Recording Hearing Loss

The new hearing loss column on Form 300 takes effect Jan. 1, 2004

OSHA's 29 CFR 1904 took effect in January 2003. It make hearing loss is recordable if it meets these criteria:

  • Standard threshold shift (STS) is detected. STS is the change in hearing described in 29 CFR 1910.95, the federal Hearing Conservation Amendment (HCA) to the Occupational Noise Exposure Standard. It is an average 10 decibel (dB) change in hearing ability from the baseline hearing test, or revised baseline as described in the HCA, at 2000, 3000, and 4000 hertz (Hz) test frequencies. STS determination is subject to all of the allowances and requirements of the HCA, including persistence, age correction, and work-relatedness. It is important to note that nothing in the new recordkeeping rule supersedes the HCA. All requirements of 29 CFR 1910.95 remain in place, including STS follow-up, evaluation of hearing protection sufficiency, retraining, and other aspects.
  • The STS results in hearing impairment. This step simply requires determining whether the average hearing threshold levels (not shift, but absolute hearing ability) determined by the last hearing test are 25 dB or greater at the STS frequencies. This is called the "25 dB fence" and is the level at which hearing impairment starts. Determine hearing thresholds at 2000, 3000, and 4000 Hz from the audiogram that confirmed the STS; sum; and divide by three. If the result is 25 or greater, the hearing loss is recordable.

OSHA has a few new wrinkles rolled into the requirement for recording hearing loss:

  • Preemption--OSHA requires all states to follow the recordkeeping criteria defined in 29 CFR 1904. While this will provide a level playing field and will permit apples-to-apples comparisons of hearing loss prevalence across the country, it is actually a step backward in worker protection in some cases. Michigan, North Carolina, South Carolina, and Tennessee currently require employers to report STS without consideration of the 25 dB fence. These and other entities that have historically chosen a more restrictive measure--or just a different measure--for hearing loss recordkeeping will be required to use the federal standard.
  • Work-relatedness--29 CFR 1904 defines work-relatedness as "an event or exposure in the work environment" that "either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness." In addition, and importantly, 29 CFR 1904.5(a) indicates that "Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment . . ." absent some specific exclusions (emphasis added). Determination of work-relatedness must be assessed by a physician or other licensed health care professional; under an agreement between OSHA and the National Association of Manufacturers, the guiding principle is "more likely than not." This agreement places the burden of the decision regarding work-relatedness on the employer, but in the case of disagreement on the work-relatedness of a given case, the burden of proof will fall back to OSHA.
  • Separate column--OSHA has required employers to report hearing loss of one description or another since 1986 but without the ability to keep separate track of the hearing loss cases, because the hearing loss reports have been combined with all other non-specified injuries and illnesses. The January 2001 issue of 29 CFR 1904 included a new set of reporting forms with a unique location for reporting hearing loss. As the rule underwent review and revision, the new forms were put on hold and the hearing loss column was dropped from the current version of Form 300. OSHA took additional comment on the need for a separate column and decided the separate column would return in 2004. The separate column will, for the first time, permit benchmarking hearing conservation program performance by industry, SIC, region, or other criteria.

After a long dormancy, OSHA is waking up to the need for revised regulations to protect workers from the hazards of high noise exposure.

This article originally appeared in the October 2003 issue of Occupational Health & Safety.

About the Author

Lee Hager brings more than 25 years' experience to his position as Hearing Conservationist for 3M, including consultation with Fortune 50 companies on hearing conservation program effectiveness. He is currently chair of the Council for Accreditation in Occupational Hearing Conservation, is past president of the National Hearing Conservation Association, and is past chair of the Noise Committee of the American Industrial Hygiene Association. He works with the National Institute for Occupational Safety and Health National Occupational Research Agenda (NORA) Manufacturing Sector Council. He publishes regularly and presents internationally on noise and hearing issues. Most of all, he cares about your ears.

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