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Not Dead Yet?

I believe OSHA's Dr. David Michaels settled the question Jan. 19 -- OSHA won't carry out the interpretation of "feasible" engineering or administrative controls it had proposed in October 2010 for reducing workers' exposure to high noise levels. Most comments submitted to the rulemaking docket opposed it, and Michaels cited "possible costs" and the concerns raised about it in the announcement it was being withdrawn.

Nonetheless, the American Industrial Hygiene Association's president, Michael T. Brandt, DrPH, CIH, submitted comments Feb. 11 supporting the proposal, with suggestions for how to carry out the new definition of "feasible."

Michael T. Brandt, DrPH, CIH, AIHA 2010-2011 presidentBrandt's comments list eight reasons why AIHA supports the proposal. Listed first is that it embraces the hierarchy of controls on which occupational safety relies. Also on the list are that the proposal promotes Prevention through Design, reflects a similar level of importance to controlling noise exposure as is given to controlling chemical or biological workplace agents, and addresses a mistaken impression that workers are fully responsible for protecting their own hearing because current OSHA policy allows hearing PPE to be considered the complete solution.

Brandt's suggestions are worth a look. He said feasibility determinations should allow for a long time to be taken to fully implement controls; feasible controls may not always eliminate the need for PPE; OSHA should "work closely with employers to arrive at sensible and equitable enforcement solutions"; OSHA's enforcement actions should take best advantage of engineering controls already shown to be effective; and because some engineering controls might introduce additional hazards, feasibility always should be judged on a case-by-case basis.

Both OSHA and foes of the proposal use BLS data to bolster their positions. The withdrawal announcement cited BLS as the source for nearly 125,000 workers' having suffered significant, permanent hearing loss since 2004, while comments submitted by the U.S. Chamber of Commerce's Randel Johnson and Marc Freedman included two charts depicting BLS data that show hearing loss cases have steadily declined in recent years.

The OSHA withdrawal announcement promised there will be a stakeholder meeting held to hear from workers, employers, and hearing conservation and public health experts on how to prevent hearing loss. Brandt's comments should help; I suggest that everyone who attends it bring along a pair of ear plugs in case the debate gets loud.

Posted by Jerry Laws on Feb 11, 2011


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