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Slide 3 of 14


Once we have a budget we need a framework to guide our decision-making as we design and test our hearing loss prevention process. The speakers have been talking about hearing conservation and hearing loss prevention, but what we have to remember is this: there are two different approaches for preventing occupational noise induced hearing loss. Noise control in the workplace is the second and usually “preferred” other method. An employer can prevent work related hearing loss by making the workplace quiet or by means of periodic worker risk assessments, and subsequent use of training and effective personal hearing protection by workers at risk of excessive sound exposure, with annual medical surveillance acting as the safety net. We must operate under the requirement that whichever route is used to prevent NIHL the outcome for the worker at retirement must be the same. Our business goal then is to find the least expensive method of assuring a worker reaches retirement without work-related NIHL. Thus, we can express these choices as a balance. To keep the focus on our goal I have the placed the at-risk-workers in the containers for the balance. Success of the program should be measured by the number of healthy ears not the number of citations.

Because the original focus of the OSHA noise standard was for implementing feasible engineering controls much effort was put forth by the business community during the 1970’s to define a “reasonable cost per worker” for engineering controls. These studies and court cases concluded that economic feasibility permitted noise control costs in the range of $500-$3,000 per year per at-risk-worker to prevent hearing loss by engineering the workplace noise down to 90 dB(A) TWA. On the other hand we have the option to allocate at least $63 per year per at-risk-worker towards hearing conservation services and tools to protect worker’s hearing health. We actually protect them to lower levels because we provide medical surveillance for workers with sound exposure risks down to 85 TWA. On the surface this looks like a very simple decision. Many employers decided that the approach they were going to use was the hearing conservation approach.

But, we need to remember that the outcomes must be the same. In the 80’s a great debate was held in the courts as to whether employers could make worker safety and health decisions based on the premise of cost-benefit or whether the decisions between alternative approaches to achieving worker health and safety had to be limited to cost-effectiveness. According to my recollection, the US Supreme Court decided that when there are different methods of accomplishing compliance with OSHA regulations, e.g. an engineering method and also a protective method or a surveillance method, that use of any one must require that the outcomes in terms of worker safety must be the same. And therefore the outcome for an effective hearing conservation program has to be exactly the same in order to be deemed effective as would have happened had we engineered the noise down to 90 TWA. And so I am going to take that as my premise.