The Audiologist's Role in Hearing Conservation



Author: David Mayou

Audiologists traditionally receive referrals for their hearing-aid fitting practice from two principal sources: 1) existing patients that refer family members and friends and 2) otolaryngologists that refer patients to be fitted for hearing aids. Some of the referrals that otolaryngologists send to audiologists are actually patients whose hearing issue was originally identified through an OSHA-required Hearing Conservation program. OSHA’s Occupational Noise Standard (29 CFR 1910.95) dictates that employers that have work areas with noise levels above 85 dBA TWA (Time Weighted Average) must implement a hearing conservation program. But as a general rule, audiologists steer clear of advising manufacturers on setting up and implementing such a program.

I believe that this common reluctance is worth challenging. Many small manufacturers are looking for assistance in implementing hearing conservation programs and the safety managers at these companies would react quite favorably to advice and guidance from an audiologist they could trust with their employees’ medical needs, including hearing-aid fitting. In that case, why make the manufacturer find you when you could find the manufacturer? Audiologists who cater to manufacturers’ OSHA-required hearing conservation needs stand a much greater chance of ultimately receiving referred patients from that business than if they simply hope the patient discovers their practice by some happy accident or coincidence.

This unnecessary disinclination to tackle hearing conservation puts audiologists in the position of reactively waiting for referrals from otolaryngologists who are unaware of an existing relationship the company may have with the audiologist. Offering to assist manufacturers with setting-up and implementing a hearing conservation program may be all it takes for these same companies to refer patients directly back to the audiologist after the patients are properly referred by the otolaryngologist. Hopefully, as an audiologist, you are convinced that working with manufacturers to set-up and implement hearing conservation programs is worth your while. I firmly believe that it is not only worth your effort, but a welcome service many manufacturers would happily seek out and truly value.

Now for the fun part. Working with the manufacturer to set-up the hearing conservation program is not as difficult as it seems once you are armed with some basic information about how to do so following OSHA’s guidelines. There are five component parts of a successful OSHA-required Hearing Conservation program: 1) Noise Monitoring 2) Audiometry 3) Hearing Protection 4) Training 5) Recordkeeping. I will discuss all five of these elements illustrating that setting up a hearing conservation program is not as difficult as it may seem for any audiologist looking to successfully market his or her practice.

Noise Monitoring
OSHA requires manufacturers to perform noise monitoring when employee noise exposure “may equal or exceed an 8-hour time-weighted average (TWA) of 85 dB.” There are two principal methods of monitoring noise levels. The first is called area noise sampling. Using a sound level meter, take a general measurement of each section of your facility. These measurements can be documented in a noise map showing the exposures of each area. This is quite accurate when noise levels are steady.

The second method is personal noise sampling, commonly known as dosimetry. The employee wears a dosimeter, an electronic device including a microphone mounted near the ear. The dosimeter records an employee’s complete noise exposure over an extended period of time and determines the time-weighted average. It is not required that every single employee participates in this measurement; however, a representative sample of employees should be included. This method is very effective when noise levels vary in a specific work area.

As a general rule, noise levels should be re-monitored and updated whenever a substantive change in the noise area has occurred. Employees should be informed about changes in noise level throughout the work area. Each employee should also have his or her TWA noise exposure recorded in company records so that the audiologist can accurately interpret the employee’s personal audiogram as well as for OSHA compliance.

Audiometry
OSHA requires an initial baseline audiogram for each employee with subsequent annual audiometric tests. These tests must be performed for all employees exposed to 85 dBA TWA within six months of first exposure to determine current hearing levels. Testing must be performed by a professional or a qualified technician. These requirements include both new hires and existing employees. If the annual audiogram demonstrates a shift in hearing of 10dB average or more at 2000, 3000 and 4000 Hz in either ear compared to baseline (known as STS), the employee must be notified in writing within 21 days. If the loss is determined to be occupational, the employer must evaluate the employee’s current hearing protectors and retrain the employee on both use and fit. As an audiologist, you are responsible for evaluating problem audiograms and revising baselines in the case of a persistent STS, or significant improvement in the thresholds.

It is important to make certain that your testing service provides the required comparison to baseline with reports that can be easily understood by the employee and with clear notification of STS to the employee. It has been proven that sitting down with the employee and clearly communicating audiometric results immediately has a positive impact on the employee in question and promotes a healthy hearing culture in the workplace that incentivizes employees to protect their hearing both at work and at home.

Hearing Protection
OSHA mandates that “a variety of suitable hearing protectors” be made available at no cost to employees exposed to an “8-hour time-weighted noise level of 85 dB.” So if your facility has an area that meets this description, hearing protectors must be made available at the cost of the company. Typically, these hearing protectors are earplugs and/or ear muffs. The permissible exposure limit is 90 dBA TWA. Hearing protectors are required to be worn by employees who work in areas where noise levels exceed 90 dBA TWA. Those who work in areas where noise levels exceed this limit must wear hearing protection. Employees that have a significant shift in hearing should be retrained and refitted with hearing protectors and are required to use them for noise exposures above the 85 dB action level.

As a general rule, manufacturers should offer at least three different types of hearing protectors to accommodate the unique needs of their employees—one style of protection may not work for everyone. Effective fit of hearing protectors can be measured in the field. Verify the protection your employees obtain and recheck their Personal Attenuation Rating (PAR) at least annually to ensure proper protection. Hearing protection should be easily available throughout different parts of the company. Recognizing—and praising—employees who wear hearing protection in the workplace encourages other employees to do the same. Once again, this creates a positive hearing culture.

Training
OSHA requires that manufacturers provide annual hearing conservation training to all workers exposed to noise levels at or above the action level (85 dBA TWA). Annual training must include the effects of noise on hearing. In addition, all employees in the hearing conservation program must be educated about different types of earplugs and earmuffs. Ideally, instruction includes guidance about how to select the most appropriate protector and how to properly fit the device. Annual training should also cover the purpose of audiometric testing and an explanation of the test procedures. Many of the training aids used in a good hearing conservation program include: group and individual presentations, computerized training modules and outside speakers. Also, research has documented that individual training is more effective than group training. Hanging motivational and educational posters near hearing protection dispensers is very helpful in keeping employees interested in participating in the program and, ultimately, protects their long-term hearing health.

Recordkeeping
Manufacturers must follow certain guidelines for document retention. Area and personal sound measurements must be kept on file for at least two years. Audiometric records of employees must be kept for the duration of their employment. According to OSHA Form 300, employers must record all employees who 1) demonstrate a Standard Threshold Shift in hearing in one or both ears and 2) demonstrate average hearing levels over 25 dB above audiometric zero in the same ears as the STS. All records may be accessed upon request by “employees, former employees, representatives designated by the individual employee and OSHA representatives. If the employer ceases operations or is acquired by another company, all records must be transferred to the subsequent organization for the required periods of time.

Make sure your testing service provides understandable follow-up reports. Manufacturers are also required to post a copy of regulation OSHA 29 CFR 1910.95 in a visible location within a facility.

Resources
The following organizations are dedicated to the training and education of professionals involved with hearing conservation programs. The Council for Accreditation in Occupational Hearing Conservation (www.caohc.org) offers training courses for professional supervisors and audiometric technicians. The National Hearing Conservation association (www.hearing conservation.org) is a membership organization of hundreds of top-tier hearing conservation professionals. Both organizations have a wealth of materials and educational opportunities for audiologists interested in the hearing conservation field.

Clearly, there are a number of details involved in implementing a hearing conservation program for a manufacturer as mandated by OSHA. With that said, however, it is reasonable and fair for virtually any audiologist to assist a manufacturer in establishing such a program. The traditional alternative of sitting back and waiting for referrals pales in comparison to the strategy of making oneself available to manufacturers who are required by law to pursue and successfully implement such a program. The safety managers employed by these manufacturers need all the help they can get. Imagine helping a local safety manager get set-up and then being rewarded with a flood of patients identified, within the Hearing Conservation program, and referred to your practice directly at the polite suggestion of the approving otolaryngologist and relieved safety manager. Your next problem may be hiring enough audiologists to keep up with the pace of steady referrals from this company. In the grand scheme of things, this is a welcome problem for any audiologist to have.    
David Mayou is Sales Manager for Benson Medical Instruments. He can be contacted at dmayou@bensonmedical.com.