Protection for Process Industries

Here, ensuring product integrity is almost as important as preventing hearing loss in employees.

• By Bill Sokol
• Sep 01, 2004

THE issue of hearing protection in the process industries--food processing, tobacco, and pulp and paper--is more complex than in other industries. Not only do employers have to protect workers' hearing, but they must also be inordinately protective of the purity of their product.

Product Purity Requirements

In the food process industry especially, a large body of federal codes, regulations, and compliance policy guides lies in wait for the manufacturer who does not pay heed to good manufacturing practices. Here's a brief sample:

• Title 21, Chapter 9, Subchapter IV, Section 342(a)(1) of the U.S. Code states, "A food shall be deemed to be adulterated if it bears or contains any poisonous or deleterious substance which may render it injurious to health."
• Section 402(a)4 of the Federal Food, Drug, and Cosmetic Act (FD&C Act) further deems food to be adulterated "if it has been prepared, or packed or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health."
• The FDA lists "Defect Action Levels" that define the extent of contamination acceptable in food.
• However, 21 CFR 110.110 also clearly states that even in cases where contamination does not exceed the Defect Action Level, food manufacturers are still required to observe current good manufacturing practices (FD&C Section 402(a)4): "The manufacturer of food must at all times utilize quality control procedures which will reduce natural or unavoidable defects to the lowest level currently feasible."
• Title 21 of the Code of Federal Regulations, Section 110.80 regarding Good Manufacturing Practice in Manufacturing, Packing or Holding Human Food, stipulates that, "All reasonable precautions shall be taken to ensure that production procedures do not contribute contamination from any source. Chemical, microbial, or extraneous-material testing procedures shall be used where necessary to identify sanitation failures or possible food contamination. All food that has become contaminated to the extent that it is adulterated within the meaning of the act shall be rejected, or if permissible, treated or processed to eliminate the contamination."
• According to Chapter 5, Sub Chapter 555, Section 555.425 of the FDA/ORA Compliance Policy Guide, a food product that contains a hard or sharp foreign object between 7 mm and 25 mm or over 25 mm in length, "should be considered adulterated within the meaning of 21 U.S.C. 342(a)(1) if a health hazard is established by CFSAN (Center for Food Safety and Applied Nutrition) review."
• CPG 515.350 addresses embedded objects in confectionery, which may cause such foods to be adulterated within the meaning of 21 U.S.C 342(d)(1).
• Any food products considered adulterated are subject to seizure by the FDA's Division of Compliance Management and Operations (HFC-210).

But running afoul of federal regulation, as serious as that can be, may not even be the worst part. An item like a stray ear plug turning up in someone's marmalade may not constitute a serious health risk, but in a litigious society like ours, the possibility of hefty lawsuits is very real. Even worse, in these days of media frenzy, the biggest potential danger to a company is public reaction should such a story catch the eye of the press. Beyond fines and settlement costs, this kind of crisis can kill a company.

In the tobacco industry, regulations regarding product purity are also very stringent, though not so strict as food. Ironically, the goal of these regulations is to make sure nothing gets into the tobacco product which can cause harm if it is combusted and inhaled. In pulp and paper, the concern is not health but primarily economic. Batches are huge, as is the cost of an impurity causing spoilage, and strict requirements to eliminate contaminants--especially plastic--extend all the way upstream to the chippers who initially grind the logs.

Detectable Hearing Protectors
All in all, then, if you are the safety officer at a process industry company, the issue of providing hearing protection that is safe for people and process is not one to be taken lightly. There are two basic approaches to protect product from hearing protectors: The first is to keep the hearing protector from falling into the product in the first place, and the second is to make it easily detectable if it does.

Manufacturers of hearing protection devices offer a wide selection of products that meet these objectives. Both single- and multiple-use ear plugs are available with integral cords that can be hung about the neck. Should a plug fall out during use, it remains attached to its fellow. And should a set inadvertently fall into a vat, only one item needs to be retrieved instead of two--which can be retrieved more easily because of the cord. Cords also offer the convenience of allowing workers to remove plugs when not needed and leave them hanging around their necks.

Similar in concept, banded plugs mount the ear plug onto a molded plastic band that also is worn about the neck. In addition to attaching the protector to the person, the band also applies slight pressure on the plugs to keep them well seated in the ear. Another product incorporates a patented design that prevents the ear pads from touching dirty or contaminated surfaces when they are set down.

A number of detection schemes are available to help retrieve plugs from process batches. One approach is to make both plugs and cords highly visible by using multiple, flashy--even stylish--colors. Another is to make the plugs, and often the cords, metal detectable. This way, even if the cords are torn loose by a mixer, a grinder, or are cut into pieces, all components are readily detectable with X-ray scans.

For industries such as pulp and paper where plastic is not allowed, cotton-fiber cords are available that will not harm process or product. These products are packaged in paper to further minimize the risk of plastic contamination.

Hearing Loss a Growing Problem
The bottom line in all this, however, remains the need to protect workers' hearing. In spite of growing awareness of hearing loss and increased efforts to combat it, the incidence of noise-induced hearing loss among industrial workers--process and otherwise--continues to rise. A recent National Health Interview Survey showed that hearing problems among individuals 45 to 64 years of age have risen 26 percent during the past 30 years. This means safety professionals need to look beyond traditional Noise Reduction Ratings (NRR) in protective equipment and consider the human factors that undermine hearing conservation efforts.

This, combined with some new technologies in hearing protective devices, can help safety professionals make better purchasing choices and help reduce the likelihood of continued noise-induced hearing loss incidence. We call this approach the "four C's" of hearing protection--Caring, Comfort, Convenience, and Communication.

The first step is to help workers understand and Care about hearing protection. For many workers, hearing loss is a remote threat at best, and many don't realize that the impact of hazardous noise is cumulative. Even brief periods without protection can generate real, lasting hearing loss. This requires an educational effort.

Wearable Hearing Protectors
Safety officers must make sure hearing protection devices are Comfortable, Convenient to use, and fitted correctly. The best hearing protection is that which is worn, and research clearly indicates comfort is the prime driver of how diligently people will wear hearing protection.

But the biggest need is the fourth "C," the need to enhance workers' ability to Communicate while wearing hearing protection on the job. It's ironic that in order to protect workers from permanent hearing loss, we subject them to temporary hearing loss; there is a growing body of research that suggests links between the inability to hear while wearing hearing protection and industrial accidents. In addition, workers who cannot communicate easily feel more isolated on the job and are less likely to be content and productive.

Ultimately, hearing protection involves human beings. If we are to reverse the growing incidence of noise induced hearing loss--and protect the purity of valuable products in the process--we need to consider the human elements of the equation and choose products and tactics that will allow us to address those elements successfully.

This article originally appeared in the September 2004 issue of Occupational Health & Safety.