Hearing Conservation EffectivenessvsOSHA Compliance Richard L. Stepkin, MS, CCC-A Occupational Audiologist, President Enviromed Corp Phone: 1-800-521-5051 Website: www.protectyourhearing.com E-Mail: email@example.com
Hearing Conservation Objectives • Protect employees hearing • Comply with OSHA criteria • Stabilize Worker’s Compensation Which is the most Important ??
STS = 2k, 3k, 4kHz Age Adjustment Allows Waivers Tied to 85 dBA TWA 83 dBA = 10 Hr shift 82 dBA = 12 Hr shift PA = .5k, 1k, 2k, 3kHz NJ = 1k, 2k, 3k MD = .5k, 1k, 2k DE = Medical Evidence No Age Adjustment Except MD No Waivers Not tied to 85 dBA OSHA Workers Comp
OSHA Regulation 1910.95 • Requires Mandatory Hearing Testing at 85dBA TWA • So why is Hearing Protection only VOLUNTARY until 90 dBA What is the purpose of Hearing Testing?
…and what about Noise Surveys ?? OSHA looks at 85dBA (TWA) Averaging noise levels is sometimes used as a way out. Are we ok at 84.9 dBA? Where is the line drawn? Are we really protecting hearing?
Audiometry • Annual testing can be nothing more than a means for documenting compensation. • Depends on how your data is reviewed • To satisfy OSHA? – good luck! • And…..what about follow-up – what is this really? • Retesting is NOT Follow-Up • Retesting is…..”Retesting” • Confirmed retesting requires “Follow-up”
Audiometry – the big question? • How come OSHA requires testing 500, 1000, 2000, 3000, 4000, 6000 Hz but….. • OSHA looks at shifts in hearing at 2000, 3000, 4000 Hz. • So, why test the other frequencies? • OSHA does not address the others. • What does this mean?
Who Reviews Audiometric Data? Do we rely on a software to do our review? Most physician’s have not had training in Hearing Science – Basic Audiology is not taught in medical school Certified Audiometric Techs and Nurses are not qualified to interpret according to CAOHC
Who should review the Data? • Use Professional Reviewers • Audiologists with Occupational Experience • ENT Physicians (Otolaryngologists) • Can be more costly than Audiologists • Occup Physicians that have attended CAOHC courses or had training in the Hearing Sciences • Offered annually at the AAOM meetings
How should Data be Reviewed? • Identify shifts in hearing BEFORE they become significant • Consider the State Compensation formula in the review process • Look at a variety of factors to include: • Averages of .5, 1k, 2k, and 1k, 2k, 3k, and 2k, 3k, 4k, and 3k, 4k, 6k. • Various threshold patterns, hearing differences
More about Data Review • The data should be reviewed in such a way as to protect hearing before it becomes a problem. • OSHA identifies hearing loss AFTER the fact • Using Age Correction (except MD) – only hides potential liability. • OK to use Age Correction for Log 300 issues • Remember Loss Prevention, not OSHA Compliance
What about Follow-up? • Bar none – the most IMPORTANT part of your Loss Prevention Program. • The MOST IMPORTANT part of your Loss Prevention Program • FOLLOW-UP FOLLOW-UP
Who should have Follow-up? • Shifts or pattern trends based upon your review criteria. • Significant Baseline Losses where Speech Frequencies may be involved • New hires (after probationary period) that showed possible “pre-existing” hearing loss
Who Pays for Follow-up? • The company should pay because: • Controls the referral source • Insures the best & most knowledgeable professional for the job • Educate the source on the company HCP • Controls the Costs • Entitles company to a report
Who does Follow-up? • Can only be done by an Audiologist or ENT Specialist • Referral to a Physician or Industrial Clinic with no Hearing Science training is not adequate • Provide the Hearing Professional with: • Detailed Employee Job Description • Noise Levels – far back as possible • Audio Data Summary • Reason for Referal
What does Follow-up include? • Follow-up testing includes as a minimum: • Air-Bone-Speech Audiometry • Otoscopy & Tympanometry • Detailed Hearing History • Employee one-on-one consultation
How to Assess Cause of Loss? • Look at all factors affecting hearing, not just work noise. • Consider all noises: military, recreational, prior jobs, hunting or target shooting, lighting firecrackers etc. • Threshold patterns relative to noise exposures, length of employment, use of hearing protection
How to Assess Cause of Loss? • Hearing Professional must have an “unbiased” attitude. • Poor assumption that 20 years in a noisy place caused the loss without looking at all factors
How to Determine % of Loss • Low Fence is 25 dB • 0-25 dB is Within Normal Limits • High Fence is 92 dB • Can be considered deaf • Every dB above 25 is 1.5 % • Thus 92 dB is 100%
How to Determine % of Loss • AAO Criteria: • Average for each ear at .5k, 1k, 2k, 3k Hz • Subtract the Low Fence of 25 dB • Multiply the remaining dB by 1.5% • Multiply the better ear times 5 • Add the poorer ear to the total • Divide by 6 for a binaural percentage
Formula Example • Assume: Right ear avg loss is 35 and Left is 45 dB • Subtract 25 from each ear • 10 dB Right and 20 dB Left • Multiply each ear by 1.5% • 15% Right and 30% Left • Multiply better ear times 5 • 75% Right and 30% Left • Add the two for a total of 105% • Divide the total by 6 which equals 17.5%
2 Kinds of Standard Threshold Shift (STS) • STS according to OSHA Reg 1910.95 Hearing Consv • Retesting required – and if confirmed: • Not required to be put on the OSHA Log 300. • Review fitting of HP and counsel employee • STS according to OSHA Reg 1904.10 Recordkeeping • Review fitting of HP and counsel employee • Determine cause of STS with Follow-Up Evaluation • Work Noise related are Log 300 Recordable • Even if just part of the loss is work related
3 Steps to Determine Standard Threshold Shift (STS) • Ears are figured separately • Step 1 = Get avg of 2k, 3k, 4k • No Age Correction Allowed • If <25 dB – Not Recordable on Log 300 (1904.10) • Could still be a non-recordable STS (1910.95) • Review fitting of HP and counsel employee • If 25 dB or more – go to Step 2
3 Steps to Determine Standard Threshold Shift (STS) • Step 2 = If 25dB or more • Compare average of the “current” test to the average of the “original” or “last revised” baseline • Apply Age Correction to both tests • If the difference between tests is <10 dB • Not recordable • Review fitting of HP and counsel employee • If 10 dB or more - then go to Step 3
3 Steps to Determine Standard Threshold Shift (STS) • Step 3 = If 10dB or more avg with age correction • Must be recorded on the Log 300 • If there was no retest or • Retest confirmed STS or • Follow-up evaluation determined that at least part of the STS was due to work noise • Review fitting of HP and counsel employee • Put on the Log 300
Summary • Know that OSHA requirements do not effectively protect employee hearing or company liability • Insure hearing test data is analyzed based on State Compensation criteria as well as OSHA criteria. • Establish a Hearing Conservation Program that requires: • Mandatory HP at 85 dBA when in noise, regardless of time exposed. • Mandatory hearing testing for anyone that goes into designated areas, regardless of time exposed • Retest and Follow-up action as recommended by the Professional Reviewer.