Construction Hearing Rule Can't Wait

700,000 workers are at risk, AIHA's president warns

THE American Industrial Hygiene Association's president, Roy Buchan, sent a letter Aug. 22 urging OSHA's acting chief to accelerate work on a hearing conservation rule for construction workers. Buchan's letter noted AIHA had taken an active role in OSHA's consideration of this rule since May 2000.

OSHA's most recent semi-annual agenda listed the rule as a "long-term action" with no timetable for additional action. That is a limbo status in which no work might be done on a rule; while the last two OSHA bosses have said their agendas reflect real priorities and actions, long-term is a handy bin for any rule too controversial or complex to issue but too politically important to kill outright.

"For over 21 years construction workers have not been afforded the same legal protections from hearing loss as have their industrial counterparts," Buchan's letter states. "Over 700,000 workers are at risk and many lose significant hearing after only 10-15 years on the job." Noise exposure evaluation is necessary for workers with potential for exposure above 85 dBA, and training of all construction workers is essential, he wrote.

Other points Buchan raised include:

* Construction environments are typically noisy, and hearing loss is common among older construction workers. He urged and improved regulation using consensus standards and "demonstrated good practices."
* Good industrial hygiene practice dicates following the hierarchy of controls. In that light, employers should exhaust efforts to substitute for and/or eliminate noise hazards, develop and deploy engineering controls, and finally use administrative controls before PPE, "which should be treated as the last line of defense."
* OSHA should look at exposure assessment and compliance methods similar to those in the lead in construction standard and the draft silica standard. Both list specific job tasks and specific protection that must be provided to a worker at the start of a job unless there is historical empirical data to show otherwise, wrote Buchan.

Buchan also urged the agency to consider compliance alternatives for employers if the agency does decide to make audiometric testing part of the standard. Washington state has a regulation in place (WAC-296-817-500, Options to Audiometric Testing) that is a good example, he wrote.

This article originally appeared in the September 2005 issue of Occupational Health & Safety.

About the Author

Jerry Laws is Editor of Occupational Health & Safety magazine, which is owned by 1105 Media Inc.

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