Roundtable 227

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The Hearing Conservation Amendment: Has it Protected the American Worker?

Has the Hearing Conservation Amendment protected the American worker? This question was debated as the Amendment was put on trial in Roundtable 227, sponsored by the Noise Committee. In addition to the session evaluation forms, members of the audience were handed ballots so they could vote on this and related questions, as well as express their comments. Representing the affirmative side were William W. Clark, Ph.D. and Carl D. Bohl, D.Sc. of Central Institute of the Deaf, and Timothy L. Rink, Ph.D. of HTI, Inc.. Arguing against the Amendment were John R. Franks, Ph.D. of NIOSH, Richard R. James of James, Anderson & Associates, Inc., and Thomas H. Simpson, Ph.D. of Wayne State University. Kimberly D. Tum Suden, CIH of Walt Disney World Co. served as the Session Chair and presided as judge in the "trial".

In Support of the Amendment …

Dr. Clark's presentation focused on exposure and its relationship to risk. He stated that the 90 dBA criterion with 5 dB exchange was an adequate measure of assessing worker risk and predicting hearing loss. He concluded that the Amendment is working, and its provisions, when followed, are adequate to protect worker hearing. He supported this with personal and referenced studies showing a close correlation in exposure and predicted impairment in trainmen. Dr. Bohl showed charts from studies comparing hearing shifts due to noise, age and their combinations, which clearly demonstrated that the effect of occupational noise was not significant when hearing protective devices were worn at least 4 hours per day. Dr. Rink presented the results of eight years of data involving over 980,000 worker hearing tests collected by his firm. He demonstrated how re-testing and evaluation of influencing factors could allow a program manager to identify those workers with noise-related STS. The data showed that rates of Persistent Threshold Shift consistent with noise-induced hearing loss were 1.21% over the eight-year period and less than 0.5% in 1997. He asserted that these data confirm the effectiveness of the Amendment and successful HCP's.

In Opposition …

Dr. Franks illustrated the difference between prevention strategies and compliance-driven programs by reviewing the HCP's of two plants studied by NIOSH. Results clearly showed how intervention and conscientious program administration could reduce incidences of worker hearing loss. He concluded that compliance with the Amendment alone is not satisfying the goal of the regulation, but applying common-sense practices within its framework can prevent worker hearing loss. Mr. James' presentation dealt with managing hearing loss prevention as a business process. He asserted that to meet the design goal of the standard, that is, for the HCA to provide equivalent worker protection as would the 90 dBA TWA engineering standard, an effective HCP must maintain an annual STS rate of 0.5% or less. He then identified reasons why current programs are ineffective and raised concerns about how hearing loss in the workforce impacts the ability of a company to carry out its mission. Concerns included employer health benefit costs for hearing disabilities, lost opportunity costs related to a 55% increased risk of safety-related incidents, and reduced capacity to perform hearing critical jobs. He concluded that worker functionality was a compelling reason to change the paradigm from "Compliance" to "Wellness." Dr. Simpson's presentation focused on data integrity as it relates to audiometric tests, sound exposure monitoring, hearing protector usage and worker demographics. He concluded that to date, existing data has insufficient integrity to identify HCP success or failure.

Calling the Question …

The presentations were followed with question/answer periods among panel members and between the audience and panel. One of the most interesting statements during this period was made by an audience member speaking of his OSHA experience, who said: "I submit that, from my experience, as long as there is a box of earplugs in the plant our instructions are never, ever to issue a citation with a serious classification… no matter what your problems are - your violations of the Hearing Conservation Amendment are."

At the conclusion of the session, the audience voiced its opinion on four questions upon which the Amendment was judged. Of 155 ballots taken by members of the audience, 83 were returned, many with very interesting comments. Many comments reflected the concern over lack of enforcement, consistent with the statement about OSHA's enforcement instructions.

Results of voting were as follows:

And the Verdict is…

1. Has the Hearing Conservation Amendment achieved the goal of the standard - protecting workers from suffering material impairment? NO: 44 (53%) Yes: 38 (45.8%) Don't know: 1 (1.2%) 2. Does compliance with the Hearing Conservation Amendment ensure achieving the goal of the standard - protecting workers from suffering material impairment? YES: 44 (53%) No: 39 (47%) 3. Has the Hearing Conservation Amendment encouraged or discouraged development of effective hearing loss prevention practices? ENCOURAGED: 61 (73.5%) Discouraged: 19 (22.9%) Don't know: 2 (2.4%) No response: 1 (1.2%) 4. Has the allocation of resources as directed by the Amendment been a cost-effective approach in preventing hearing loss? YES: 38 (46.3%) No: 37 (45.1%) Don't know: 6 (7.3%) No response: 1 (1.2%)

In Summary …

It was interesting to note that the audience felt by slim margins that the Amendment was not achieving the goal of protecting worker hearing, but that compliance with the Amendment did ensure that the goal would be achieved. Many attendees commented that the Amendment was not being enforced adequately and that employers were not complying fully with its provisions. Although the audience members felt that hearing loss prevention practices were being encouraged by the Amendment, they were less enthusiastic about endorsing the Amendment as a cost-effective means to prevent worker hearing loss.

Roundtable 227 was highly successful regardless of the outcome of the "trial" because it gave the audience an opportunity to participate in the most current arguments in finding ways to prevent worker hearing loss.

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