700,000 at-risk construction workers need OSHA hearing conservation standard, urges AIHA (4/1)
The American Industrial Hygiene Association has staked out a position urging OSHA to move ahead with a standard on hearing conservation programs for construction workers.
AIHA made the same request in a letter to OSHA four and a half years ago.
In a March 30 letter to OSHA chief Dr. David Michaels, AIHA President Cathy L. Cole, CIH, CSP wrote: “While technological change and a growing body of research and practice demonstrate even more clearly that a hearing conservation standard for construction workers is practical and necessary, OSHA has in essence not moved on this issue in this time period.
“ndeed, for over 26 years construction workers have not been afforded the same legal protections from hearing loss as their industrial counterparts. Over 700,000 workers are at risk and many lose significant hearing after only 10-15 years on the job.”
According to AIHA, as of December 2009 this issue remains relegated to ‘Long-Term Actions’ on the OSHA agenda, “essentially removed from consideration at this time, with no timetable set for any additional consideration,” writes Cole.
“Many workers on construction sites are exposed to noise at levels likely to result in hearing loss, and hearing loss is common among long-term construction workers. OSHA should develop a regulation addressing hearing conservation on construction sites using consensus standards and demonstrated good practices. The ANSI A10.46-2007 standard has been accepted nationally by broad sections of the construction industry for two years now, and the acceptance of the Washington state construction hearing construction regulation by the construction industry in that state has demonstrated that employers are willing and able to adopt the practices required by that regulation.
“We encourage OSHA to look at worker exposure assessment/compliance methods similar to the Lead in Construction Standard and the draft Silica standard. In both of these cases, specific job tasks are listed along with specific protection that must be provided to the worker at the start of the job unless there are historical empirical data to show otherwise. The employer then has the option to use traditional IH exposure assessments to provide data demonstrating that a lower level of protection is adequate.
“We encourage OSHA to aggressively enforce its existing construction noise standard. Noise is the most common occupational health hazard, but it isn't even on the top 10 list of OSHA violations. In FY 2007, more than 17,000 construction inspections resulted in only 27 OSHA noise violations being cited. Citations for the weak current construction hearing conservation provision, 1926.52(d)(1) are even rarer, with only an annual average of 14 such citations recorded for the entire period of 2005 through 2009. Enforcement should consider approaches such as citing where the same work task is conducted for the entire day and limited measurements indicate exposures greatly exceeding levels associated with TWA exposures >90 dBA. Lack of protective equipment availability and enforcement for such tasks could and should be considered presumptive evidence of violations.
“Although engineering and administrative noise controls are the preferred strategy for exposure reduction, use of HPDs to prevent hearing loss on construction sites is often unavoidable. An effective HPD program must exhibit these characteristics:
“We respectfully request OSHA to begin efforts to move expeditiously forward on a hearing conservation standard for construction. As a first step in this process, we urge OSHA to publish a proposed rule in 2010,” concludes AIHA President Cole’s letter to Dr. Michaels.
AIHA made the same request in a letter to OSHA four and a half years ago.
In a March 30 letter to OSHA chief Dr. David Michaels, AIHA President Cathy L. Cole, CIH, CSP wrote: “While technological change and a growing body of research and practice demonstrate even more clearly that a hearing conservation standard for construction workers is practical and necessary, OSHA has in essence not moved on this issue in this time period.
“ndeed, for over 26 years construction workers have not been afforded the same legal protections from hearing loss as their industrial counterparts. Over 700,000 workers are at risk and many lose significant hearing after only 10-15 years on the job.”
According to AIHA, as of December 2009 this issue remains relegated to ‘Long-Term Actions’ on the OSHA agenda, “essentially removed from consideration at this time, with no timetable set for any additional consideration,” writes Cole.
“Many workers on construction sites are exposed to noise at levels likely to result in hearing loss, and hearing loss is common among long-term construction workers. OSHA should develop a regulation addressing hearing conservation on construction sites using consensus standards and demonstrated good practices. The ANSI A10.46-2007 standard has been accepted nationally by broad sections of the construction industry for two years now, and the acceptance of the Washington state construction hearing construction regulation by the construction industry in that state has demonstrated that employers are willing and able to adopt the practices required by that regulation.
“We encourage OSHA to look at worker exposure assessment/compliance methods similar to the Lead in Construction Standard and the draft Silica standard. In both of these cases, specific job tasks are listed along with specific protection that must be provided to the worker at the start of the job unless there are historical empirical data to show otherwise. The employer then has the option to use traditional IH exposure assessments to provide data demonstrating that a lower level of protection is adequate.
“We encourage OSHA to aggressively enforce its existing construction noise standard. Noise is the most common occupational health hazard, but it isn't even on the top 10 list of OSHA violations. In FY 2007, more than 17,000 construction inspections resulted in only 27 OSHA noise violations being cited. Citations for the weak current construction hearing conservation provision, 1926.52(d)(1) are even rarer, with only an annual average of 14 such citations recorded for the entire period of 2005 through 2009. Enforcement should consider approaches such as citing where the same work task is conducted for the entire day and limited measurements indicate exposures greatly exceeding levels associated with TWA exposures >90 dBA. Lack of protective equipment availability and enforcement for such tasks could and should be considered presumptive evidence of violations.
“Although engineering and administrative noise controls are the preferred strategy for exposure reduction, use of HPDs to prevent hearing loss on construction sites is often unavoidable. An effective HPD program must exhibit these characteristics:
- HPDs must be readily available on the jobsite.
- HPDs must be appropriate for the designated use. Because HPD use can be a barrier to essential auditory communication, HPDs must be selected based on exposure, task, and need. HPDs with frequency attenuation characteristics that allow better verbal communication are now available. Workers must be given a choice of several HPDs to achieve one with the best fit.
- Users must be trained on effective HPD use. All employees expected to use hearing protection devices should receive training on correct use and care.
- The HPD selected for use must be well accepted by users and be comfortable.
“We respectfully request OSHA to begin efforts to move expeditiously forward on a hearing conservation standard for construction. As a first step in this process, we urge OSHA to publish a proposed rule in 2010,” concludes AIHA President Cole’s letter to Dr. Michaels.
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