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Effective Hearing Conservation Program Elements

Quick Tips #260

Occupational noise exposure is the most significant health hazard present in the modern industrial workplace. Not only does it impact employees who have suffered permanent hearing loss due to unsafe levels of industrial noise, it also takes a huge bite out of the pocketbooks of employers who must financially compensate affected workers.

According to the Third Edition of Fundamentals Of Industrial Hygiene, published by the National Safety Council, an estimated 1.7 million workers in the U.S. between 50 and 59 years of age have compensable noise-induced hearing loss. Assuming an average claim amounts to $3,000, if only 10 percent of those workers filed for compensation, the potential cost to industry could exceed $500 million.

The serious consequences of industrial noise have not been lost on the Occupational Safety and Health Administration (OSHA). In March of 1983, OSHA incorporated the Hearing Conservation Amendment (HCA) into its existing occupational noise exposure standard, which had been enforced since 1974. The occupational noise exposure standard is located in 29 CFR 1910.95.

Occupational Noise Exposure Standard

As OSHA standards go, the occupational noise exposure standard is a relatively user-friendly document. It's extremely thorough, thus eliminating much of the reader interpretation that most standards require.

The standard essentially implements a three-pronged approach to addressing industrial noise. The basic components are recognition, evaluation and control. Additionally, training and record keeping are used to support each of the standard's basic components. The importance of these elements cannot be underestimated.


Before determining whether an employee is being exposed to an unsafe level of noise,  the level of noise must first be quantified. OSHA identifies 90 decibels (dB) based on an eight-hour time-weighted average (TWA) as the absolute "safe" level of noise exposure. This 90dB concentration is referred to as the OSHA permissible exposure limit (PEL) for noise exposure. Any eight-hour time-weighted average exceeding 90dB requires the employer to implement control measures to reduce the exposure to 90dB or below.

In addition to the 90dB PEL, OSHA also recognizes an 85dB time-weighted average as its action level. The action level was established in the 1983 Hearing Conservation Amendment. While employee exposure to the action level does not force an employer to take measures to reduce employee noise exposure, it does require the employer to establish a hearing conservation program. The Hearing Conservation Amendment defines a hearing conservation program in detail. It mandates that the employer conduct noise exposure monitoring, perform audiometric testing on employees, provide hearing protection to employees who request it, conduct employee training and retain records of the aforementioned activities.

Noise Level Monitoring

Under 29 CFR 1910.95(d), OSHA states noise levels must be monitored, "When information indicates that any employee's exposure may equal or exceed an eight-hour time-weighted average of 85 decibels." As a general rule of thumb, if an individual's voice must be raised to converse at a distance of three feet, the noise level probably exceeds 85dB. At the very least, this is an indication that monitoring should be conducted.

Two basic types of instruments are available to monitor noise levels: sound level meters and noise dosimeters. Both instruments measure in decibels. It's important to note that decibels are not linear units like feet or pounds. The decibel is a dimensionless unit that expresses a logarithmic ratio to an established reference level. To put the decibel into perspective, remember that while a reading of 10 decibels is 10 times greater than one decibel, a reading of 20 decibels is 100 times greater (10 x 10) than one, and a reading of 30 decibels is 1000 times greater (10 x 10 x 10). This logarithmic ratio is similar to the Richter scale used to measure earthquakes.

Both sound level meters and noise dosimeters are usually capable of measuring decibels in two or three different frequency scales. Frequency refers to the number of vibrations per second a noise contains; it is measured in hertz (Hz). The frequency scales are known as the A scale, the B scale and the C scale. OSHA requires that noise measurements be conducted using the A scale, which most closely resembles the human ear.

Sound level meters are direct reading instruments that provide a "snap shot" measurement of noise levels at a particular time. They do not average noise levels to provide the eight-hour time-weighted average on which OSHA bases its exposure levels. Because of this, sound level meters are most appropriate for preliminary noise surveys to determine if any work areas exceed the 85dB action level. If these areas are identified, then a noise dosimeter can be used to determine an employee's time-weighted average exposure.

Noise dosimeters are physically worn by employees for an entire work shift in order to record exposure levels. These levels are used to calculate an employee's time-weighted average exposure.

In terms of calibrating these instruments, the OSHA standard is very vague. It states the instruments, "shall be calibrated to ensure measurement accuracy" (29 CFR 1910.95(d)(2)(ii)). For more specific guidance concerning calibration, refer to the manufacturer's instructions for the instrument.

After the initial noise monitoring, OSHA requires that additional monitoring be performed whenever there is a change in the production process that may increase noise exposure. It is also required that the employer document all noise exposure measurements and retain these records for at least two years.

Should the noise level monitoring determine that employees are being subjected to levels equaling or exceeding the 85dB action level, the next step is to establish an audiometric testing program for those exposed. In addition, the employer must provide hearing protectors (earmuffs, ear plugs) at no cost and institute a training program for all affected employees. According to OSHA, the training program must be conducted annually and ensure that the employees are informed of, "The effects of noise on hearing; the purpose of hearing protectors; the advantages, disadvantages, and attenuation of various types of hearing protectors; instructions on their selection, fitting, use and care; the purpose of audiometric testing; and an explanation of the test procedures."


The backbone of the employee evaluation is the audiometric test. This is more commonly referred to as a hearing test. Under 29 CFR 1910.95(g), OSHA details the requirements of an audiometric testing program.

An audiometric testing program is comprised of two types of tests, or audiograms: baseline and annual. Audiograms are used to document an employee's hearing level. The baseline audiogram must be conducted within six months of confirmation of an exposure equal to or exceeding the 85dB action level. It establishes a reference point to which future annual audiograms can be compared. The initial annual audiogram must be conducted within one year of the baseline. Subsequent annual audiograms must be performed yearly thereafter.

By comparing the annual audiogram to the baseline audiogram, an employer can evaluate whether an employee has experienced any recordable hearing loss during this window of employment. This hearing loss is referred to in the OSHA standard as a standard threshold shift (STS). OSHA defines a standard threshold shift as, "a change in hearing threshold relative to the baseline audiogram of an average of 10dB or more at 2000, 3000, and 4000 Hz in either ear" (29 CFR 1910.95(g)(10)).

Should the audiogram results indicate an standard threshold shift has occurred, OSHA requires that the affected employee be fitted (or refitted) with hearing protectors, trained on the proper use of them and required to wear them. The employee must be informed of the standard threshold shift and may be referred for further audiometric testing.

When it comes to audiometric testing, OSHA is quite specific in terms of who can administer the test and the type of equipment that must be used. The criteria for those who can perform audiometric tests are referenced under 29 CFR 1910.95(g)(3). Basically, OSHA requires a licensed or certified audiologist or a technician who is certified by the Council of Accreditation in Occupational Hearing Conservation. 29 CFR 1910.95(h) gives detailed specifications for the instrumentation required for audiometric testing.

The employer is required to retain all of the audiometric test records for a given employee for the duration of the affected employee's employment. The specific guidelines for what must be included on these records are located under 29 CFR 1910.95(m)(2)(ii).


The final basic component of the OSHA standard involves controlling employee exposure to excessive noise levels. This element comes into play primarily when noise level monitoring indicates employee exposure levels are surpassing the 90dB PEL. 29 CFR 1910.95(b)(1) states that if the 90dB PEL is being exceeded, "feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of Table G-16 (90dB PEL), personal protective equipment shall be provided and used to reduce sound levels within the levels of the table."

The OSHA standard does not offer any guidance on appropriate administrative or engineering control measures. It does, however, thoroughly address the selection process for personal protective equipment.

Administrative controls are defined as, "Methods of controlling employee exposures by job rotation, work assignment, or time periods away from the hazard" (Fundamentals of Industrial Hygiene, Third Edition, published by National Safety Council, 1988). This can be accomplished by moving an employee from a job in a high-noise setting to a job in a low-noise setting. For example, if an employee worked in a 92dB environment, after six hours the individual would reach 100% of his daily time-weighted exposure. This same employee could work in the 92dB environment for five hours and then rotate to an 80dB location for the remaining three hours of the work shift and not exceed the 90dB time-weighted average PEL.

Engineering controls are defined as, "Methods of controlling employee exposures by modifying the source or reducing the quantity of contaminants released into the workroom environment" (Fundamentals of Industrial Hygiene, 3rd edition, published by National Safety Council, 1988). Examples of engineering controls include: isolating the source of the sound to eliminate or reduce employee exposure, installing noise-absorbing acoustical foam or baffles to capture and deaden reverberating noise, or, where possible, incorporating noise-reducing technology into the design of a piece of equipment or work area.

Personal protective equipment (PPE) is available in two basic formats: earmuffs, which fit over the entire external ear and seal against the side of the head, and ear plugs, which are inserted directly into the ear canal. In either format, hearing protectors will always have an assigned noise reduction rating (NRR). The NRR was developed by the Environmental Protection Agency (EPA) as a method of gauging the adequacy of a hearing protector's attenuation, or noise-reducing capacity. The EPA regulation requires that the NRR be printed on the packaging for each hearing protector.

In theory, the NRR of a hearing protector is the amount of decibels by which a given device will reduce noise exposure. If a worker exposed to a 100dB time-weighted average was assigned a pair of earmuffs with an NRR of 26, the 26dB would be subtracted from 100dB, leaving the worker with a 74dB time-weighted average exposure. It is important to note this calculation is true only if the original time-weighted average exposure (in this case the 100dB time-weighted average) was arrived at with a noise measuring instrument reading in the C scale.

When the A scale is used for the initial noise level monitoring, OSHA requires a slightly different adjustment: 7dB must first be subtracted from the hearing protector's NRR; this number is then subtracted from the time-weighted average exposure.

If the A scale had been used to record the above 100dB time-weighted average exposure, then 7dB must be subtracted from the hearing protector's 26dB NRR. This leaves a 19dB NRR. This number is then subtracted from the 100dB exposure, leaving the worker with a 81dB time-weighted average exposure. In either of the above examples, the worker would be well below the 90dB time-weighted average PEL.

OSHA also suggests using a 50 percent safety factor when performing either of the above adjustments. This 50 percent safety factor is suggested because the manufacturers' assigned NRRs are obtained under ideal conditions, in a laboratory setting. This environment is typically far different from the conditions under which the hearing protectors are being used. If the 50 percent safety factor were used in either of the above examples, the 26dB NRR of the hearing protector would have been immediately cut in half to a 13dB NRR. The respective calculations would then be performed, leaving the worker for the C scale example with an exposure of 87dB. In the A scale example the 50 percent safety factor is applied after the 7dB are subtracted from the NRR. This leaves the worker with a time-weighted average exposure of 90.5dB. This exceeds the OSHA PEL. Remember, OSHA only suggests using the 50 percent safety factor; they cannot issue citations based on the safety factor adjustment.

Occasionally, high-noise environments may necessitate using earmuffs and ear plugs in combination. When this is done, OSHA allows 5dB to be added to the greater of the two NRRs. This is added after all other adjustments are made. If ear plugs with an NRR of 21 were used in combination with the earmuffs in the above examples, five additional dB of protection would be added to each exposure. In the last example, this would bring the 90.5dB exposure down to 85.5dB. The worker's exposure would then drop below the PEL.

When it comes to hearing protectors, OSHA requires that employees be given the opportunity to select their hearing protectors from a variety of suitable options, and that the employer provides training on the use and care of the selected devices.


While the OSHA standard is comprehensive and relatively user friendly, OSHA does recognize that employers may need assistance in complying with the standard's requirements. To address this issue, a state-by-state OSHA Consultation Project Directory can be accessed on the OSHA website. The phone number for your state's OSHA Consultation Project can be found there.

29 CFR 1910.95, Occupational Noise Exposure

Fundamentals of Industrial Hygiene, 3rd edition, published by National Safety Council, 1988.

(Rev. 5/2014)

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Please Note:
The information contained in this publication is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This publication is not a substitute for review of the current applicable government regulations and standards specific to your location and business activity, and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney.

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