is Your Professional Supervisor?
Barbara Panhorst, EdD RN COHN-S
Chair, Occupational Hearing Conservationist Committee and CAOHC Representative of the American Association of Occupational Health Nurses
As a consultant to industry, this is one of the first questions I ask when reviewing a company's occupational hearing conversation program (HCP). The answer I receive is usually a good indicator of the quality and compliance of the program. Frequently, I am told the Professional Supervisor is the occupational health nurse or the occupational hearing conservationist (OHC) because this is the person the company sent to be trained in hearing testing. Sometimes the human resource manager, industrial hygienist, or safety professional is identified. Occasionally, the company doesn't know who the Professional Supervisor is and, in fact, is not aware of the OSHA requirement for this individual.
Why is there confusion in this area? The term "Professional Supervisor" is never mentioned in 29 CFR 1910.95; however, the qualifications and particular duties of the supervising professional are well-defined in the preamble and hearing conservation amendment (HCA) itself. Employers, and even the designated Professional Supervisor, ask what and where does it say what the supervising professional's responsibilities are.
Role of the Professional
Supervisor in the HCP
The preamble to the HCA discusses the obligations of the supervising professional.
The standard envisions that persons administering audiometric tests will ensure the appropriateness of the test environment and functionally calibrate and maintain the audiometer; in addition, this person will screen audiograms to identify problem audiograms needing further evaluation by a professional and audiograms with standard threshold shifts. .....the responsibility for the direction of the hearing conservation program should remain "in the hands of a professional audiologist, otolaryngologist, or physician".
14 Quiet Hours
Employers or professionals supervising audiometric programs are, of course, free to prohibit the use of hearing protectors to provide quiet hours before the baseline audiogram if, in their judgement, the circumstances so warrant.
Grandfathering of Baseline Audiograms
After review of the evidence on this issue, OSHA is reaffirming its position ... of allowing the grandfathering of baseline audiograms. This policy is consistent with the exercise of professional judgment. It is the responsibility of the professional supervising the hearing conservation program to determine which pre-existing audiograms are acceptable and which to choose as the baseline.
Evaluation of Audiograms
These professionals are responsible for supervising the employer's audiometric test program and ensuring that tests conducted by technicians are carried out properly, that the test equipment is calibrated, and the test room is sufficiently quiet. Professional supervisors also determine the need for employee referral for further testing when test results are questionable or when problems of a medical nature are suspected. Because these professionals have extensive education and training in audiometry and the recognition of various types of hearing loss, they are considered to be the most qualified to oversee a testing program.
In light of the evidence to the record, OSHA has decided that an annual audiogram may be substituted for the baseline audiogram if the professional supervising the program determines that the employee has experienced a persistent STS or has shown a significant improvement in hearing activity.
OSHA believes that it should be left to the judgement of the professionals supervising the audiometric examinations and analyzing the results to advise the employer concerning the effectiveness of the employer's hearing conservation program.
The HCA itself further identifies the responsibilities of the professional supervisor:
(g) (3)Audiometric tests shall be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council for Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining and checking calibration and proper function of the audiometer being used. A technician who operates a microprocessor does not need to be certified. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or physician.
(7) (iii)The audiologist, otolaryngologist, or physician shall review problem audiograms and shall determine whether there is a need for further evaluation.
(8) (ii)Unless a physician determines that the standard threshold shift is not work-related or aggravated by occupational noise exposure, the employer shall ensure that the following steps are taken when a standard threshold shift (STS) occurs:... (9)Revised baseline. An annual audiogram may be substituted for the baseline audiogram when, in the judgement of the audiologist, otolaryngologist or physician who is evaluating the program:.........
A professional supervisor can only be an audiologist, otolaryngologist, or other physician. Audiometric technicians (whether they operate a manual or microprocessor audiometer) do not need to be certified but everyone must be able to show competence in the proper use, maintenance, calibration and functioning of the audiometer used and must be responsible to an audiologist or physician. Today, 14 years after promulgation of the HCA, some employers still believe if they use a microprocessor audiometer they do not need a professional supervisor to oversee their HCP. Only a physician can determine the job-relatedness of a standard threshold shift (STS). This information will help to determine the listing of the STS on the OSHA 200 Log.
There are specific responsibilities designated to the Professional Supervisor. These include:
It is not unusual for a person to have the title of Professional Supervisor and not fully understand the accountability of the position. Every employer should review these responsibilities with their professional supervisor to help assure compliance. I recommend that business and industry send their supervising professional to a CAOHC Occupational Hearing Conservationist Course. This will provide an opportunity to learn the OSHA requirements for occupational hearing conservation and better understand the duties of the OHC.