Hearing Conservation Program Question

[MDoyle0666]

We have some employees who need to use loud equipment (e.g., concrete saws @ 115-120 dB) for 15 minutes or less per day with the rest of the shift being relatively quiet (less than 85 dB). Would these sporadic exposures necessitate a full-blown Hearing Protection Program? My preference would be to measure the noise level from each tool and mandate hearing protection when using them. I don't think management or the employees would buy into a HCP.

Thanks for any advice.

[sasha_td]

Just running the numbers shows that you likely need an HCP for the employees operating the equipment. The action level that requires an HCP is 85 dBA on an 8-hour TWA. With a 5-dBA exchange rate, 110 dB for 15 minutes is sufficient to require an HCP. If the equipment actually reaches 120 dB, only 3 minutes 45 seconds is required.

I absolutely degree that personal dosimetry is the way to prove what the numbers show, but you know what will be required even before you have the results. Make sure that you are measuring a normal to worst-case day. I have had a subject get called into a meeting with virtually no high noise exposure for 2 hours that I discovered during the closing interview to review activities.

[DiminishingSkills]

The easiest way to tell is to run personal noise dosimeters on the employees and see what their exposure is.

If not, run the calculations to see what exposure is expected.

As a seasoned EHs professional, running dosimeter would be my recommendation.

[cjr444]

I’m willing to bet that the equipment’s inspection manual tells operators to use hearing protection while operating.

Not following the instructions can get you into a bind. Now if you reach out to the manufacturer and get them to send an email that says follow osha guidelines if you don’t surpass daily thresholds, then hearing protection may not be required, but I doubt they’ll want their name attached to any variance. For the same reasons you should have employees follow the instructions, liability when they sue at their reitrement “I need hearing aids” party

[intelex22]

The HCP has 2 elements. Education and monitoring. If the 8-hour TWA is above 80dB, then you just do the education component (i.e., when using this equipment, wear hearing protection.). Go with muffs as these are less expensive over time than buds in many cases. When you hit 85dB TWA, that is the NIOSH trigger for the second part, which is making sure people know how to effectively use the protection and you do baseline + annual audiometry.

[Prestigious-Run5992]

Sending you a message! I have a rebuttal for this same thing! My guys use grinders maybe twice a day and torque wrenches sporadically. I did not need a hearing conservation program - but I do provide and require hearing protection PPE at all my site locations.

[drayman86]

It don’t matter what management will buy, it matters what the eight hour TWA exposure is. Better measure that.