Hearing conservation in construction

April 1, 2005
/ Print / Reprints /
ShareMore
/ Text Size+
Many interested folks were disappointed — and others probably relieved — to see OSHA’s much-discussed rule covering hearing conservation programs for construction workers slip further down the regulatory ladder when the latest agenda for standards-setting was published. Specific hearing conservation measures for construction sites is now filed under “long-term actions.”

This “downgrading” becomes more perplexing if you review the transcript from OSHA’s October 2004 Advisory Committee on Construction Safety and Health’s (ACCSH) meeting. In October it seemed that the program was pushing forward.

Does this mean a slowdown in the rulemaking effort? Probably. In fact, OSHA’s news release scheduling the February 2005 ACCSH meeting did not even list hearing conservation as an agenda item.

What happened?

OSHA issued an Advanced Notice of Proposed Rulemaking (ANPRM) for a construction industry-oriented hearing conservation program in 2002. The notice included an invitation for comments and job site hearing program experiences. At the October 2004 ACCSH meeting, an OSHA representative discussed the comments that had been received and the difficult issues encountered by construction employers regarding efforts to protect workers’ hearing. These barriers are obviously proving hard for OSHA to overcome. From the ACCSH transcript, here are the issues OSHA cited as being the most difficult:

  • Audiometric testing is controversial.
  • Exposure monitoring can be difficult, not only to implement, but also to interpret for construction.
  • Hearing conservation programs are difficult to develop and monitor in construction because of the mobility of the workforce, high worker turnover, and job site variability.
  • Impact on small business is a major concern. OSHA needs to be sensitive to this concern.
  • Keeping it simple is an absolute must. Simple requirements and simple concepts are what works best in the construction industry.

Here are some facts OSHA discovered which might cause it to push forward with a proposed rule in the “long term”:

  • The use of hearing protection in the construction industry is not common.
  • Hearing loss occurs in construction at a high rate.
  • Complete hearing conservation programs, such as is required in general industry, are rare.


Continuing the effort

Although it seems that OSHA is slowing down the pace to promulgate a rule, at last October’s meeting it did outline steps being taken to address obstacles. For example, OSHA is:

  • Completing contract work to generate an industry profile and an exposure profile for the construction industry with respect to noise exposures.

  • Doing site visits to gather information on hearing conservation and monitoring programs to determine what is working and what is not.

  • Holding stakeholder meetings.

    What’s a contractor to do?

    In 1983, OSHA issued the Hearing Conservation Amendment (HCA) for general industry. The amendment added a requirement for employers to implement a hearing conservation program if employee noise exposures exceed a time-weighted average level (TWA) of 85 dBA over an eight-hour workday. At that time, OSHA stated it would develop a separate regulation for construction employees. Twenty-two years later, it has not happened.

    So what is missing from current construction provisions that a new regulation would require?

    The big issue is: The construction occupational noise exposure regulation, 29 CFR 1926.52, requires a hearing conservation program but does not tell the employer what should be in the program.

    The rule says: In all cases where the sound levels exceed the values shown in Table D-2, Permissible Noise Exposures, a continuing, effective hearing conservation program must be established.

    Interestingly, in an August 1992 “Letter of Interpretation” written in response to a question from the field, OSHA described what would constitute a good hearing conservation program for the construction industry under the requirements of 29 CFR 1926.52. That letter stated:

    “OSHA has determined that an effective hearing conservation program consists of the following elements:

    • Monitoring employee noise exposures.
    • Instituting engineering, work practice, and administrative controls for excessive noise.
    • Providing overexposed employees with individually fitted hearing protectors with adequate noise reduction ratings.
    • Implementing employee training and education regarding noise hazards and protection measures.
    • Establishing baseline and annual audiometry examinations.
    • Preventing further occupational hearing loss when the loss is identified.
    • Keeping proper records.

    “Every construction industry employer’s hearing conservation program must incorporate as many of these elements as are feasible.”

    Doing nothing is not an option

    In the interest of employee long-term hearing protection, construction employers need to do more than provide ear plugs. If you need a place to start, use the above OSHA suggestions as a guide and fill in the blanks using OSHA’s general industry requirements at 29 CFR 1910.95—Occupational Noise Exposure.

    Other good sources for occupational noise exposure information are: 1) OSHA’s Technical Manual (OTM), Section III, Chapter 5—Noise Measurement; and 2) the National Institute for Occupational Safety and Health’s Web site for Noise and Hearing Loss Prevention at: www.cdc.gov/niosh/topics/noise.

  • Did you enjoy this article? Click here to subscribe to ISHN.

    You must login or register in order to post a comment.

    Multimedia

    Videos

    Image Galleries

    Scenes from the World of Safety

    Sights, signs & symbols from the National Safety Congress & Expo held in San Diego, CA, September 15-18

    11/4/14 2:00 pm EST

    Eye Injuries: You rarely see them coming. Practical Solutions for reducing injuries to the eye.

    The 3M Eye Injury Reduction webinar will provide an examination of how to help solve eye injuries in the workplace. This issue continues to challenge virtually every industry, and the solution is often times multifaceted. 3M will share some new tools and approaches to help you in solving this issue.

    ISHN Magazine

    ISHN1014_cover.jpg

    2014 October

    This issue features articles about PPE safety and OSHA standards

    Table Of Contents Subscribe

    THE ISHN STORE

    M:\General Shared\__AEC Store Katie Z\AEC Store\Images\ISHN\safetyfourth.jpg
    Safety Engineering, 4th Edition

    A practical, solutions-driven reference, Safety Engineering, 4th edition, has been completely revised and updated to reflect many of today’s issues in safety.

    More Products

    For Distributors Only - SEPTEMBER 2014

    ISHN FDO SEPTEMBER 2014For Distributors Only is ISHN's niche brand standard-sized magazine supplement aimed at an audience of 2,000 U.S. distributors that sell safety products. Circulation only goes to distributors. CHECK OUT THE SEPTEMBER 2014 ISSUE OF FDO HERE

    STAY CONNECTED

    Facebook logo Twitter YouTubeLinkedIn Google + icon

    ishn infographics

    2012 US workplace deathsCheck out ISHN's new Infographic page! Learn more about worker safety through these interactive images. CLICK HERE to view the page.