In response to the recent announcement of the impending change to the Noise Reduction Rating (NRR) for hearing protection devices, the National Hearing Conservation Association (NHCA) has provided its recommendations to EPA. Based on expert member input and review, NHCA’s recommendations are intended to improve the utility of hearing protection devices for occupational hearing conservation programs and for personal use.
"Noise-induced hearing loss is a progressive and permanent disease which has a pervasive impact on people's lives. While noise control efforts are the preferred way to reduce occupational and community noise exposures and prevent hearing loss, many Americans depend on earplugs and earmuffs to protect their hearing,” said Rick Neitzel, PhD, CIH, NHCA President. “The current Noise Reduction Rating methodology is obsolete and needs to be updated to reflect a more real-world approach to hearing conservation. Also, the new NRR needs to account for the fact hearing protectors are used both in the workplace, where users should be trained on how to protect their hearing and how to wear protectors correctly, as well as recreationally, where users are likely to be less knowledgeable about how to best protect their hearing.”
In its letter, NHCA asks for two major changes to the EPA’s proposed legislation.
First, NHCA believes that the labeled values should be based on the ANSI S12.6-2008 Method B protocol, which accounts for hearing protectors fit by trained and naïve hearing protection device (HPD) users alike.
“The EPA should also ensure that the de-rating of labeled values is eliminated from the new NRR scheme. Over the years, de-ratings have created a great deal of uncertainty and confusion that has diminished the effectiveness of hearing loss prevention programs in the United States,” said Neitzel.
Second, NHCA urges the EPA to revise and simplify the labeling of hearing protectors. This will help ensure that all users – and especially users who have not been trained on the proper use of hearing protectors – receive adequate protection when they use the devices.
“The required labels should be simplified, made more symbol-based, and provided in multiple languages to ensure that their correct use is clear for all users,” said Neitzel. “Supporting information, such as the performance of the protector at specific test frequencies, should be provided online, as a packaged insert or upon request from the manufacturer in order to further simplify package labeling.”
Hearing experts to EPA: Eliminate de-rating from new NRR scheme (12/16)
December 16, 2009