheduled to be reported in the December 19 Federal Register.
Other OSHA Noise Related Standards
Hearing loss is one of the leading causes of occupational illness in the American workforce. In addition to the new Recordkeeping standard, OSHA addresses this workplace hazard in the construction industry in these other standards as well:
- 29 CFR 1926.52 (Occupational Noise Exposure)
- 29 CFR 1926.101 (Hearing Protection)
29 CFR 1926.52 includes Table D-2 that sets permissible exposure to noise based on the duration of exposure. For example, unprotected workers cannot be exposed to levels above 90 decibels over an eight-hour period. The permitted level of exposure depends on the duration. For example, the permitted exposure rises to 92 decibels for a six-hour period. Measurements used to determine whether levels permitted by Table D-2 have been exceeded must be performed using instrumentation set on an A-weighted scale set on slow response.
Where noise exposures exceed levels permitted in Table D-2, 29 CFR 1926.52 requires that feasible engineering and administrative controls be used, such as enclosing noise sources or rotating workers through high-noise tasks. Hearing protection must be used if, after implementing feasible engineering and administrative controls, they are still needed to reduce worker exposure below levels specified in Table D-2.
Where levels in Table D-2 are exceeded, a hearing conservation program must be administered. 29 CFR 1926.52 does not describe what must be included in such a program. However, the General Industry Occupational Noise Standard (29 CFR 1910.95), while not enforceable on construction projects, provides guidance on what OSHA would expect to see in a hearing conservation program. According to 29 CFR 1910.95, a hearing conservation program must include the following elements:
- Monitoring to evaluate noise exposures
- Employee notification of noise exposures exceeding allowable limits
- Observation of monitoring by employees or their representatives
- Audiometric testing of employees at the start of employment and periodically (e.g., annually) to determine whether occupational noise exposure are leading to hearing loss
- Training workers in the hazards of noise, proper use of hearing protection, and the purpose of audiometric testing
- Maintaining records of audiometric testing and noise monitoring
29 CFR 1926.101 requires that hearing protection inserted into the ears be fitted or determined by individually by competent individuals. 29 CFR 1926.101 also prohibits the use of plain cotton as a hearing-protection device.
Given the levels of noise exposure typically found on industrial painting projects (e.g., abrasive blasting noise levels usually exceed 100 decibels), the OSHA construction noise standards typically apply to any project where an existing coatings system is removed by abrasive blasting or power tool cleaning. With the change in OSHA standards for Recordkeeping, complying with these standards is not only important to prevent hearing loss in workers and OSHA citations, but also reduce frequency and severity of occupational illnesses recorded on OSHA injury and illness records.
For more information on this and other regulatory concerns, visit www.osha.gov.
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