Ensuring Effective HCPs

For real savings, learn to identify at-risk workers and prevent progression toward compensable hearing loss.

It’s late in the afternoon on a Friday at International Meta-Multi-Mega Manufacturing Inc.’s corporate headquarters, and Bill, the manager of Safety, Health and Environmental Services, is on the hot seat regarding management’s latest concerns about compensation liability. The director of Finance, Samantha, is anxious to get some answers. The HR manager, Hector, nods in agreement.

“Bill, why are we seeing an increase in OSHA 300 Log recordables and the possibility of new compensation claims for hearing loss in our Central Zone operations? This last report shows eight new Standard Threshold Shifts! I thought we had a Hearing Conservation Program out there that would keep this from happening, but the way things look to me, we’re not getting the job done! We spend lots of our money and lots of your time getting noise measurements, doing training, supplying ear plugs, and getting hearing tests done, and for what? You know, if we end up with compensable hearing loss cases, it will cost us even more—possibly a lot more! Your reports give me lots of noise sampling data, but we need answers rather than data. . . .What are we doing wrong? We have a board meeting Monday and I need something from you that makes sense—now!”

Samantha’s concerns are valid. One projection by the U.S. Chamber of Commerce indicates the average maximum compensation cost per worker for occupational hearing loss will be $98,729 by the year 2013. NIOSH estimates 30 million U.S. workers are at risk of losing their hearing because of occupational exposure, and BLS statistics for 2006 show the incidence rate for hearing loss in the manufacturing sector is 215 percent greater than any of the other major categories of non-fatal illnesses reported (skin diseases or disorders, respiratory conditions, and poisonings). Hearing loss compensation awards for federal employees alone in the year from July 1, 2003, to June 30, 2004, were $54,092,936!

Given these kinds of potential liabilities, it’s no wonder business owners and top executives want to know they have a handle on future costs. Workers who are not protected by an effective Hearing Conservation Program (HCP) today could very easily become recipients of significant monetary awards in the future.

Unfortunately, when it comes to providing the kinds of answers Bill’s management team is demanding, safety and health professionals often find themselves with a dilemma. That is, just how are we supposed to measure the performance of our existing HCP and take steps to identify, report, and correct deficiencies, plus create a process for continuous program improvement? More important, how can we use the data we have now to project and communicate future liability to the rest of the organization? Because the ultimate goal is preventing hearing loss, how can we identify those workers who, for whatever reason, may be at risk of significant hearing impairment? And for those who do exhibit a change in hearing threshold levels, how can we be sure it is work-related?

Using the Right Tools
An effective HCP should have the proven ability to reduce or eliminate OSHA-recordable hearing loss, but this is often not the case. While many programs are effective, there are no defined standards as to how to gauge their performance. Defining performance metrics for HCPs is an area of increasing interest in the safety and health discipline as more and more companies adopt continuous improvement initiatives across their entire organization.

OSHA’s fundamental requirement as stated in 29 CFR 1910.95(c) is for a “continuing, effective” HCP, but nowhere does it put forth the means or metrics by which to gauge the effectiveness of a specific hearing conservation program. While OSHA has given a definition of “effectiveness” (in a rule interpretation dated June 6, 1985) that states: “Effectiveness . . . means a hearing conservation program that prevents workplace noise from producing a standard threshold shift in the hearing ability of any employees,” the fact is, an individual’s risk of hearing loss is usually not identified by any HCP until after it has already occurred. Audiograms (hearing tests) are really good at documenting hearing loss, but a single audiogram does not provide enough information to draw conclusions regarding risk of future hearing loss in a given worker or group of workers. Most companies already have exhaustive recordkeeping procedures for noise exposure sampling and audiogram reports and maintain a log of OSHA recordable injuries, but they may not be using all or even any this information to their best advantage. Yet methods and tools for doing so exist today. Standards quantifying the relationship of noise exposure to hearing loss have been adopted, including ANSI S3.44-1996, Determination of Occupational Noise Exposure and Estimation of Noise-Induced Hearing Impairment, and ISO 1999-1990, Acoustics—Determination of occupational noise exposure and estimation of noise-induced hearing impairment. These standards provide a basis for understanding how noise exposure translates to individual risk assessment. When you consider there is a quantifiable cause-and-effect relationship between noise exposure levels and changes to Hearing Threshold Levels (HTL,a measure of hearing acuity at various frequencies), it seems logical that information contained in the data already being gathered could be put to better use. It can, if you know what to look for.

The good news is that the answer usually lies in data that already has been acquired; the challenge is in leveraging that existing information to its best advantage. The goal is to sift through the data, uncovering leading indicators that identify at-risk individuals or population groups before a recordable Standard Threshold Shift takes place. Assuming loud noise is present in the workplace, it will be considered by OSHA to be the cause of any recordable hearing loss—barring evidence to the contrary—so correctly sampled and well-documented personal noise exposure levels are a logical place to start. But that knowledge by itself does not provide all of the necessary answers.

That’s because many other factors, such as variability in noise exposure patterns from day to day, type of hearing protectors worn (assuming they are worn and worn properly), and even individual genetic vulnerability to noise-induced hearing loss (yes, some people’s ears are less “robust” than others’) all play a role in determining the outcome. Add in preexisting, temporary, or permanent medical conditions and a whole host of potentially damaging noise exposure sources outside the workplace, and you have a multi-dimensional set of causal factors and potential outcomes.

How At-Risk Workers Are Identified
Making sense of it all requires the ability to identify, quantify, and qualify the various risk factors using information that is accurate and reliable. The pieces of information needed fall into three basic categories: a) Exposure data, b) Individualized medical, behavioral, demographic, and environmental data, and c) Audiometric test results. The process for obtaining the data for categories a) and c) is formalized in the requirements of OSHA 1910.95, and these are the “hard” numbers of noise exposure and hearing threshold shift that derive from using calibrated testing equipment. Most companies have these kinds of data already, and it is usually of reasonable quality.

The process for obtaining the information in category b) is not as well defined nor specifically required, and thus not nearly as ubiquitous as the exposure and audiometric data are. A detailed employee questionnaire is the best tool for obtaining this important information. (See Figure 1.) The questionnaire is an often-underutilized means for understanding the relationship between noise exposure and hearing threshold shift (changes in hearing acuity).

Then what? As is often the case, the power of newer computer software developed specifically for this application can be used to take into account all of the information outlined above, test it for validity, and then plot the results of an individual’s hearing tests against the expected norm for that person’s age, gender, work history, noise exposure, and non-occupational activities.

The result is a percentile ranking, or score, of that person’s rate of hearing level degradation. While 10th percentile would indicate he is doing much poorer than expected, 90th percentile indicates much better than expected. The same software that provides this powerful analysis also effectively manages the recordkeeping process, but unlike common database tools, the application includes expert pattern recognition and data mining capabilities that not only rank an individual’s risk for hearing loss, but also can be used to determine potential liability.

By identifying the at-risk workers early enough, through changes to the work environment, and providing better hearing protection devices or better training on the use of hearing protection devices, it just may be enough to save a worker from compensable hearing loss before it’s too late. If an unacceptable level of hearing loss is predicted from the data, future costs can be projected by local jurisdiction, providing the occupational health and safety professional cum hearing conservationist with powerful financial incentives to offer management for taking corrective action early and preventing hearing loss on its watch.

Bill Makes His Case
Having spent much of the weekend researching the latest ideas in HCP improvement, Bill made his report to the board and included a suggestion it adopt the latest software analysis techniques for measuring performance and improving the company’s HCP, along with some projected costs of implementation and potential for reduced liability. On their way out of the boardroom, Samantha smiled and said,“Bill, well done. I knew you’d get out in front of this issue—thanks!”

This article originally appeared in the March 2009 issue of Occupational Health & Safety.

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