The Everyday Hearing Protection Program

Protecting your most valuable asset (your employees) is a constant responsibility for safety managers.

• By Linda F. Johnson, MS, CSP
• Apr 01, 2006

YOUR hearing protection/conservation program is rolling along. Upper management is in full support. The budget is workable and approved, including audiometric testing, and engineering corrections (where possible) have been put into place. Your written program is great.

You have the PPE dreams are made of: a vast, colorful assortment of plugs, bands, muffs, combo units, and plenty of spares for any need and situation. You have distributed them to every affected employee and provided basic training. Now what?

Before you pat yourself on the back, consider that our workplaces are alive with sounds and noise--clacks, squeals, hums, whumps, the grating and growling of machinery, the seemingly familiar impact sounds of metalwork, the buzzing roar of saws in and out of the forest, the noise/vibration combination of construction work, and the deafening sounds of aircraft, trucks, and shipping. We as safety professionals do our best to protect employees from noise, but how can you ensure a living, working hearing protection program that really gets the job done? It is important to remember that our noisy workplaces are constantly changing, depending on the work being done at that minute! Use these tips as your guide.

• Complete a work site assessment including task assessment and document it accurately. This document for each job will provide a baseline of tasks and needed PPE. Keep a mindful eye on noise-related activities and special-duty tasks that are not frequent. Be aware, this is not an easy program. It is well worth the effort but can be overwhelming in itself.
• Audit your hearing protection program and PPE. Look at the written plan for changes every year or whenever conditions change that need to be updated in your program. This can be great fodder for committee activity; include your worker's compensation representative, insurance representative, and safety committee in the process to ensure you have covered everything needed in the changes. Ensure records are open, available, and up to date for all employees on every shift and location in the event someone requests them. Spot-check with employees and ask specific questions, such as, "What would you do if you needed hearing protection for a job and none was immediately available?" Give examples, such as calling for PPE at a remote location, a wearability problem, etc. to cover different potential non-compliance issues.
  You'll be amazed by how much you learn about your program this way and what is not working out in the field. Don't forget seasonal or temporary worker coverage and tasks that these employees do. Make notes--lots of notes--so you can make those additions and changes that are needed. Enforce consistency of use for all affected employees. Ask questions about use, sanitation, medical care, and disposal.
• Ask for assistance from employees. Your employees deal daily with the business of getting the job done and often know what works and what does not work. Ask them what improvements are needed, including training methods, assistance, or format; better PPE, including more sizes or materials; or other issues you may have overlooked. Sometimes the most expensive is not the best in the way of PPE. Find out what works at your site and use it.

Training Issues
Ensure training and awareness are appropriate for workplace noise hazards. Do night shift employees receive the same training as day shift? How about those temp workers and seasonal folks? Are they trained in a timely manner? Is everything documented? Do employees know how to ask for assistance if there are questions or concerns? What about special visitors, such as inspectors? Are they briefed about potential noise hazards and provided PPE?

• Update the program. One of the most frequently overlooked aspects is updates. We finish a program, breathe a sigh of relief, file it, and move on to other issues. However, updating may be critical, especially during start-ups or constantly changing occupations.
• Use graphic examples for training and awareness. Loss of hearing is no laughing matter, but one that needs to be addressed constantly. This is not a "get better" situation. Once damaged, a worker's hearing is damaged forever. No worker's compensation can repay such loss, and employees need to understand their part in protection and what the ultimate costs will be to their personal lives.
• Have realistic examples that apply to all age groups affected. Be honest about the potential, and be realistic about the long-range effects in the workplace. Consider misuse situations that can create injury potential, whether the exposure is accidental or planned by employees.
• Ensure every affected employee attends training and is upright and awake, paying attention to what you have to say. Know about and provide assistance for any employee who needs special accommodations.
• Maintain control of the training sessions. Humor is great, but don't let it get out of hand or you may lose the training momentum altogether. Quietly but quickly, deal immediately with disruptive behaviors or lack of interest. Be consistent.
• Don't forget the other employees on site. Have a plan for training and documentation for all employees who rotate from area to area and special-needs employees or visitors. If your audience uses a mix of languages, make sure the training is understandable by having interpreters if needed.

Documentation
Document the training. This cannot be stressed enough! Make employees sign that they received it. File it where it can be traced if needed, such as in their personnel files or a central database. If they get cute and do not sign in, make them take the training again!

Verify that intended points you wanted to convey were learned. Test or spot-check the students if necessary or if the potential hazards warrant it.

• Revamp your training to discard unworkable elements. Add new, easy-to-understand training ideas for next time. If you hand off retraining to supervisors, make sure helpful handouts are provided to assist with covering key points equally in all sessions.
• Update your own training and awareness, too. Unfortunately, safety professionals sometimes forget to brush up on topics. Attend other safety professionals' training sessions on a regular basis. There are constant improvements in training and getting the message out to workers.
• Convey personal interest in your workers' saving their own hearing. Let's face it, you cannot make isolated workers wear protection; they must want to comply. Reminding them of the long-term losses they will experience may help.
• Instill the employee's personal responsibility for hearing protection. They have the most to lose in this situation! This is not an "employer program" only; it should be a personal program goal for each person.

Rewards of a Good Program
A well-developed, well-implemented, well-monitored hearing protection program protects your employees and helps them safeguard their hearing each and every shift. Your workplace is unique, and its noise levels may mean there's a chance that employees could be exposed to excessive noise levels. Being proactive by providing physical hearing protection and hearing conservation training are important ways to help them protect their hearing on the job.

Such a program protects and trains your employees to understand noise exposure hazards in their workplace. Hearing protection options that are immediately available reduce the risk of employee hearing loss and improve the health of your workforce. They also reduce your liability.

This article appeared in the April 2006 issue of Occupational Health & Safety.

This article originally appeared in the April 2006 issue of Occupational Health & Safety.