AIHA requested the PEL to be lowered to 85 dBA (as an 8-hour time-weight average) and to adopt the 3 dB exchange rate, changes AIHA “strongly believes” are appropriate for both general industry and construction standards.
“One of the greatest challenges and concerns we now face in the United States is the hearing loss that is occurring in our work force,” Booher wrote. “Over 30 million workers are exposed to hazardous levels of noise, and noise-induced hearing loss is one of the most common occupational diseases. Such hearing loss significantly affects the ability to communicate and negatively impacts a worker’s quality of life.”
According to the letter, even a compliant hearing conservation program – where workers are exposed up to 90 dBA TWA with no hearing protection – “will yield up to 26 percent excess risk of material hearing impairment over the course of a working lifetime.” Lowering the PEL to 85 dBA, however, could reduce the number of workers at risk by at least one half.
“The vast majority of the nations of the world regulate workers’ noise exposures at lower levels than the U.S. In fact, the U.S. is one of only two nations that still uses the 90 dBA PEL and is one of only three nations that uses the 5 dB exchange rate,” Booher wrote. “As a result, American workers are allowed exposure to noise levels that would result in more hearing loss than the rest of the world.”
The letter also pointed out that many agencies and organization in the United States use or recommend the lower exposure limit, including the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH). Furthermore, lowering the PEL could help streamline hearing conservation program management by adopting a single threshold for all engineering controls, training, hearing protection and hearing conservation programs.
“AIHA urges OSHA to take immediate action on this issue to ensure that American workers are afforded the same level of protection from hazardous noise that the majority of the world’s nation provide their workers,” Booher wrote.