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CAOHC Newsletter: UPDATE

A Quick Checklist for Monitoring Your OHC Program

Barbara Panhorst-Lassiter, EdD RN COHN-S
CAOHC Representative of the American Association of Occupational Health Nurses

There aren’t enough hours in the day. How many times have you said this? For most of us, occupational hearing conservation is just one of the many responsibilities we have in our job. We want to perform well but are we remembering everything?

The Noise Standard 1910.95 identifies five required elements of a Hearing Conservation Program. These components include exposure monitoring, audiometric testing and evaluation, hearing protection, employee training, and Recordkeeping. The following are checklists that can be used to help monitor your program. These lists are by no means exhaustive but are meant to provide a way to quickly assess the essential elements.

Exposure Monitoring
When information indicates that any employee’s exposure may equal or exceed an 8-hour time-weighted average of 85 decibels, the employer shall develop and implement a monitoring program. Monitoring shall be repeated whenever there is a change in production, process, equipment or controls that increases noise exposure.

  • Was sound level equipment calibrated before and after monitoring?
  • Was monitoring done in all areas where high noise levels are suspected?
  • Were personal dosimeters used when there were variable noise exposures?
  • Could workers observe monitoring and receive monitoring results?
  • Are areas identified where employees are to be included in the hearing conservation program?

Audiometric Testing
The employer shall establish and maintain an audiometric testing program for all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 decibels.

  • Do you maintain a notebook or file that contains certificates of calibration for your audiometer?
  • Is there annual documentation that the booth meets noise requirements?
  • Are there functional check (biological) records for every test day?
  • Is there a current CAOHC (or other) certificate of training on file?
  • Is testing performed and results compared annually to determine if a STS has occurred? Are STSs retested within 30 days?
  • Are associates notified in writing of test results within 21 days?
  • Is a Professional Supervisor in charge of the program and reviewing STSs to determine if referral is necessary?

Hearing Protection
Employers shall make hearing protectors available to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater at no cost to employees.

  • Are a variety of HPDs available to all workers exposed to an 8-hour TWA/85 dB?
  • Is a selection of HPDs offered at no cost?
  • Is the employee trained in use, care, and fit of HPDs?
  • If sized, is the dispenser trained?
  • Does the HPD provide adequate attenuation for the environment?
  • Is a compliance policy in force?

Training and Education
The employer shall institute a training program for all employees who are exposed to noise at or above an 8-hour time-weighted average of 85 decibels, and shall ensure employee participation in such program.

  • Is the educational presentation revised and updated to keep interest high and to keep up with changes in equipment and processes?
  • Is the trainer knowledgeable in occupational hearing conservation?
  • Are workers who experience STSs counseled individually?
  • Are supervisors involved in the retraining and monitoring of workers who have an STS?
  • Is the date, content, trainer, and those workers who attended the training session documented in writing?
  • Is training conducted in one or more sessions annually?
  • Does training cover effects of noise; the purposes, selection, fit, care and attenuation of HPDs; how and why audiometric tests are accomplished?
  • Is a copy of the standard available to workers and is it posted in the workplace?

The employer shall maintain accurate records of employee exposure...audiometric tests...measurements of background sound pressure levels in audiometric test rooms...

  • Are audiometric test results maintained in some form (hard copy, duplicate, microfilm, etc.) for employment plus thirty years?
  • Are noise exposure measurements maintained for at least two years?
  • Do audiometric records contain OSHA-required information?
  • Are sound booth and audiometer calibration records maintained?
  • Are employee education and training records signed and retained?
  • Are hearing protector type and size documented?
  • Are copies of audiometric technician training or certification preserved?
  • Are employee follow-up and referral actions documented?
  • Is a copy of the hearing conservation amendment (noise standard) posted in the workplace?

If you can answer yes to these questions, you are well on your way to OSHA compliance. For more comprehensive guidelines, see the standard or your HEARING CONSERVATION MANUAL, by Alice Suter, 3rd Edition.