The hearing protection industry has invested millions of dollars in new technologies that significantly contribute to reducing the incidence of noise-induced hearing loss. This focus on “technologies” is in line with current thinking about personal protective equipment (PPE) in general, in which we are seeing a shift away from use of the term “equipment” to “personal protective technologies” (PPT), which more accurately portrays the breadth of innovation in worker protection products.

For example, NIOSH operates the “National Personal Protective Technology Laboratory.” Another example is the title of a report by the Institute of Medicine (IOM) issued November, 11, 2010: “Certifying Personal Protective Technologies: Improving Worker Safety.”

Here is the intro from the report: “Millions of workers in worksites across the United States rely on personal protective technologies (PPT) to guard against injury, illness, or death.

“For personal protective technologies (PPT) — where the major purpose of the product is to protect the wearer against a hazard — a deficit in product effectiveness can mean injury, illness, or death. Examining the extent to which products meet specific performance or design criteria is the focus of conformity assessment efforts. For PPT conformity assessment, the ultimate goal is preventing worker illness, injury, or death from hazardous working conditions.

“In 2009, the National Institute for Occupational Safety and Health (NIOSH) requested that the Institute of Medicine convene an expert committee to assess the certification or conformity assessment mechanisms needed to ensure the efficacy and effectiveness of non-respirator PPT.

You will see increasing references to PPT: respirators, healthcare worker PPT, firefighter and emergency responder PPT, ballistic-resistant body armor, hearing protective devices, and personal flotation devices, among other types.

The IOM report issued this recommendation regarding the assessment of PPT conformity to standards: “(NIOSH) should work with other relevant government agencies, certifying and accrediting organizations, manufacturers, and end users to develop, implement, and support conformity assessment processes for non-respirator PPT. These conformity assessment processes should be commensurate with the level of risk of injury, illness, or death that could result from failure of the PPT to protect the user from workplace hazards.

PPT conformity assessment

NIOSH, NPPTL announced May 18, 2011, the availability of the PPT (Personal Protective Technologies) Conformity Assessment Docket, NIOSH Docket 237, and solicits input from interested parties. The docket is being established to provide interested parties the opportunity to provide input to the NIOSH, NPPTL strategy to address the recommendations issued in November 2010 by the Institute of Medicine (IOM) in its report Certifying Personal Protective Technologies: Improving Worker Safety. The report focuses on the need for a consistent risk-based approach to PPT conformity assessment. This docket will be available until July 1, 2011. All comments will be assessed as part of the effort to address the IOM recommendations.

Near-term strategy

NIOSH, NPPTL intends to implement a multi-year strategy to address Recommendation 1 of the IOM report to develop and implement risk-based conformity assessment processes for non-respirator PPT. The impacts of non-compliance (consequences of failure to provide the expected protection) are best described in terms of their potential risk to the user and the independence and rigor of conformity assessment. This relationship is described in Gordon Gillerman’s Making the Confidence Connection published in ASTM Standardization News (2004).

Timeline to address recommendation

The timeline to address Recommendation 1 includes, but is not limited to the following activities conducted over a two year time period:
  1. Defining the standards to be included in the process;
  2. Identifying the PPE on the market which complies with current standards;
  3. Finalizing the conformity assessment terminology to be used in the effort;
  4. Defining low, medium, and high levels of risk;
  5. Assessing available sources (e.g. surveillance data) to document the risks of the PPE not working properly and the risks of noncompliance;
  6. Defining the level of conformity assessment, including configuration management, required for each level of risk; and
  7. Defining the types of PPE to be included in the framework to include those required by regulation, those desired by the user, and those that respond to specific health and safety needs in the marketplace.
NIOSH, NPPTL will develop a draft risk-based strategy and solicit public comment on the strategy. NIOSH, NPPTL will conduct face-to-face and virtual public meetings to discuss the PPT conformity assessment strategy during the strategy development process. The proposed strategy will be published and is expected to serve as a reference for standards development organizations.