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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.
Back to the AIHCE98 Roundtable Presentation Index
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