In-House Advantages

One-on-one training and follow-up are much easier for small businesses' hearing conservation programs, but resources must be managed wisely.

WE know the DuPonts and Fords can afford to maintain effective hearing conservation programs. But more than 99 percent of U.S. companies are defined as small businesses. They employ more than half of the U.S. workforce and are the dominant power in driving the economy. Small-business employers of noise-exposed workers can feel a real pinch in meeting OSHA's requirements for effective hearing conservation programs. So how do small employers, who must keep as close an eye on conserving the bottom line as on conserving hearing, also protect their noise-exposed workers?

As an industrial audiologist, I have seen effective OSHA-standard hearing conservation programs operating in a 10-person machine shop, as well as a 50,000-person oil company. While the principles of hearing conservation are the same in both settings, the small employer must use resources more wisely. He or she must distinguish the components of a program that can be competently handled in-house and those that are best contracted out to experts.

There are several ways small employers can reduce the cost of expensive consultants' bills and manage the risk of noise-induced hearing loss for less. In fact, small employers often can leverage their small size into some real advantages in their company's hearing conservation programs. Each part of an OSHA-standard program is described below, with recommendations tailored to small businesses to maximize their benefit.

Noise Monitoring
You run a mid-size manufacturing shop using equipment that generates some noise. But how can you tell whether the noise is hazardous or you need more in-depth measurement? The common rule of thumb is that if you must shout over the background noise to be understood by someone just an arm's length away, that noise is probably hazardous and approaches OSHA's Action Level of 85 decibels (dBA).

Accurate noise monitoring is the foundation of a program. Look for sources that will conduct basic noise surveys at no charge for your facility. Many liability insurers offer this service to their insureds, and OSHA consultation agencies frequently offer this service at no charge to small employers (with fewer than 250 employees).

For larger facilities or work sites with high fluctuation in noise exposures, it is best to contract an acoustical engineer, industrial hygienist, or audiologist for complex measurements. This initial expense is worth the cost: Accurate noise measurements are often valid for several years if there is no significant change in equipment or work processes. Noise monitoring does not need to be repeated annually--only when there is a significant change in the noise sources.

While the initial cost of equipment (a sound level meter and a noise dosimeter) is expensive, some employers purchase their own meters and competently monitor their noise levels in-house. OSHA-standard noise monitoring requires no certified training, but it is critical to follow manufacturers' instructions or other competent tutorials for accurate measurements. (For example, hold the sound level meter at extended arm length rather than near the body, which can shield incoming sound.)

Many employers like to purchase their own noise measurement equipment to monitor noise levels under varying conditions or to measure the differences caused by changes to the physical layout. Note that sound level meters are rated for integrity; for OSHA-standard measurements, a Type II or Type I meter is required--not the less expensive Type III meters that are useful only for screening purposes.

Audiometric Testing
Small employers nearly always contract out the audiometric testing service because it requires specialized equipment and trained personnel. According to OSHA regulations, noise-exposed employees are to receive an annual hearing test that is compared to the employees' baseline tests to determine whether their hearing has remained stable. Noise damage can be determined only when audiograms are compared serially. A single industrial audiogram cannot identify noise damage.

Although a nearby industrial clinic may offer audiometric testing, many mobile testing services fit the budget of small employers. Mobile testing services minimize the time away from the job for the worker. A source list of competent mobile testing services is maintained by the National Hearing Conservation Association (303-224-9022 or info@hearingconservation.org).

Whether the testing is administered at a clinic or by a mobile service, use a provider who will combine OSHA-required employee training with annual audiometric testing. One-on-one training at the time of audiometric testing beats large-group training when outcomes that affect hearing conservation are measured. Also, make certain your testing service provides the required comparison to baseline with understandable follow-up reports. As part of their service, many providers offer notification letters to employees who show a significant shift in hearing--a convenient service for the small employer. In fact, research shows that when each employee receives a copy of his/her audiogram or an explanation of the results at the time of testing, the rates of noise-induced hearing loss in that workforce decrease.

Here's an added tip: Include managers/owners in the audiometric testing program. When employees see the managers/owners taking their hearing seriously, it sends a positive message throughout the workforce.

Hearing Protectors
Employers are obligated to provide a "variety of suitable hearing protectors" to noise-exposed workers; offering only one type of hearing protector does not suffice. One proven method of obtaining worker buy-in for the use of hearing protectors is to include them in the selection process. Use your existing safety committee or form an ad hoc group of workers to try out several different hearing protectors during a two-week trial period. Their valuable input will help you evaluate features that cannot be determined from a catalog page: comfort, ease of use, and the ability to communicate in noise. Hearing protectors recommended by workers themselves are usually those most likely to be used.

Develop a firm but fair policy about using hearing protection in noisy work areas. The owner of one 15-person machine shop I know has an unmistakable enforcement policy: "If I see you working in noise without your ear plugs, don't bother coming to work tomorrow." And he sets the example by using hearing protectors any time he sets foot on the work floor. For most companies, however, an effective enforcement policy is based upon motivation and education, not fear.

Small employers are in a much better position than their larger counterparts to fulfill a key role in a successful hearing conservation program, the individual fit checks of hearing protectors. It is not enough simply to supply hearing protectors; OSHA regulations specifically require the employer to ensure a proper fit is obtained. Here are three easy tools for the small employer to help verify proper fit of ear plugs.

* Visual check: Look at the ear plug wearer from the front (face to face) or look in the mirror if you are wearing ear plugs yourself. For ear plugs with a stem (a firm, protruding piece used for insertion), only the tip of the stem should be visible from the front. For ear plugs without stems (most foam models), the ear plug should not be visible. An ear plug that is clearly visible from the front is a warning sign of poor insertion.
* Pull check: When properly inserted, an ear plug will completely seal the ear canal. Check this seal by pulling on an inserted ear plug: If it comes out with no resistance, it was not properly fitted.
* Acoustic check: With ear plugs inserted while in noise, cup your hands firmly over the ears and release. Properly fitted ear plugs will block enough noise so that covering the ears with the hands results in no significant change in noise level.

Training
A small employer also has a definite advantage when it comes to OSHA-required annual hearing conservation training: one-on-one contact. Research confirms that one-on-one training is more effective than group training in hearing conservation skills. Employers are free to use any means of training: brochures, videos, classroom, etc. But when group training is supplemented with individual training, research shows a dramatic increase in the usage of hearing protection and the proper fit of those protectors.

Hearing conservation training can be outsourced, perhaps bundling it with the annual audiometric testing. After all, there is no better time to motivate workers to use hearing protection than immediately after their audiometric test and the subsequent explanation of results. Mobile audiometric services often request that workers bring their hearing protectors at the time of testing so an individual fit check can be performed.

Small employers should not overlook the option of providing training in-house. An OSHA-standard training program includes content on the effects of noise, the purpose and proper use of hearing protectors, and an explanation of the audiometric testing. A variety of safety resources provide that content. But ideally, a training program will also include motivational materials proving to workers they are susceptible to noise damage, demonstrating the future risk of hearing loss, and removing the barriers to wearing hearing protectors.

Recordkeeping
Keeping records of noise exposures and audiometric tests is not only a regulatory requirement; it also makes good business sense. When contracting for outside services, look for providers who offer reports that are understandable and concise. And don't forget to post a copy of OSHA's hearing regulations at the work site. Nearly three-fourths of OSHA's recordkeeping violations in hearing conservation the past five years were simply not having a copy of the hearing conservation standard posted in the workplace. Posters of the standard are available from several manufacturers.

Conclusion
Small employers are at no disadvantage in implementing effective hearing conservation programs. In fact, a smaller organization makes one-on-one training and follow-up much easier. But resources must be managed wisely. The small employer cannot be the expert in all safety matters, but he or she certainly must be aware of safety matters.

Hearing conservation is not a program to be taken off the shelf once a year at the time of audiometric testing, dusted off, then placed back on the shelf until next year's testing. A successful program will be championed by a small employer who recognizes the hazards of noise and adequately protects and motivates workers each day.

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

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

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