I am pleased to have this opportunity to present my case for why the Hearing Conservation Amendment has failed. I would like to take a little different tack. My thrust over the past 20 years has been to focus on how we integrate hearing loss prevention in the business process. It has always been my opinion that the risk of sound exposure is pervasive in our society both at work and at home. If we are to reduce and, hopefully prevent Noise Induced Hearing Loss (NIHL) in the American worker the required changes in attitudes, life styles, work-tools and recreational-toys, and the processes that we use to direct our personal and business lives are staggering. Success in accomplishing these changes are difficult to direct through a mechanism such as a OSHA standard. Such standards can outline good practice processes and requirements, but over time the original goal(s) of the standards change. For example, we forget the goal of healthy hearing for workers at retirement and begin to focus on avoiding OSHA citations, or worse, decide to “play the odds”, by balancing the cost and likely-hood of a citation again the cost of implementing effective hearing loss prevention and noise control processes into our normal business practices. Today I would like to share some of my insights gained by almost 30 years of experience consulting with industries that are trying to make hearing loss prevention their goal and about why the solution to this problem requires a re-evaluation of our attitudes about hearing health and business processes.