ASSE previously sent OSHA a letter opposing the agency’s Interpretation of Provisions for Feasible Administrative or Engineering Controls of Occupational Noise. The current OSHA standard calls for employers to use administrative or engineering controls rather than personal protective equipment (PPE) to reduce noise exposures that are above acceptable levels when such controls are feasible. OSHA is revising its current enforcement policy to reflect this interpretation. Noise intensity is measured in dBA and time of exposure to noise is measured in hours and minutes.
In a letter this week to OSHA Administrator David Michaels, ASSE President Terrie S. Norris, CSP, ARM, CSPI, said that a more valuable measure to reduce noise exposures for workers would be to lower OSHA’s permissible exposure limit (PEL) for noise from 90 dBA (decibel) to 85 dBA.
“We urge OSHA to focus its efforts on achieving a more effective measure to protect workers from hearing loss that, if taken, would make it much more important that OSHA carefully consider any future effort to pursue the proposed change in its economic feasibility interpretation,” wrote Norris. “Our members believe to help reduce noise exposures to employees it would be best to lower OSHA’s PELs from 90 dBA with a 5 dBA exchange rate to 85 dBA with a 3 dBA exchange rate for all workers for an eight hour day. This is a widely accepted practice among our members.”
Norris noted that in the relatively small number of workplaces where economic feasibility is a pressing issue, engineering controls become exponentially more expensive and difficult to achieve for some employers. In such situations, Norris noted, there will be employers who now adequately protect workers from noise with PPE but, if pressed to invest in engineering controls on old equipment, would find it more difficult to keep a workplace in business.
At the lower PEL, engineering controls can become more expensive and difficult to achieve, adding to the reasons OSHA should not pursue a new economic feasibility interpretation, Norris said. ASSE also urged OSHA to communicate more widely its stated practice of working cooperatively with employers to achieve incremental improvement in noise levels over reasonable periods of time.
“Instead of trying to make more difficult an already tough decision for some employers, ASSE urges OSHA to focus on the overall gains that can be made in a lower PEL for noise,” Norris said.