Council for Accreditation in Occupational Hearing Conservation (CAOHC)

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

  • Baseline audiometric exam

  • Annual audiometric exam

  • Written follow-up of test results to employees

C. Audiometric Evaluation

  • What to do if a work-related STS (standard threshold shift) is identified

  • Confirm the standard threshold shift within 30 days by retesting

D. Proper use of hearing protection

E. Documented training program

  • Access to information and training material

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:

  • Name and job classification of employee

  • Date of audiogram

  • Examiner's name and CAOHC certification number

  • Date of last acoustic calibration of audiometer

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

  • Make sure functional and calibrated sampling equipment is used.

  • When documenting results, compare the results to the appropriate action level (AL) and permissible exposure limit (PEL). If the work shift is other than 8 hours in length, you need to adjust the AL and PEL.

  • Document the results, recommendations and follow-up actions.

  • Facilitate IH monitoring any time a change in the workplace occurs that may alter operator exposure to noise.

VII. Hearing Protection

Requirements

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.

  • Provide a variety of hearing protection at no cost to the employee

  • Inform employees of the purpose, advantages and disadvantages of hearing protection

  • Train the employees how to select, fit and care for hearing protection

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:

  • Work areas

  • Area and personal exposure level

  • Shift duration

  • Monitoring date

  • Names of exposed employees and their ID number

  • Test Date of baseline exam

  • Test results of last annual exam

  • (STS) Standard Threshold Shift - if there is any

  • Necessary follow-up actions

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

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