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What are the primary differences between the OSHA and MSHA hearing conservation rules?

Although the two hearing conservation standards are similar, the two are very different in how they are implemented. Both may be federal agencies, but the regulators enforce the regulations quite differently. For example, when employees are subjected to sound exceeding the PEL's, OSHA states "feasible administrative or engineering controls shall be utilized". MSHA, on the other hand, defines "feasible" much more stringently and won't allow the use administrative controls, for example, hearing protectors, until all engineer efforts to reduce the noise at it's source have been exhausted.

  How do I know my company must have a hearing conservation program (hcp)?

If employee noise levels found in the workplace, as determined by a noise survey, are at, or exceed 85 decibels, a formal hearing conservation program must be established.

What are the five required components of a compliant hcp?

Monitoring, baseline/annual hearing testing, annual employee training, appropriate and adequate hearing protection, and record keeping.

There are four objectives of an noise survey; To identify workplace areas where noise levels are at or exceed 85 decibels; explore the feasibility of using engineering controls to reduce noise levels; identify employees who must be included in a hcp; and enable the proper selection of hearing protection.

Should I use a noise dosimeter or sound level meter to obtain noise levels?

Which noise measuring device you use depends on the how constant or variable the noise levels found in the workplace. The personal noise dosimeter is usually the best choice unless noise levels at the employee's ear vary no more than two decibels over an 8-hour work shift.

What is a baseline hearing test?

The first hearing test given to an employee as part of the hcp and is used as a reference to which all subsequent hearing tests are compared.

How soon must I establish a baseline hearing test on a newly hired employee?

Within one year if a mobile test van is used to satisfy the audiometric testing requirement, otherwise the employee must be tested within the first 6 months of being to exposed to noise levels at or in excess of 85 decibels.

Am I required to obtain a baseline hearing test on temporary employees?

Yes

What is an annual hearing test?

Any hearing test after the baseline test has been established that is used to satisfy the requirements.

What are the follow-up procedures once the hearing test is obtained?

Every hearing test subsequent to the baseline test must be compared to the baseline to determine if a standard threshold shift (STS) has occurred, to make certain the audiogram is valid, and to refer for additional testing or a medical evaluation.

How do I handle medical referrals?

If the physician or audiologist determines a medical referral is necessary, the employee should be informed in writing of the need to see a physician. Usually, the employee pays for the first visit to the physician, but the employer is not required to do so.

What is a standard threshold shift (STS)?

Compute the average decibel value in each ear at 2000, 3000, and 4000 Hz from the baseline hearing test and compare the results with the average decibel value in each ear at same frequencies from the current test. If the difference is 10 decibels or more, a STS has occurred.

Under what circumstances may a baseline hearing test be changed or revised?

The standards do not spell out how to revise a baseline hearing test but does say we may do so when the change in hearing is persistent or if the person's threshold of hearing improves significantly. One criterion for changing the baseline is to validate the change with at least two subsequent test before revising the test.

When is the STS recordable on the OSHA 300 Log?

If an employee’s hearing test reveals that the employee has experienced a work related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee’s total level is 25dB or more above audiometric zero (averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS, you must record the case on the OSHA 300 Log.

How can I know for certain that a loss of hearing, especially a STS, is work related?

You can't know for certain. Audiograms showing noise-induced hearing losses look similar whether the noise exposure was on or off the job. OSHA, however, assumes any loss of hearing is work related, unless the employer can show the otherwise, so a fully compliant hearing conservation program is essential

What topics must be included in our hcp employee training program?

The annual employee training program must include the following topics: the effects of noise on hearing; the purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instruction on the selection, fitting, use, and care; and the purpose of hearing testing.

Can just showing a training film or video tape be sufficient to satisfy the rules?

Yes, if the training film or video is comprehensive enough. However, such a training program be quite lengthy. A short video or film combined with a brief live demonstration, especially in the proper fitting of the hearing protector, would be best.

Which of the many hearing protective devices (HPD) is best for my employees?

Which protector to use depends on the intensity and duration of your employee's noise exposure and the type of industry in which they must work. Remember, however, that the insert type of HPD carries the largest noise reduction rating (NRR) and will yield the greatest noise reduction to the employee's ear, followed by the HPD that fit over the outer ear such as the earmuff type, and finally by those that rest at the entrance to the ear canal.

What is the NRR?

Noise Reduction Rating and ostensibly indicates, properly fitted, how much ambient noise is reduced to the employee's ear. The NRR is, however, an ideal rating and rarely reflects real-world attenuation. To arrive at a more accurate amount of noise reduction, divide the NRR by one-half and then subtract another 7 decibels. Example: If HPD has an NRR of 32, the expected real-world attenuation would be 9 decibels (NRR = 32/2-7=9).

How can I be certain our employees are adequately protected from noise?

Have a fully compliant hearing conservation in place. Knowing workplace noise levels, regularly testing employee hearing, providing annual employee training, and ensuring properly fitted and monitored hearing protection, will prevent on-the-job hearing loss.

What are the eight program elements required by the Respiratory Protection Standard?

The major program elements of the Respiratory Protection Standard (29 CFR 1910.134) are: 1. selection of a proper respirator: 2. baseline medical evaluation: 3. fit testing; 4. respirator maintenance and care; 5. air quality; 6. annual employee training; 7. program evaluation.

How can I obtain a copy of the publication Question and Answers on the Respiratory Protection Standard?

This 79 page document contains guidance and interpretations on the most frequently asked questions on respiratory protection.n a Q and A format. Go to www.osha.gov ???

What is a "fit check" or "user seal check"?

A fit check, sometime referred to as user seal check, is a procedure the employee performs each time the puts on the respirator and is not meant to be a substitute for the fit test. The purpose the fit check is to ensure the respirator is properly seated to the user's face.

Is a written respiratory protection program required for voluntary use of a respirator?

No. The employee is obligated to determine that such respirator use will not itself create a hazard and to provide the user with the information required by the Standard.

Are seasonal or temporary workers exempt from the required medical evaluations?

No.

Can a fit test be performed before the initial medical evaluation has been completed?

No. The initial medical evaluation must be conducted prior to fit testing.

Are medical evaluations required for both positive and negative pressure respirators?

Yes.

Are medical evaluations required annually?

No, but there are four conditions that can trigger a medical re-evaluation: the employee reports problems wearing the respirator; if the program administrator determine one is necessary; changes in workplace conditions that may increase workload; any information which may indicate the need for re-evaluation.

Can an employee use their own physician to provide a medical evaluation rather than the employer's?

Yes.

Can an employee decline to be medically evaluated for use of a respirator?

No, an employee cannot refuse to be medically evaluated and still wear a respirator.

Do all tight-fitting respirators have to be fit tested?

Yes. Both positive and negative pressure tight-fitting respirators must be fit tested.

Does a "user seal check" or "fit check" qualify as fit test?

No. The fit check is a procedure used by the employee each time the respirator is put on and is not a substitute for the more inclusive fit test.

Can a employee wear a tight-fitting respirator with a beard or other facial hair?

No. An employer cannot allow tight-fitting respirators to be worn by employees who have facial hair that comes between the sealing surface of the respirator and the face. However, some types of loose-fitting hoods or helmets accommodate facial. Also, if the employer has determined there is no hazard, voluntary users are not prohibited from wearing a beard.

Is annual respiratory protection training required by the standard?

Yes, annual employee training must be provided to employees who are required to use respirators.

What information must be included in the employee training program?

The performance-based training must be understandable to the employee and should include at a minimum the following: why the respirator is necessary limitations and capabilities of the respirator how to use in an emergency how to inspect, put on, remove, use, and check the seals maintenance and storage recognition of any medical signs that may limit or prevent use.