Bruce Kirchner, MD, MPH, CPS/A
When Deanna Meinke, Laurie Wells and I wrote a short CAOHC Update article in 2005 called “Bringing CAOHC to Procter & Gamble, Europe,” I noted the challenges that P&G experienced in delivering CAOHC certification to Europe. Since then, gaining from our international experiences, we at P&G have expanded upon this and now have trained site health care providers at all of our plants and technical centers around the world.
How did we do it? Here a few principles that helped us move in that direction.
P&G’s hearing conservation program has traditionally used the federal Occupational Health and Safety Administration (OSHA) regulation 29 CFR 1910.95 as the basis of the program. The OSHA regulations, along with some good practice advice from the federal National Institute for Occupational Safety and Health (NIOSH) and other sources from around the world, were then put together to produce our corporate standards. These standards are deployed through a global network of regional medical and safety leaders to site noise control and occupational hearing conservationists.
These P&G safety and medical standards are expected to be followed at all P&G sites where employees are exposed to excessive noise. We attempt to keep up with the hearing conservation literature in order to adjust our program standards. For example, we had previously followed the OSHA 90 dB threshold for wearing hearing protection, but moved to NIOSH’s more conservative threshold. We now use an 85 dB damagerisk criterion and have adopted the more conservative 3 dB exchange rate, instead of the 5 dB value commonly used across industry. Periodic auditing is conducted to ensure compliance with program standards. All site managers are held accountable for results and are expected to develop action plans to address opportunity areas.
Quality training of all personnel performing workplace audiometry has always been a key requirement. Proctor and Gamble employees, including any contractors used to administer audiometric testing, receive advanced audiometric training. CAOHC has traditionally been our training platform in the United States, as well as in Canada. In the rest of the globe, where ongoing CAOHC training was not available, our standard stated that training “equivalent to CAOHC” was to be used. However, subsequent audits demonstrated that this requirement was not being met. In many situations, the only training the audiometric testing technician received was from the supplier of the audiometer. Not only were some of the audiometers of poor quality, but the training was equally suspect. In other locations, such as in Western Europe, educational classes were available, but they were not comprehensive enough to meet our “CAOHC equivalent” requirement. Casual review of audiometric tests during audits demonstrated issues with quality. We felt that we were doing our employees a disfavor and needed to standardize training by providing CAOHC training to all of our audiometric testing technicians.
In order to provide CAOHC training, we used several models to accomplish our goals. Although U.S.-based CAOHC Course Directors provide most of the training, the medical leader in our Central and South American region gained CAOHC approval as a Course Director. This has worked well, because that indvidual can provide training in Spanish to P&G health care providers residing in sites located in most of the major countries in South and Central America. Even in Brazil, where Portuguese is spoken, there is enough language similarity to allow Spanish to be used. CAOHC training is usually done in conjunction with periodic regional medical meetings at which P&G-specific medical issues are discussed, as well as with other training, such as pulmonary function spirometry education. Training is being conducted on a one- to three-year repetitive basis, allowing for recertification as well as initial training of new audiometric technicians.
It is not easy to obtain funding to provide for these meetings and training! It never is in the corporate world where all initiatives and trainings must be fully justified as to the connection to the bottom line. However, if the corporate culture states that people are your most important asset and you can show that there are many quality of life and safety reasons for conducting quality hearing conservation programs, the task becomes somewhat easier. As time goes by, training then becomes an expected part of doing business.
The journey to provide CAOHC training internationally has gone from North America to Western Europe to Central and Eastern Europe to Africa, then on to Latin America and now to Asia. Now that CAOHC training has been conducted during the past two years in China and India – two of P&G’s fastest growing markets – P&G now has attained the goal of establishing and maintaining the quality audiometric testing standard that we had sought. We have trained and certified audiometric testing technicians providing support to the roughly 150 manufacturing and research centers around the world.
Through recent reports and audits, it is clear that the quality of testing has dramatically improved. Many of the CAOHC-trained individuals have become responsible for parts of or all of the manufacturing site’s entire hearing conservation program. This is because CAOHC has provided them with a holistic vision of how the various components of an effective hearing preservation program should work together on behalf of the noise-exposed employee.
Besides the general employee benefits of training, our health care providers have really valued the educational experience. In many countries, occupational health training of this quality is not available. The CAOHC certificate has become much valued by the testing technician and is proudly displayed right next to the testing booth. In a company where internal skill-based certifications are needed by manufacturing workers for assignment broadening and potential career advancement, health care personnel can demonstrate how their audiometric testing skills also contribute to meeting their site’s business needs. The CAOHC-trained health care practitioners are respected by the rank and file and are trusted to be advocates for preserving their hearing.
CAOHC is truly the “gold standard.” There is no other organization in the world that delivers the quality knowledge and skill-based training needed to meet the demands of business and the hearing health of the noise-exposed employees.