Hearing Conservation Program

Written February 17, 2019

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OSHA's Hearing Conservation Standard requires employers to measure noise levels in the workplace. If the levels are above the standard of 85dBA on an 8-hour time weighted average exposure, you are required to implement a hearing conservation program. Operations where noise levels are less than the 85 dB(A) are exempt from the standard. Use SGIA’s Hearing Conservation Program Template as your guide.

When measured noise levels exceed 90 dB, in addition to the hearing conservation program requirement, an employer must attempt to utilize feasible administrative or engineering controls to reduce sound levels below 90 dB.

  • Administrative controls could be as simple as limiting an employee’s shift time or rotating work to avoid prolonged time in the high noise environment
  • Engineering controls could include equipment barriers, insulating noise locations, enclosures of the noise sources, or replacing equipment for ones with a lower noise level

Depending upon the type of equipment used in a printing operation and the substrate being printed, some workers in a printing operation can be exposed to noise levels above OSHA’s 85 dBA limit. In other instances, certain employees can be exposed above 90 dBA. In either case, action on the part of the employer is required to meet the regulation and protect their employees hearing.

The only way to prove your facility is exempt is by performing noise measurement testing. While this may seem to be an excessive measure, in the long run it can prove beneficial to your operation as you will not be required to implement a hearing conservation program. Also keep in mind that as equipment or configuration of existing equipment changes, additional measurements may be required to determine any changes in exposure levels.

Employers Might Have a Loud Work Environment if:

  • There are employee complaints about excessive
  • A worker must shout to be heard from an arm’s length distance
  • A worker has a symptom of ringing or humming in their ears after leaving work
  • A worker experiences temporary hearing loss when leaving work

Noise Measurement Testing

hearing-conservation-2 To determine workplace noise levels, there are two noise measurements that can be taken-- Instantaneous and Over Time.

  • The Instantaneous approach measures the intensity of sound at a given moment. This is done with a sound level meter
  • Since sound level meters provide a measure of sound intensity at only one point in time, it is generally necessary to take several measurements at different times during the day to estimate noise exposure over a workday. If noise levels fluctuate, the amount of time noise remains at each of the various measured levels must be determined
  • The Over Time approach is performed with a dosimeter that stores sound level measurements and integrates them over time, providing an average noise exposure reading for a given period, such as an 8-hour workday
  • In determining worker exposure using a dosimeter, a microphone is attached to the employee's clothing and the exposure measurement is simply read at the end of the desired time period. A sound level meter can also be positioned within the immediate vicinity of the exposed worker to obtain an individual exposure estimate. Such procedures are generally referred to as "personal" noise monitoring
  • Area monitoring can be used to estimate noise exposure when the noise levels are relatively constant, and employees are not mobile. In workplaces where employees move to different areas or where the noise intensity tends to fluctuate over time, noise exposure is generally more accurately estimated by the personal monitoring approach

    In situations where personal monitoring is appropriate, proper positioning of the microphone is necessary to obtain accurate measurements. With a dosimeter, the microphone is generally located on the shoulder and remains in that position for the entire workday, no matter where the employee’s location. This includes lunch and other breaks taken during the day. The dosimeter is not removed at any time until the end of the designated 8-hour time period.

    With a sound level meter, the microphone is stationed near the employee's head, and the instrument is usually held by an individual who follows the employee as he or she moves about.

    Hearing Conservation Program Components

    A successful hearing conservation program includes the following elements:

    • Designation of personnel responsible for developing and overseeing the program
    • Determination of noise level exposures by equipment, area, or activity.
    • Identification of employees covered by the standard and classifying them according to their noise level exposure
    • Implementation of a hearing conservation program when noise exposure is at or above 85 decibels averaged over an 8-hour time-weighted average (TWA)
    • Conducting baseline audiograms for all new hired or employees transferred to high noise areas.
    • Conducting annual audiograms for all employees
    • Provision of annual training on the effects of noise; the purpose, advantages, and disadvantages of various types of hearing protectors; the selection, fit, and care of protectors; and the purpose and procedures of audiometric testing
    • If necessary, purchasing of hearing protection and a requirement for employees to wear in the following situations:
      - For any period exceeding 6 months from the time they are first exposed to 8-hour TWA noise levels of 85 dB or above, and until they receive their baseline audiograms if these tests are delayed due to mobile test van scheduling
      - If they have incurred standard threshold shifts that demonstrate they are susceptible to noise; and
      - If they are exposed to noise over the permissible exposure limit of 90 dB over an 8-hour TWA

    It is recommended that the programs be periodically reviewed. Updates may be needed due to employee exposures, changes due to new equipment installation, removal of existing equipment, or changes in equipment configuration.

    SGIA’s OSHA Compliance Resource Center provides technical assistance and services designed to allow printing operations to manage compliance and stay informed. For more information on Hearing Conservation or SGIA’s EHS services, email govtaffairs@sgia.org or call 888-385-3588.