CAOHC | UPDATE: Volume 15 - Issue 3

Letter to the Editor

Dear Editor,

I am an OSHA compliance Industrial Hygienist and conduct many investigations to determine compliance with the OSHA Noise Standard. It appears to me that the articles by Susan Megerson involving recording hearing loss on the Form 300 may have erroneous information. Specifically, in Volume 15 - Issue 1, "Amendments to OSHA's Final Rule for Recording Occupational Hearing Loss", Table 1: Example Protocol for Determining STS Recordability, Step 4, Ms. Megerson asks "Has a qualified health care professional determined that the shift in hearing is more likely than not work-related?" If no health care provider is involved with the process (which is typically the case) then there will be no Yes to the question and the STS would not be recordable. According to Ms. Megerson, a health care provider must confirm the STS to be valid and recordable. I do not believe this is correct.

Harvey Johnson, CIH
Michigan

Editor's Note: This response from the author, Ms. Megerson, will also appear iin the Fall 2003 UPDATE newsletter being released in late October 2003.

Dear Mr. Johnson,

Thank you for your comments on this potentially confusing portion of my recent articles regarding 1904.10. As you know, OSHA requires professional review of problem audiograms under the Noise Standard, 1910.95. The table incorporated in my UPDATE articles was intended to provide only a simplified summary of a more complicated review process within the context of an effective, and compliant, hearing conservation program. It had not occurred to me that the guidance in the table could be misconstrued to suggest that a company could avoid recording work-related STSs simply by neglecting to have their audiograms professionally reviewed. I certainly agree with you that if the cause of a potentially recordable STS is inconclusive or undetermined, the company should accept work-relatedness by default and record the case. For a more detailed discussion on the topic, readers may wish to refer to the original article in the series: Megerson, S. C. (2002). OSHA's Final Rule for Recording Occupational Hearing Loss, CAOHC UPDATE, 14(3), 1, 3, 10.

Susan C. Megerson, MA CCC-A
The University of Kansas
Intercampus Program in Communicative Disorders

	Search \| Home
	UPDATE: Volume 15 - Issue 3 - Fall 2003

printer-friendly version Letter to the Editor Dear Editor, I am an OSHA compliance Industrial Hygienist and conduct many investigations to determine compliance with the OSHA Noise Standard. It appears to me that the articles by Susan Megerson involving recording hearing loss on the Form 300 may have erroneous information. Specifically, in Volume 15 - Issue 1, "Amendments to OSHA's Final Rule for Recording Occupational Hearing Loss", Table 1: Example Protocol for Determining STS Recordability, Step 4, Ms. Megerson asks "Has a qualified health care professional determined that the shift in hearing is more likely than not work-related?" If no health care provider is involved with the process (which is typically the case) then there will be no Yes to the question and the STS would not be recordable. According to Ms. Megerson, a health care provider must confirm the STS to be valid and recordable. I do not believe this is correct. Harvey Johnson, CIH Michigan Editor's Note: This response from the author, Ms. Megerson, will also appear iin the Fall 2003 UPDATE newsletter being released in late October 2003. Dear Mr. Johnson, Thank you for your comments on this potentially confusing portion of my recent articles regarding 1904.10. As you know, OSHA requires professional review of problem audiograms under the Noise Standard, 1910.95. The table incorporated in my UPDATE articles was intended to provide only a simplified summary of a more complicated review process within the context of an effective, and compliant, hearing conservation program. It had not occurred to me that the guidance in the table could be misconstrued to suggest that a company could avoid recording work-related STSs simply by neglecting to have their audiograms professionally reviewed. I certainly agree with you that if the cause of a potentially recordable STS is inconclusive or undetermined, the company should accept work-relatedness by default and record the case. For a more detailed discussion on the topic, readers may wish to refer to the original article in the series: Megerson, S. C. (2002). OSHA's Final Rule for Recording Occupational Hearing Loss, CAOHC UPDATE, 14(3), 1, 3, 10. Susan C. Megerson, MA CCC-A The University of Kansas Intercampus Program in Communicative Disorders