In the event that an employee suffers a work-related illness or injury, the employer is required to complete a form known as the OSHA 300 Log. This Log is used to categorize and track the severity of the illness or injury.
Every year at the beginning of February, employers must post the results of their annual OSHA 300 Log publicly to their employees in the workplace. Throughout the year the Log is submitted electronically to OSHA respecting the required reporting guidelines. Companies with 10 employees or fewer are exempt from recording and reporting their work-related illnesses or injuries. The primary goal of OSHA’s record keeping is to capture data for statistical purposes and to look for opportunities to improve health and safety for workers. However, a log won’t protect an employee from a future illness or injury. This is why education, awareness, prevention, and protection are so important.
When it comes to hearing loss, a Standard Threshold Shift (STS) is a 10 dB(HL) deterioration of the average of thresholds at 2000, 3000, and 4000 Hz when comparing the baseline for each ear to the most recent test. Age correction may be permitted depending on the state where the testing is taking place. When an STS is identified, the employee must be notified in writing within 21 days. If an STS is present and the average hearing level at 2000, 3000, and 4000 Hz is equal to or greater than 25 dB(HL), then it should be recorded on the OSHA 300 Log. The employer has 30 days to perform the recommended retest, but ideally it should not be performed on the same day as the original test that reported the STS due to potential transient issues impacting hearing.
After the completion of the retest, and confirmation by a qualified hearing healthcare professional that a work-related STS has occurred, the employer has seven days to record the shift on the OSHA 300 Log. If the retest does not confirm the STS, then no recording is necessary. And if a retest is not performed, the STS is automatically confirmed and is required to be logged within 30 days of the original test. If a subsequent test shows that the recorded STS is no longer present, it can be repealed from the OSHA Log.
Regardless of whether a shift in an employee’s hearing is determined to be recordable or not, there are specific follow-up actions that the employer should take. First, if the employee has already been fitted with hearing protection devices, they should be refitted and retrained. It may also be time to consider hearing protectors that offer greater attenuation if necessary. An employee that is not currently wearing hearing protection devices should be fitted with them and trained on their proper use. Some additional follow-up actions include:
- obtaining new dosimetry – or measurement of noise exposure – for the employee
- investigating noise control mitigation options
- fit-testing of hearing protection
As a final precaution, the employee might have to be referred to an external clinic for further assessment. This will help to determine if a potential medical pathology of the ear is present, or if advanced testing is required.
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