Why do experts in government and out in the field expect a huge rise in OSHA recordables for hearing loss next year? Jim Weaver, senior risk control administrator at Hallmark Cards, has an answer to that question.
Last year, out of approximately 5,000 employees at its Kansas City, Mo., headquarters complex, Hallmark had just one recordable case involving a standard threshold shift (STS) of 25 decibels (dBs).
Weaver said that if OSHA's revised recordkeeping rule, scheduled to take effect Jan. 1, were in place today, he would be looking at 28 recordable cases of occupational hearing loss. That's because the revision requires employers to record a change in hearing threshold of just 10 dB, averaged at 2,000, 3,000 and 4,000 hertz. Hallmark is in the process of gathering more data on hearing loss, and Weaver thinks the company will soon make moves to strengthen its hearing conservation program (HCP).
Many safety and health professionals agree with Weaver's assessment of what OSHA's new definition of STS will mean. John Franks, chief of the hearing loss prevention section at the National Institute for Occupational Safety and Health (NIOSH), foresees a "huge spike" in hearing loss recordables across the nation when the revised recordkeeping standard goes into effect next year, in part because many companies have not been recording hearing loss at all.
Why So Many HCPs Don't Work
In view of OSHA's more stringent definition of STS, which is coupled with a new column on the Form 300 just for hearing loss, some safety and health managers are taking another look at their hearing protection efforts. That is a good idea, according to one leading NIOSH researcher who believes too many worksites have no HCP, while other programs are not working nearly as well as they should be.
"There are some programs that look good on paper, but when you look at their records, it seems like they're just documenting hearing loss," said Carol Merry, a NIOSH specialist in hearing loss prevention.
Merry and other experts believe they know why so many programs are failing: Workers are not wearing hearing protection devices.
"The fundamental problem here is that hearing conservation programs have been viewed as something done for the worker," said Lee Hager, executive vice president of James, Anderson & Associates, a hearing loss prevention consulting firm in Lansing, Mich. "Workers never took this on as their own personal responsibility. They see it as 'something management does for me.'"
In her research, Merry encountered a good deal of resistance to the wearing of hearing protectors because they are seen as uncomfortable and inconvenient. In addition, workers sometimes argue that these devices represent "the easy way out" for management. Merry found many workers who complained and would say, "Instead of trying to make the worksite quieter, they just throw these hearing protectors at us."
Although noise controls are generally preferable to hearing protectors, these controls are not always practical and carry with them their own set of problems. Elliott Berger, senior scientist in auditory research at E-A-R in Indianapolis, argues it is often difficult to achieve 10 dB of noise reduction with a retrofit noise control application. Ten dB is what the better kinds of hearing protector devices (HPDs) can provide when used properly.
Most engineering controls require maintenance and periodic adjustment to remain effective. These problems can be avoided by cutting noise at its source through redesigning equipment, or "buying quiet," but this solution is not always feasible.
Still, Merry's research suggests that for a company to have an effective HCP, it should at least make an effort to reduce noise and to communicate this effort to workers.
Checklist for a Good HCP
A substantial body of research has established the various elements needed to have a successful HCP, according to The Encyclopedia of Occupational Health and Safety. In an article published in this resource, Larry Royster, a professor at North Carolina State University, and Julia Doswell Royster, president of Environmental Noise Consultants in Raleigh, N.C., organized this research into a checklist of good HCP practices.
Included in this checklist are five phases of an effective program:
- Sound exposure surveys of individual, daily noise exposures, including noise maps of the plant showing where HPDs must be worn;
- Engineering and administrative controls used when possible;
- Education and motivation that is updated annually, reinforced with quarterly reminders and backed by management personnel who wear HPDs;
- Hearing protection that is appropriate, is required and its use is consistently enforced in noisy areas; and
- Audiometric evaluations that are conducted regularly and employees' auditory history that is updated annually.
The Roysters' research indicates that the best strategy for making these five phases work together is to unite them under the supervision of one "key individual" who oversees the entire HCP. They note that one of the problems at large companies is that too many staff members become involved in the HCP, leading to a fragmentation in the effort.
The choice of the key individual can be critical to the success of the program. The Roysters contend that genuine interest in hearing protection is the most important qualification for this position. Keeping accurate records of sound surveys and hearing tests, and doing regular program evaluations are important functions for the key individual.
The five phases of a good program listed above can be seen as a kind of "chain" of protection, but the entire HCP may be only as strong as the weakest links in that chain -- workers who are not using hearing protection.
There are signs that the safety and health community is forming new alliances and taking bold steps to attack the problem.
Getting to Yes with HPDs
In February 2000, the National Safety Council (NSC) and NIOSH collaborated on two publications that feature hearing protection.
The material was largely the result of research of Merry and Mark Stephenson, a research audiologist at NIOSH. NSC distributed 95,000 copies of "Today's Supervisor" and 42,000 copies of "Safeworker," according to Todd Briggs, NSC's government relations program specialist.
Briggs explained that NSC signed on to the unprecedented project because it was clear "people weren't getting the message about hearing loss."
Hager thought the joint effort was on target. "Strategically, this is exactly the right thing to do," he said. The reason HCPs often do not work, according to Hager, is because workers have not internalized the value of protecting their hearing. "The attempt to communicate these issues of risk and appropriate self-protection to the workers and to their first-line supervisors is absolutely key to effectiveness."
"Today's Supervisor" states that, no matter what kind of HPD is used, employees' acceptance and use of hearing protection depends on four Cs:
- Communication, and
Comfort is the No. 1 concern voiced by employees, according to the authors. No one is going to wear anything for hours at a time if it is uncomfortable. Because of individual differences, employers must make a range of sizes and models available.
Joe Durst, director of field services and communications for the United Brotherhood of Carpenters, agrees. "You can't just have a one-size-fits-all hearing protector, hand it out and have it work."
Fortunately, there are more than 200 HPDs marketed in the United States, ranging from disposable earplugs to custom electronic earmuffs. Yet, according to Merry, the crucial importance of letting workers choose their HPDs is a message many employers have simply failed to hear.
"I can't tell you how many places we've been to where there's just one option -- a box of earplugs," she said.
Allowing workers to have a hand in choosing their HPDs has another advantage: It increases their sense of participation in protecting their hearing, making it more likely they will take the time and trouble to wear the devices.
This gets at two of the other Cs: communication and cost. Because we are social beings, workers will want HPDs that allow them to exchange comments with co-workers from time to time. The answer here is to find protectors that block out noise but do not overprotect.
According to NIOSH's Stephenson, the most important message of the booklet is captured by "cost," which means letting workers know the cost of not protecting their hearing.
"I wish I had a nickel for every time I heard someone say, 'My Dad lost his hearing, and I will too," he said. "For the average worker, there's no reason to have a hearing impairment."
Form 300 and Hearing Loss: Government and Business Reaction
"What's important about the new Form 300, as compared to the 200, is hearing loss is recorded as a separate entity in column 6. Before, it was lost under 'physical agents' or 'repetitive exposures,'" explains John Franks, chief of the hearing loss prevention section at the National Institute for Occupational Safety and Health.
After a big uptick in 2002, Franks expects to see numbers concerning hearing loss that mean something. Over time, this will reveal which hearing conservation programs (HCPs) are effective.
The Bush administration is reviewing all regulations issued in the final days of President Clinton, including OSHA's recordkeeping standard. OSHA officials could not comment on the rule, nor confirm that the new rule will, as expected, take effect next year.
Jim Weaver of Hallmark Cards is not waiting to find out. Hallmark goes beyond OSHA regulations by implementing its HCP at 83 decibels (dBs) instead of 85. In some Hallmark facilities, employees are required to wear hearing protection devices (HPDs) at 83 dBs. Weaver is assessing the situation and thinks the company will move in the direction of requiring all of its workers to wear HPDs at lower noise levels. He said he will also explore noise engineering solutions.
Despite the possible need to make these adjustments, Weaver said, he welcomes the new standard because it simplifies the burden of recordkeeping.
Marcia Kram, CIH, is a specialist in hearing conservation at Air Products and Chemicals, based in Allentown, Pa. She agrees with Weaver that the new rule will lead to a significant increase in recordable cases of hearing loss. Kram oversees a program with approximately 4,000 workers in plants around the country. Like Weaver, she welcomes the new rule because it will make recordkeeping easier.
"I'm glad they got rid of the 25 standard threshold shift (STS), so now there's just one number we have to keep track of," she said. Because some state programs required follow-up when a worker had an STS of 10, Kram had to keep two databases for every worker to keep track of both STSs. "It was very confusing to the people in our plants who had to manage this program," she said.
Kram is not anticipating any major changes to her HCP at this point, but added that "we will be monitoring the program very carefully in the months ahead because of the recordkeeping requirements."
One part of her program that Kram said has proven to be quite effective is the practice of conducting hearing tests on site at the larger plants. Doing this means less lost time for the company and cuts down on the number of inaccurate tests. Kram said that, with onsite testing, any time an STS of 10 or more is detected, the worker can be re-tested at once to confirm the result.
Because an STS of 10 now means an OSHA recordable, making sure the audiometric test is accurate is more important than ever.