If you are new to hearing conservation, or your workplace has recently been assessed for noise and is now at or above the OSHA action level of 85 dB(A) time-weighted average (TWA) over an 8-hour day, you may be wondering who you need to engage to help build your Hearing Conservation Program (HCP). While there are many roles to fill, several can be held by only a few people and thankfully, not all are mandatory. As your business grows, you may want to hire people with more specialized skill sets to help your program run smoothly.
The following are the 10 key roles you may find in a Hearing Conservation Program:
The Program Manager
This person is often an EHS (Environmental Health and Safety) manager who may run several programs, of which the Hearing Conservation Program (HCP) is only one. They will be responsible for overseeing the program, ensuring testing is completed on time, tracking compliance, monitoring the effectiveness of hearing protection, and record-keeping (noise measurements, noise controls, and maintenance of the OSHA 300 Log). They may also be in charge of scheduling and the audiometric testing itself. In cases where a Standard Threshold Shift (STS) has been identified, they are responsible for notifying the employee, reviewing the employee’s workspace for physical noise mitigations, fitting of HPDs (Hearing Protection Devices), and additional training on proper use of HPDs both on and off the job.
Role of Employees in an Occupational Hearing Testing Program
In the context of an HCP, this includes anyone who is exposed to noise (85 dB(A) time-weighted average or more) at work. Once they are exposed, you must make at least two different types of hearing protection available for these employees, and they must be included in the monitoring program. If the employees are exposed to 90 dB(A) TWA, hearing protection for these employees is mandatory. Employees can play a major part in your program compliance. When employees are engaged in the program and understand the benefits of wearing hearing protection both on and off the job, your injuries will be reduced, and less time and money will be spent on evaluations and worker’s compensation.
Environmental Health & Safety Managers
Regional EHS Managers have similar roles to the Hearing Conservation Manager (HCM) but on a local or site level. Commonly these are Board-Certified Safety Professionals (CSPs), who are often responsible for maintaining the OSHA 300 Logs for the locations they oversee. They may also assist with hearing testing, scheduling, fitting and insertion of HPDs, and are often the people facilitating the annual hearing conservation training.
Occupational Hearing Conservationists and Qualified Test Examiners
The Council for Accreditation in Occupational Hearing Conservation (CAOHC)1 provides training across the US and abroad to become certified in hearing testing for occupational programs. This training is mandated in some states and considered best practice for all those involved in audiometric testing. When testing using an automated method such as SHOEBOX Audiometry, additional training is provided by the manufacturer to gain expertise in the use of their technology.
Occupational Health Nurses
If your organization has Occupational Health Nurses, they can be very useful members of the team who may serve a similar role to the Regional EHS Manager. They may be responsible for conducting the hearing testing, record-keeping, and training. Nurses are trained in otoscopy (looking in employee’s ears); therefore, they can check for things such as wax impaction or ear anomalies. Nurses are typically only found in larger organizations who have an on-site clinic and may have access to sound booths to perform testing.
Industrial Hygienists (IH) maintain workplace health and safety by identifying, evaluating, and controlling exposure to various chemical, physical, ergonomic, and biological hazards. Their responsibilities vary depending on the industry, workplace, and the types of hazards affecting employees; however, their goals are often the same: to implement control measures that will reduce the incidences of sickness or injury and identify potential health threats in the workplace. The IH has a particular expertise in noise monitoring. They are trained in the use of sound level meters for noise surveys and the creation of noise maps. These are the average sound levels (time-weighted over an 8-hour period) mapped across a physical workspace on a grid and help identify which workers are at risk of noise exposure. They would also be responsible for tracking and determining Personal Exposure Levels (PELs) of workers through dosimetry and, ultimately, for helping determine who qualifies for inclusion into the hearing conservation program.
The 1983 OSHA’s Hearing Conservation Amendment first emphasised the role of a hearing healthcare professional in the audiometric testing components of 29 CFR 1910.95 (g). For example: “A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist, or physician.’’ Similar rules exist in the MSHA Noise Regulation (30 CFR Part 62). The Professional Supervisor (PS) “has responsibility for ensuring the adequacy of the audio-metric testing environment, procedures, and record-keeping; the training of audiometric technicians; as well as the coordination of audiometric services delivered by a third-party health care provider”2. The Professional Supervisor could also be the health care professional who reviews the employee audiograms, but this is not always the case. For example, a company that has locations in several different states would typically only have one Professional Supervisor but could have multiple audiogram reviewers, as those individuals need to be licensed in the state in which the employee is stationed. Professional Supervision responsibilities include:
- Ensuring that baselines are appropriately set and modified
- Ensuring all testing equipment, as well as the testing environment(s), meet regulatory compliance guidelines
- Ensuring proper testing protocols, including annual testing, retests, and confirming appropriate paths of referrals
- Reviewing the annual hearing conservation training content provided to employees
- Ensuring that there are a minimum of two types of hearing protection options for employees
- Investigating trends in hearing shifts
- Overseeing the training of the hearing test administrators, including how the results are shared with the employee
The review of audiograms is required under 1910.95(g)(7) (iii) and states that ‘‘The audiologist, otolaryngologist, or physician shall review problem audiograms and shall determine whether there is need for further evaluation.’’ Reviewers are responsible for ensuring that the results for a particular employee are valid, complete, and whether or not there is a shift in hearing from previous evaluations. They would record their clinical impressions as well as recommendations for next actions, which could include requesting a retest, notifying the employee of a change in hearing, modifying baselines, and/or recommending a medical or audiological referral. More on the role of the Professional Supervisor and Audiological Reviewers is available in Chapter 7 (Establishing an OSHA-Compliant Occupational Hearing Testing Program).
Safety Specialist or Engineer
A Safety Engineer spends a lot of time at worksites to ensure proper implementation and monitoring of safety factors. When aiding a Hearing Conservation Program, their role would be to implement engineering controls to prevent unnecessary noise exposure. These controls can reduce sound exposure levels for most noise sources. They can involve altering equipment (i.e. converting a mechanical component to an electronic one), replacing old machinery, and making physical barriers at the noise source to block the transmission path and to reduce the noise level at the worker’s ear. This type of prevention is preferred over administrative controls, such as reducing the time an employee is exposed during their shift or using different personal protective equipment (PPEs). By combining a knowledge of health and safety with systems engineering, they are able to ensure that equipment, machinery, chemicals, and other environmental factors are safe. This is not a mandatory role but can be very helpful to the Health and Safety Team in administering the HCP. Often the Hearing Conservation Program Manager would take on these tasks if a Safety Engineer was not on staff.
An Acoustical Engineer is an engineer who specializes in the science of sound and vibration. Their primary role is the control of noise or vibration that can be harmful to employees and the general public. They are commonly found in the industrial, manufacturing, architecture, and transportation sectors, all those which benefit from expertise in acoustical engineering. Within an HCP, the Acoustical Engineer would be responsible for the diagnoses of noise problems in a noisy environment. They are looking for the dominant sound sources as well as the solutions that make it possible to reduce the noise. Acoustic diagnostics in noisy environments require, in addition to the traditional sound level meter, more specialized tools such as sound intensity probes, sound mapping, and beamforming antenna (a signal processing technique).
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next 10 weeks! However, if you would like to download the complete guide now, complete the form below.
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1 Hearing Conservation Manual, Council for Accreditation in Occupational Hearing Conservation, 5th Edition (2017)
2 The Role of the Professional Supervisor in the Audiometric Testing Component of Hearing Conservation Programs. ACOEM Task Force on Occupational Hearing Loss. Journal of Occupational and Environmental Medicine. 60(9):502-506, September 2018.