HEARING LOSS PREVENTION PROGRAM AUDIT
Preventing occupational hearing loss is a complex matter, but it is
often entered into without first assessing the assets available, the assets required, and
the expected outcome of the program. Before any program to prevent hearing loss is
put into place, or before any changes in an existing program are made, an audit should be
performed on the system as it exists. Many companies decline to perform an audit because
they either can't conceive of a need for it or don't recognize its value as the foundation
of a successful program. A hearing loss prevention program audit should be considered as
important to the outcome of the program as is a business plan to the success of the
company.
While it is not difficult to conduct an audit, it may require time to assemble the
materials necessary to fully answer audit questions. Thus, the audit is often best done in
phases. The first phase should address whether or not the information needed to answer
various questions is available. Then, after materials to support answers are available,
the questions of the audit should be answered. There is no standard form available for a
hearing loss prevention program audit, but the questions in Appendix B, Program Evaluation
Check List, can serve well.
It is best to perform the audit from the top down, with administrative issues addressed
first. In the United States, occupational safety and health programs historically have
been driven by regulations. Thus, it is important to assure that the regulations for
hearing loss prevention programs are being addressed by the program. At the same time,
there needs to be a corporate recognition that addressing only regulatory issues will not
create an effective program. Good safety and health practices need to be followed. The
company policy must be developed and all who administer or participate in the program must
be aware of the policies. Decisions need to be made as to who is responsible for providing
facilities and materials for the hearing loss prevention program. Decisions also need to
be made about who the program implementer or key person will be and guidelines for
evaluating the effectiveness of that person need to be established. The role of
supervisors in the program should be established. If front-line supervisors have a role,
the role must be defined and procedures to notify supervisors and train them in their role
should be established.
Hazard assessments should be addressed during the audit. The audit should determine if
appropriate measurements have been taken. Methods should be developed to evaluate the
results of hazard measurement. Who will notify employees and how they will be notified of
the results of hazard measurement should be determined. It is important to identify the
critical measurements that need to be taken and how often they should be repeated. A
system should be developed to ensure that the results of hazard assessment are included in
the affected employees' health records and into shop folders. The program implementor
should also be aware of the assessment results.
Since the most effective means of preventing occupational hearing loss is to remove or
control the hearing hazards, engineering and administrative controls should be evaluated
heavily during the audit. Hazard control priorities should be established. In the long
run, addressing control matters in order of the level of hazard present will, over time,
remove the hazards from the workplace. The cost-effectiveness of engineering and
administrative controls must be considered in the audit. While it may not be feasible to
control all of the hazards at once, it may be feasible to resolve one or two situations
per year until all have been addressed. Most companies will not have hazard control
expertise in house and will have to rely upon outside consultants and contractors.
Provisions for the use of outside experts must be included in the audit.
Monitoring audiometry and related record keeping are critical parts of the hearing loss
prevention program. Often, many companies assume that this is the simplest part of the
program, and they are wrong. The training and experience of the supervisor of the
audiometric testing program (this should be an audiologist or a physician) are important.
It may be more efficient to contract out for the testing and record keeping services, but
it will be necessary for the company's program implementor to be well versed in this
aspect of the hearing loss prevention program regardless of who conducts the testing.
Among matters to be considered for an internally or externally managed company are quality
of the audiograms, access to prior audiograms by persons performing hearing testing,
training and certification of audiometric technicians, adequacy of the testing
environment, methods for determining changes in hearing status, communication of test
results to employees, and follow-up procedures for those employees showing shifts in
hearing.
Regular testing of employees' hearing is the most effective means of ascertaining that
hearing loss is being prevented. But, there will be employees whose hearing does change
for the worse. It may become necessary to refer these employees for further testing and
evaluation. The audit should address no less than the following: clear referral policies;
agreement between the company and consulting audiologists or physicians as to the
expectations from a referral; establishment of mechanisms to ensure that employees needing
evaluation or treatment actually receive the service; timely and accurate transmission of
records between the company and the consulting audiologist or physician; and guidelines
for providing evaluation and treatment for hearing loss or ear disease determined to be
not related to hazard exposure at work.
Those employees exposed to hazardous noise will need to use hearing protectors. While
seemingly simple, this can become a complicated aspect of the hearing loss prevention
program. The audit should address the criteria for determining whether or not the use of
hearing protectors is required. Types of hearing protection and sources should be
addressed and if not implemented in a policy, the person(s) responsible for making the
decisions should be identified. Hearing protectors need maintenance and replacement and
how that is to be achieved should be a topic of the audit. The audit should also consider
what to do about the employee who continues to show increasing hearing loss even though
using hearing protection. Lastly, the audit should address the employee who refuses to use
hearing protection when it is required or who wishes to use self-provided protection.
An effective hearing loss prevention program ensures that employees and management
receive training and educational experiences. The audit should address the frequency of
the training, how the training is provided, and what the training emphasis will be. For
example, training may be spaced over the year with some of it given by an instructor, some
by reading materials, some by video tape or interactive computer program, and some by the
audiometric technician at the time of the hearing test. The audit will help the company
determine the resources needed for training, identifying those easily accessible and those
that must be acquired.
Plans should be made in advance to evaluate the effectiveness of the hearing loss
prevention program. Many companies find that after a couple of years of operating a
program they have no idea if their efforts are having any effect. The audit should define
what metrics will be used to determine if the program is successful or not. Once the
metrics have been selected, the program implementor must make sure that all data collected
support the evaluation strategy selected.
The hearing loss prevention program audit should be reviewed annually by the program
implementor and appropriate managerial personnel. As the program grows and evolves, the
audit will provide a mechanism to force into review all aspect of the program. By using
the audit, it will be unlikely that any portion of the program will run ineffectively or
incorrectly, since problems should be identified so that they may be remediated
immediately.
Further Reading
Gasaway DC [1985]. Evaluating and fine-tuning the elements that comprise a program. In:
Gasaway DC. Hearing Conservation: A Practical Manual and Guide. Englewood Cliffs, N.J.:
Prentice Hall, Inc., Chapter 15.
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