Record Keeping

Records quite often get the least attention of any of the hearing loss prevention program's components. But audiometric comparisons, reports of hearing protector use, and the analysis of hazardous exposure measurements all involve the keeping of records. Unfortunately, records are often kept poorly because there is no organized system in place, and in many cases, those responsible for maintaining the records do not understand their value. People tend to assume that if they merely place records in a file or enter them into a computer, adequate record keeping procedures are being followed.

Many companies have found that their record keeping system was inadequate at the moment accurate information was most needed. This has often occurred during the processing of compensation claims. Problems can be avoided by implementing an effective record keeping system, in which: 1) management encourages that the system be kept active and accessible, 2) hearing loss prevention program implementors make sure that all of the information entered is accurate and complete, and 3) employees validate the information.

Hearing loss prevention program records should include all items for each phase of the program: 1) hearing loss prevention audit, 2) monitoring hearing hazards, 3) engineering and administrative controls, 4) audiometric evaluation, 5) personal hearing protective devices, 6) education and motivation, and 7) program evaluation. Each phase generates its own form of records, and the information from the various records must be considered in order to evaluate the effectiveness of the hearing loss prevention program.

OSHA's record keeping requirements can be found in items no. 45-49 of Appendix A in this document. For more information on this subject, readers may consult the recommended readings at the end of this section, as well as the checklists in Appendix B. The reader is also referred to the chapter on Emerging Trends and Technologies for a discussion of the use of optical card technologies to store and retrieve hearing loss prevention program records.

Management should make available the facilities to store records and should provide sufficient resources to process them quickly and accurately. The forms or computer format used to gather information are the foundation of a good record keeping system. These forms should be designed so that necessary actions are triggered and then documented. If a company does not have the available resources to design a hearing loss prevention record keeping system compatible with the general safety and health record system, the company should turn to consultants for assistance.

Because hearing loss prevention program records can be complex, management should see that program implementors are fully trained in the record keeping system and its function. There should be working copies of records as well as archived copies. If an outside contractor keeps the records, a method should be established to ensure that original records are accurate, and are returned and entered into the company's files in a timely fashion.

Hearing loss prevention records are medical records and, as such, deserve the same level of integrity and confidentiality as other medical records. The company needs to make sure that these records are accessible only to program implementors, affected employees or their designated representatives, and government inspectors. Increasingly, companies maintain all of their employee health and safety records in a computer system. The use of computers supports easy access and storage of data, provides for automatic triggering of actions based on the data contained in the records, and generates hard copies to be maintained as archives. Prudent managers will see that original copies of records pertaining to individual audiometry and hazard exposure monitoring are retained in personal medical or industrial hygiene folders.

The records should be made available at the time of audiometric testing. Having the audiogram available will allow an instantaneous check of the new audiogram with the others on record so that checks for threshold shift can be made and so that the reliability of the new audiogram can be assessed. Having information about hearing hazard exposure, hearing protector use, and related information available will allow the tester to make an accurate and timely report to the employee of the outcome of the evaluation as well as conduct the one-on-one training that is so important to hearing loss prevention program success.

In most cases, hearing loss prevention program implementors will use a records system and associated forms that were developed by someone else, and must adapt their own procedures accordingly. The hearing loss prevention program implementor or operator must make sure that all information entered in the records is accurate, complete, legible, verifiable, and stated clearly so that the information does not need to be interpreted. If the operator discovers, while reviewing a record, that an employee's noise exposure level is not known, the measurements should be obtained and entered in the record. The same applies to other kinds of information. Also, there should be no blanks left in the form, since it is not possible to know whether a question did not apply or was overlooked. When blanks appear, they should be filled in or marked with NA for "not applicable" or INA for "information not available." Additional abbreviations should be avoided unless their meanings are clearly stated on the form in which they appear. Finally, original copies should always be available in an archive.

While management may provide the record keeping system and the necessary resources, the program implementors must ensure that the system works. The most important attributes of an effective record keeping system are standardization, maintenance, integration, and documentation. Standardization ensures commonality and consistency of data and format. Maintenance keeps records current and accurate. Integration of the recorded information allows the program implementor to assess the impact of the program on employees' hearing. Documentation of hearing loss prevention program elements permits analysis of long-range implications since cause-effect relationships associated with hazardous exposure levels only become evident over time.

Program implementors may wish to consider the following rule of thumb regarding how long records should be kept: Keep all records until you leave - then let the next person decide how long to keep the records. More practically, records should be kept for the length of employment plus 30 years, just as is standard practice with medical records. Thus, it is important for the program implementor to have resources for adequate records storage facilities be they computer-based or in hard copies.

Employee hearing loss prevention records should be available and accessible, especially at the time of regularly scheduled hearing tests. This is the ideal time for employees to check on the status of their hearing, and to pass along their comments on the hearing loss prevention program. Workers have a vested interest in the accuracy, validity, and accessibility of their hearing loss prevention and other medical records. Once they have been properly counseled, they should sign each audiogram to identify it as their own, and to signify that they are aware of any changes in hearing. They should also verify the accuracy of their medical history, any non-occupational noise and chemical-exposure history, and past and current personal or work-related information.

Code of Federal Regulations, Title 19, Chapter XVII, Part 1910, Subpart G, 1910.95: section (m).

See checklist in Appendix A of this guidebook,
items no. 42-49.
See checklist in Appendix B of this guidebook,
section entitled
"Monitoring Audiometry and Record Keeping."

Franks JR [1988] Management of hearing conservation data with microcomputers. In: Lipscomb DM, ed. Hearing Conservation in Industry, Schools, and the Military. Boston, MA: Little, Brown and Co., Chapter 9.

Gasaway DC [1985]. Using documentation to enhance monitoring efforts. In: Gasaway DC. Hearing Conservation: A Practical Manual and Guide. Englewood Cliffs, NJ: Prentice-Hall, Inc., Chapter 11.