In an April 28, 2009 letter to Jordan Barab, acting assistant secretary of labor for OSHA, American Industrial Hygiene Association President Lindsay E. Booher, CIH, CSP, pressed OSHA to take immediate action to lower the permissible exposure limit (PEL) for occupational noise exposure to 85 dBA (as an 8-hour time-weighted average) and to adopt the 3 dB exchange rate.

“AIHA strongly believes the 85 dBA limit and 3 dB exchange rates are appropriate for both the general industry and construction standards,” said Booher.

“One of the greatest challenges and concerns we now face in the United States is the hearing loss that is occurring in our workforce,” said Booher. “Over 30 million workers are exposed to hazardous levels of noise, and noise-induced hearing loss is one of the most common occupational diseases. Such hearing loss significantly affects the ability to communicate and negatively impacts a worker’s quality of life.

“We cannot wait any longer to address this issue,” said AIHA’s president.

According to Booher: “Review of the damage risk estimation upon which the current regulation is based indicates that even a currently compliant hearing conservation program i.e., one where workers are exposed up to 90 dBA TWA with no hearing protection, will yield up to 26 percent excess risk of material hearing impairment over the course of a working lifetime. It is unimaginable that any other regulated hazard would permit 20-30 percent of the exposed population to have material impairment. Lowering the PEL to 85 dBA would reduce the number of workers at risk by at least one-half.

“Many agencies and organizations in the U.S. have adopted an occupational exposure limit of 85 dBA, with a 3 dB exchange rate. Both the National Institute for Occupational Safety and Health (NIOSH) and the American Conference of Governmental Industrial Hygienists (ACGIH) have long recommended such exposure limits.

“The vast majority of the nations of the world regulate workers’ noise exposures at lower levels than the U.S. In fact, the U.S. is one of only two nations that still uses the 90 dBA PEL and is one of only three nations that uses the 5 dB exchange rate. As a result, American workers are allowed exposure to noise levels that would result in more hearing loss than the rest of the world.”

Booher concluded: “Lowering the PEL to 85 dBA may also streamline management of hearing conservation programs by adopting a single threshold trigger for all hearing loss prevention activity such as engineering controls, training, hearing protection, and hearing conservation programs. AIHA urges OSHA to take immediate action on this issue to ensure that American workers are afforded the same level of protection from hazardous noise that the majority of the world’s nations provide their workers.”