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OSHA’s Revised Record-Keeping Rule. by Paul L. Osley, PE, BCEE, CIH, CSP Principal Environmental Occupational Health Services.

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osha s revised record keeping rule

OSHA’sRevised Record-Keeping Rule


Paul L. Osley, PE, BCEE, CIH, CSP

Principal Environmental Occupational Health Services


The following presentation is a synopsis of the information provided in the April 2006 Synergist Article:“Counting Ears – OSHA’s Revised Record-Keeping Rule for Hearing Loss Yields Insight”by Lee D. Hager

  • Identify the limitations of historical

(pre-2004) OSHA hearing loss record keeping/data

  • Identify new rule (29 CFR 1904.10) record-keeping criteria
  • Identify the power of post-2004 data and ability to begin to see true prevalence and incidence of noise-induced hearing loss in the American work force
  • Virtual tour/demonstration of the new hearing loss data (since 2004) available at various Bureau of Labor Statistics (BLS) websites:





prevalence and incidence what do those terms mean again

Prevalence and Incidence …What do those terms mean … again?

I’m Glad You Asked !

How about a crash course in Biostatistics and Epidemiology!

crash biostatistics epidemiology refresher course1
Crash Biostatistics/Epidemiology - Refresher Course
  • “Prevalence” - total number of “cases” present during a specified time
  • “Incidence” – number of new cases developing in a population over some period of time
hl data limitations pre 2004
HL Data Limitations (Pre-2004)
  • Historically the IH Community has shared hearing conversation programs by benchmarking and comparison

(seeThe Synergist, October 2002, pp. 32-33)

  • However, it has been difficult to compare the net effect of programs and identify the real prevalence of work-related, noise-induced hearing loss in the work place.
  • Why?
hl data limitations pre 20041
HL Data Limitations (Pre-2004)
  • Why?

Because until 2004, the OSHA hearing loss record-keeping requirements in 29 CFR 1904.10 was a “guideline rather than a regulation” and hearing loss fell into a catch-all “all other illnesses” section of OSHA’s record keeping rules

revisions to 29 cfr 1904 10
Revisions to 29 CFR 1904.10
  • Starting in 2004, established a clear and unambiguous criteria for clearly identifying what hearing loss configuration qualified as a OSHA recordable injury on the Form 300
  • Established a unique location on the OSHA Form 300 for recording hearing loss injuires
revisions to 29 cfr 1904 101
Revisions to 29 CFR 1904.10
  • In 2004, anecdotally, many programs reported significant increases in the number of hearing loss cases being reported under the new protocol
  • While one year’s data will not reveal trends, it is likely that the change in 29 CFR 1904.10 has resulted in a three- to fivefold increase in the number of hearing losses recorded as compared with the previous rule
revisions to 29 cfr 1904 102
Revisions to 29 CFR 1904.10
  • Changes were implemented in two stages:
  • Stage 1 - Revisions to the recordable criteria were put into effect in 2003
    • A recordable event was defined as:
      • A standard threshold shift as defined in 29 CFR 1910.95 (OSHA’s Hearing Conservation Amendment) of an average 10 dB change in hearing at 2,000, 3,000 and 4,000 hz test frequencies but only if the standard threshold shift resulted in hearing threshold levels (absolute hearing ability) of an average of 25dB or worse at standard threshold frequencies
revisions to 29 cfr 1904 103
Revisions to 29 CFR 1904.10
  • Stage 1 (cont’d):
    • By combining a shift criteria (standard threshold shift) with an impairment fence (25 dB hearing threshold levels), OSHA tried to ensure that the hearing losses reported on Form 300 were significant
    • However, hearing losses meeting the new criteria and detected in 2003 were recorded on Form 300 in the “all other illnesses” category, making it impossible to assess the effect of the new criteria for that year
revisions to 29 cfr 1904 104
Revisions to 29 CFR 1904.10
  • Stage 2 – Effective January 2004, a new location (Column M5) was added to Form 300 specifically for cases of recordable hearing loss
    • Maintaining unique records for hearing loss will enable OSHA and IH’s to track hearing losses detected in hearing conservation programs across industries
    • The OSHA imposed new definition of recordable hearing loss on all jurisdictions (even those stat-plans that may have more stringent requirements), will over time should enable apples-to-apples comparison of rates of hearing loss across states and across industries
power of 2004 hl data
Power of 2004 HL Data
  • Compiled data for 2004 is now available, giving the IH world some insight as to both what the changes in the record-keeping rule may bring and the true prevalence and incidence of noise-induced hearing loss in the American work force
  • Note data is available from 1994 forward, but due to the ambiguous classification criteria prior to 2004 (i.e. “all other illness”) hearing loss is impossible to parse out
virtual tour to the bls website
Virtual Tour to the BLS Website

Hold on to Your Seats !

(One moment … please)


Industry Injury and Illness Data

two new web based tools for analyzing occupational injury and illness rate iir data
Two New Web-based Tools for Analyzing Occupational Injury and Illness Rate (IIR) Data
  • Compute your company’s own IIR for safety management purposes and compare to the industry rate at:
    • http://data.bls.gov/IIRC/
  • Access IIR data by industry, demographic and case characteristics at:
    • http://data.bls.gov/GQT/servlet/InitialPage
  • OSHA Inspection Data, select Frequently Cited OSHA Standards and look for “noise”
    • www.osha.gov/oshstats
summary conclusions
Summary & Conclusions

“Making hearing loss data publicly and widely available allows employers to view the net results of their hearing conservation program efforts in a new way. It enables benchmarking of hearing conservation program performance by comparing individual hearing impairment and recordability rates across and within industries.”

summary conclusions1
Summary & Conclusions

“These data also provide the first truly useful information about the net effect of hearing conservation programs on a national basis. While arguments may conitue about the appropriateness of OSHA’s new recordable hearing loss criteria, the ability to readily view hearing impairment should enable employers, industrial hygienists, hearing conservationists and OSHA to better focus their energies where the problem is clearly demonstrated to be greatest.”

thank you

Thank You !