A successful hearing conservation program starts with the audiometric testing records. This data must be maintained for 30 years, except for noise exposure measurements which are only required to be on file for two years. These records include:
- the name and job classification of the employee
- the test date
- the examiner’s name
- the date of the last acoustic or exhaustive calibration
- measurements of the background sound pressure levels in audiometric test rooms
- the employee’s most recent noise exposure measurement
- delivery of training materials
You will be required to produce these records should an employee, former employee or auditor request them. You may be asked to provide audiometric testing data for the entirety of an employee’s tenure with your organization. If you’re testing outside of a standard sound booth (as clients do with SHOEBOX Audiometry), you must also maintain records to prove that the room was sufficiently quiet enough to adhere to OSHA’s Maximum Permissible Ambient Noise Levels (MPANLs).
Advantages of Digital Record Keeping
For those customers who do use SHOEBOX for their occupational hearing testing, all of their audiometric test data is saved and stored digitally. There are several advantages to digital record keeping over paper files.
What comes to mind first is the space required to properly store paper-based records. Some organizations have had to resort to paying for storage units that provide the necessary extra space to securely house paper records.
With digital records, there are no space limitations. Filtering through the information to find what you need is also much more convenient with the advent of electronic record keeping. Precise information can be obtained immediately with a search query in a database for a specific employee’s name, ID number, and date range. Doing the same is significantly more tedious when using paper records. You must be highly organized to find needed data when searching through thousands, or even tens-of-thousands, of paper records potentially going back decades.
Turnover happens, and roles change within all levels of an organization, especially during the 30 years that OSHA mandates your records be kept. This lengthy time frame can result in a ton of records, especially for companies with high turnover rates. An employee may have only worked for your organization for a couple of months, but their hearing test data must be maintained with the same regard as your most tenured workers. The people administering your program can also exit your company, or the program may expand to a level where additional help is needed. Electronic records make the management of a hearing conversation program more straightforward for the people maintaining it today, and for years to come.
A pervasive problem we often see is one of missing records, and out-of-date baseline indicators. Once a record is missing, it can be troublesome to track, especially if you don’t know it’s missing. A common cause of missing records occurs when an employee visits an outside clinic for a retest. The employee may return with a paper copy of the audiogram that then needs to make its way into their file. They can get misplaced, or the program manager might forget to upload the record into their database. It can be quite difficult to ensure that hard copy records are uploaded immediately to your database. Organizations already utilizing clinic-based audiometric testing services will most likely have a process in place to upload paper records. Chasing down these records with the clinic is time-consuming and easily drops to the bottom of the Safety Manager’s busy schedule.
What we see most often, however, is out of- date data. When clients change service providers, some of the data settings may get lost in the process, or the data is incorrectly uploaded into the new database. If you have done this a few times, the issue becomes compounded.
When new SHOEBOX clients come on board, we often see baselines that are out-of-date. They may have 20 years of records for an employee, but only one baseline established (usually from the employee’s hiring date). There may have been several persistent threshold shifts during that employee’s tenure. Often, the first thing we’ll do when beginning with a new client is to review their baseline data. If it is not up-to-date this is very important to note as it will result in a higher percentage of recordable shifts. For a smaller number of employees (<300), it may be possible for an Audiology Reviewer to go in case-by-case to update them. Unfortunately, for larger numbers of employees, this becomes more arduous.
All threshold shifts require review by an Audiologist or Occupational Physician. In cases where the baseline was not kept up-to-date, the Reviewer will update the historical baselines and the unconfirmed recordable STS is not recorded on the OSHA Log. This may require the HCM to review past OSHA entries to ensure they were noted at the original time of injury. We discussed OSHA logging in more detail in Chapter 9: What To Do When an Employee Has an STS? What is Required for Maintaining the OSHA 300 Log.
Digital Storage of Hearing Conservation Data
In our early days of offering occupational health solutions, we encountered some apprehension due to concerns with cloud-based storage of digital records. After learning about the advanced security measures that are in place to keep data safe and secure, these concerns are a thing of the past. On the plus side, electronic records are more accessible, easier to work with, and don’t require any physical space for storage. SHOEBOX for Occupational Hearing Testing includes unlimited data storage. Once people understand the emphasis we place on data security, and the new-found ability to manage records, the transition to cloud-based record storage is not only welcomed, it’s embraced.
Accurate and accessible audiometric testing data is the foundation of any well-maintained Hearing Conservation Program. Digital records provide organizations with the flexibility needed to scale, and the ability to access decades worth of records with a quick and straightforward search.
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 3 weeks! However, if you would like to download the complete guide now, complete the form below.
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