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CAOHC Newsletter: UPDATE

Avoiding the Pitfalls
Linda S. Frye, MPH RN COHN-S
Constance M. Tatman, MS RN CCM COHN-S
CAOHC Representatives of the American Association of Occupational Health Nurses

Congratulations! You have attended the CAOHC course, passed the exam, applied for and received CAOHC certification as a hearing conservation technician (COHC). You have returned to your work site and you are eager to implement or revise your hearing conservation program.

You are aware that the purpose of a Hearing Conservation program is to protect employee's hearing and to comply with Federal Standard OSHA 29 CFR 1910.95.

To avoid common pitfalls, adhere to the following:

I. Develop a written protocol

The protocol should include the following program components:

A. Noise monitoring and employee notification of monitoring results

B. Audiometric Testing Program

C. Audiometric Evaluation

D. Proper use of hearing protection

E. Documented training program

F. Record keeping, Record Retention, Access to Records

G. Address in writing how your program will handle presbycusis

II. Post a copy of the noise standard in a visible spot in the workplace
III. Maintain records in accordance with 29 CFR 1910.95

A. Keep an accurate record of all employee exposure measurements

B. Retain area noise exposure measurement records for 2 years

C. Obtain and retain employee audiometric test records for the duration of the affected employee's employment and for 30 years post employment.

Include in this record:

D. Keep a written chronological log that the audiometer was calibrated and by whom before each day's use. Calibration can be done using a biological ear followed by a human listening check of the headset or by testing a person with known stable hearing.

E. Keep accurate records of measurements of background sound pressure levels in audiometric test rooms.

IV. Perform an otoscopic examination

The goal is to see the tympanic membrane. Employees with impacted cerumen, drainage and/or significant congestion may not test well. Refer these employees to their primary care provider or your supervisor (a physician, otolaryngologist, or audiologist).

V. Record (STS) Standard Threshold Shifts

Within 6 days of determination that a work-related (STS) Standard Threshold Shift has occurred record as occupational

hearing loss in column 7 of the OSHA 200 log

VI. Facilitate, Document and Address Results of Industrial Hygiene (IH) Sampling
VII. Hearing Protection


Hearing protection is required for: employees who are exposed to an 8 hour time-weight average (TWA) of 85 dB(A) or greater and who have not had a baseline audiogram or who have experienced an STS, and employees who are exposed to an 8 hour TWA of 90 dB(A) or greater.

VIII. Develop a Hearing Conservation Database

This electronic data maintenance will save you time, provide ready documentation for an OSHA inspector, and will organize the necessary information for medical surveillance. Include these points in your database:

Off the shelf IH monitoring data bases are available from software suppliers. There are vendors who will manage and evaluate data.

Stay informed by reading this publication, the UPDATE, or you can access the Federal OSHA web page at: http://www.osha-slc.gov/SLTC/noisehearingconservation/index.html