NHCA Urges OSHA to Renew Focus on Noise Control

In a March 16 letter to OSHA, the National Hearing Conservation Association (NHCA) urged the agency to “renew its focus on noise control despite the current climate of economic adversity.”

OSHA withdrew its “Interpretation of OSHA’s Provisions for Feasible Administrative or Engineering Controls of Occupational Noise,” a proposal that would interpret guidelines emphasizing the use of engineering and administrative controls to mitigate occupational noise, in January. Some safety stakeholders expressed disappointment over this decision and suggested the withdrawal could have a negative impact on workers safety.

“The apparent reason for not enforcing the noise control requirements as specified in the original standard was the argument that a hearing conservation program could as effectively protect noise exposed workers at a much lower cost than designing and implementing noise control measures,” NHCA President Timothy Rink, Ph.D., wrote in the letter. “While an effective hearing conservation program may achieve this objective for some workers, a program designed to comply with the minimal requirements of the hearing conservation amendment to the noise standard may not.”

In the letter, NHCA outlined several advantages of noise control, including: the reduction of potential user error, negligence or deliberate non-compliance regarding the use of hearing protectors such as earplugs or earmuffs; improved hazard awareness and perception of safety alerts and warnings; reduction of the risk of life-altering hearing loss, tinnitus and other effects of excessive noise exposure; and the cost effectiveness of noise controls as a long-term strategy for addressing the hazard of excessive workplace noise.

“Consistent with other OSHA regulations, which stress the primacy of engineering controls in reducing the risks associated with chemical exposure, noise controls should also be foremost in the hierarchy of strategies to prevent occupational noise-induced hearing loss,” the letter explained. “OSHA’s intended return to an accurate definition of ‘feasible’ would have been a return to the original objective of the regulation by bringing the noise control regulation in line with other hazardous exposure regulations.”

Read NHCA’s letter to OSHA in its entirety here.

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