I would say that even in the better run hearing conservation programs, very few companies know whether the at-risk workers have been identified. Monitoring is not really being done with sufficent resolution to know for certain if all at risk workers are included in the hearing conservation process. We don’t know whether we are really preventing hearing loss and we don’t know whether the workers are impaired.

Can we say whether fewer workers are at risk today than 10 years ago? We don’t know whether the noise controls are really working to reduce hearing loss. We aren’t sure whether we are in compliance because OSHA has provided very little guidance. We don’t know the weaknesses or strengths of our programs. And, in most cases we have not even begun to understand what the barriers are to making the program better.