Chair's Message - Fall 2008
By Mary M. McDaniel, AuD CCC-A CPS/A
How effective is your Hearing Loss Prevention Program? What metrics are you using to assess effectiveness? Are you successful in your efforts? Have you confused compliance with effectiveness?
There are six elements for a Hearing Conservation Program as outlined in the OSHA noise regulation; noise monitoring, noise control, audiometric testing, hearing protection, employee training, and record keeping. If implemented properly, these six basic program elements should yield a compliant program. But, is a compliant program an effective program?
I have spoken for years about the elements of an effective hearing loss prevention program and have used the term "Synergistic Seven". Despite the fact there are only six elements outlined in the regulation, there is an extremely important element not listed. Without Program Evaluation, the seventh element, you will have very little chance of achieving effectiveness. If you merely go through the motions, check off the boxes, and store the results in the file drawer, you'll be compliant but probably not effective.
Every element is required and if the information gleaned from each element is used to its full potential, you have a chance for an effective program. The key is in seeing the value and necessity of every element and the importance of all six elements working together. There's little value in measuring noise in the workplace if there is no attempt to examine the feasibility of noise control. Doing an audiogram does not prevent noise induced hearing loss unless the results of the hearing tests are used to motivate and encourage workers. Providing hearing protection will not save hearing unless each worker is fitted with a protector that is appropriate for the noise level and more importantly, the worker is properly trained in how to fit and use the protector. Employee education and motivation will not protect or prevent anything unless it's meaningful, relevant, and there's an assessment of whether learning actually occurred. And if the primary focus of record keeping is the number of Standard Threshold Shifts or OSHA 'recordables', aren't you measuring your failure rate as opposed to success?
Each element of an effective program contributes to the whole. Noise measurement determines the direction for the rest of the program; the requirements and feasibility of noise control; who is required to be in the HLPP; what types and styles of hearing protectors are warranted. The audiometric test alone does nothing! No hearing loss is prevented nor are any ears protected by taking a hearing test. The audiogram, however, can be viewed as our report card. If the other elements of the program are working, it will be evident in the stable audiograms obtained though annual audiometry. Putting a box of earplugs by the time clock in no way promotes consistent or effective hearing protection use. It's necessary to have appropriate selection and fitting of hearing protection along with monitoring their use; merely tracking the number of STSs or 'recordables', is like closing the gate after the horses are out! It is critical that you examine the records to help determine where your program is strong, where it is weak, and where to focus your energies and priorities for the program in the future.
The six elements of the hearing conservation program must be working together, each supporting the other. Program evaluation, the seventh element, is the one that will help determine your effectiveness. Look at your program, examine the test results, review your records, ask questions of the workers, and take the time to determine whether your efforts are successful. There's so much more to hearing conservation than hearing testing and earplugs! Don't fall short in your efforts. Employ the 'synergistic seven' to your advantage and always strive for an effective program rather than a compliant program. The comprehensive curriculum of your CAOHC training stresses the importance of each and every element of an effective hearing loss prevention program. Use what you have learned and strive for excellence. CAOHC - there is no equal!