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751 Hearing Conservation Program Management
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Program Evaluation Checklist

Hazard Controls

Evaluate and prioritize hazard controls to mitigate noise hazards. Use external consultants if necessary and plan gradual implementation. Questions related to hazard controls include:

  1. Are hearing protectors made available to all employees whose daily average noise exposures are 85 dBA or above? (NIOSH recommends requiring HPD use if noises equal or exceed 85 dBA regardless of exposure time.)
  2. Are employees given the opportunity to select from a variety of appropriate protectors?
  3. Are employees fitted carefully with special attention to comfort?
  4. Are employees thoroughly trained, not only initially but at least once a year?
  1. Are the protectors checked regularly for wear or defects, and replaced immediately if necessary?
  2. If employees use disposable hearing protectors, are replacements readily available?
  3. Do employees understand the appropriate hygiene requirements?
  4. Have any employees developed ear infections or irritations associated with the use of hearing protectors? Are there any employees who are unable to wear these devices because of medical conditions? Have these conditions been treated promptly and successfully?
  5. Have alternative types of hearing protectors been considered when problems with current devices are experienced?
  6. Do employees who incur noise-induced hearing loss receive intensive counseling?
  7. Are those who fit and supervise the wearing of hearing protectors competent to deal with the many problems that can occur?
  8. Do workers complain that protectors interfere with their ability to do their jobs? Do they interfere with spoken instructions or warning signals? Are these complaints followed promptly with counseling, noise control, or other measures?
  9. Are employees encouraged to take their hearing protectors home if they engage in noisy non-occupational activities?
  10. Are new types of or potentially more effective protectors considered as they become available?
  11. Is the effectiveness of the hearing protector program evaluated regularly?
  12. Have at-the-ear protection levels been evaluated to ensure that either over or under protection has been adequately balanced according to the anticipated ambient noise levels?
  13. Is each hearing protector user required to demonstrate that he or she understands how to use and care for the protector? The results documented?

Audiometry and Record Keeping:

Oversee audiometric testing with qualified personnel, possibly outsourcing, and ensure the implementer understands this aspect thoroughly. Questions related to monitoring and recordkeeping:

  1. Has the audiometric technician been adequately trained, certified, and recertified as necessary?
  2. Do on-the-job observations of the technicians indicate that they perform a thorough and valid audiometric test, instruct and consult the employee effectively, and keep appropriate records?
  3. Are records complete?
  4. Are follow-up actions documented?
  5. Are hearing threshold levels reasonably consistent from test to test? If not, are the reasons for inconsistencies investigated promptly?
  6. Are the annual test results compared to baseline to identify the presence of an OSHA standard threshold shift?
  7. Is the annual incidence of standard threshold shift greater than a few percent? If so, are problem areas pinpointed and remedial steps taken?
  8. Are audiometric trends (deteriorations) being identified, both in individuals and in groups of employees? (NIOSH recommends no more than 5% of workers showing 15 dB Significant Threshold Shift, same ear, and the same frequency.)
  9. Do records show that appropriate audiometer calibration procedures have been followed?
  10. Is there documentation showing that the background sound levels in the audiometer room were low enough to permit valid testing?
  11. Are the results of audiometric tests being communicated to supervisors and managers as well as to employees?
  12. Has corrective action been taken if the rate of no-shows for audiometric test appointments is more than about 5%?
  13. Are employees incurring STS notified in writing within 21 days? (NIOSH recommends immediate notification if retest shows 15 dB Significant Threshold Shift, same ear, and the same frequency.)

Knowledge Check Choose the best answer for the question.

5-5. NIOSH recommends requiring the use of hearing protection devices if _____?