The Occupational Safety and Health Administration (OSHA) Region 3 (covering Delaware, Pennsylvania, West Virginia, and the District of Columbia) has renewed a Regional Emphasis Program under which it focuses inspection resources on “High Level Noise.” This announcement provides a useful reminder to employers throughout the US to evaluate occupational noise and the risks of employees’ hearing loss. The remainder of this note summarizes OSHA’s Occupational Noise Standard for General industry (separate requirements cover construction).
What employer actions might OSHA’s Occupational Noise Standard require?
The Standard requires employers to manage workplace noise following a series of steps:
- Monitoring of noisy work areas to determine if they exceed noise levels set by OSHA
- “Feasible administrative and engineering controls” to reduce employees’ unprotected exposures below specified noise levels
- Hearing conservation programs including workplace monitoring, employee hearing tests, and personal protective equipment (PPE) for workers exposed to noise above OSHA’s “action level”
- Annual hearing tests for workers who regularly work in a noisy environment, and follow-up if hearing loss is detected
- How does OSHA set permissible noise levels?
The Standard recognizes that noise can damage hearing in two basic ways:
- Sudden bursts of “impulsive or impact noise”
- Continuing noise over time
OSHA’s permissible exposure levels (PELs) recognize these two models, and range from 90 decibels (dB) throughout 8 hours, up to 115 dB if for 15 minutes or less. Workplace noise should never exceed 140 dB. For comparison, normal conversation levels are considered about 60 dB, a freight train passing close is 80 dB, and a jet taking off close is 130 dB. OSHA considers the potentially harmful effects of noise to be cumulative, and so requires employers to evaluate noise throughout employees’ shifts.
- How must employers respond to excessive workplace noise levels?
If workplace exposures exceed PEL levels, OSHA requires the employer to apply “feasible administrative or engineering controls” to reduce ambient workplace noise below these levels, and requires personal protective equipment (PPE) if ambient controls cannot meet these requirements.
OSHA does not define administrative and engineering controls directly. Instead, OSHA offers general guidance and examples. OSHA online Noise webpage offers the following:
- Engineering controls involve modifying or replacing equipment, or making related physical changes at the noise source or along the transmission path to reduce the noise level at the worker's ear. Examples of inexpensive, effective engineering controls include choose low-noise tools and machinery; maintain and lubricate machinery and equipment (e.g., oil bearings); place a barrier between the noise source and employee (e.g., sound walls or curtains); and enclose or isolate the noise source.
- Administrative controls are changes in the workplace or schedule that reduce or eliminate the worker exposure to noise. Examples include: operate noisy machines during shifts when fewer people are exposed; limit the amount of time each person spends at a noise source; provide quiet areas where workers can gain relief from hazardous noise sources; and control noise exposure through distance is often an effective, yet simple and inexpensive administrative control.
Employers with workplace noise issues can explore these options further.
What is a Hearing Conservation Program?
OSHA’s Standard provides detailed requirements for hearing conservation programs, which must include the following:
- Workplace noise monitoring
- Employee hearing tests - baseline and annual (to identify “standard threshold shifts”)
- Hearing protectors (PPE)
- Employee training in noise and hearing conservation, hearing protectors, and hearing tests
- Additional information – general, and employee-specific
- Record-keeping
What happens next?
OSHA’s regional enforcement programs do not create new requirements, but employers should still take the reminder to evaluate noise in their workplaces, and whether employee protection s are necessary.
Self-Assessment Checklist
Has the organization evaluated its workplaces to determine if workers may be exposed to noise hazards?
If any workplaces include exposures exceeding an OSHA PEL, has the organization established engineering and administrative controls to maintain exposures below those levels?
- If adequate ambient noise controls are not sufficient, has the organization assigned adequate PPE?
Does the organization implement a hearing conservation program meeting OSHA requirements, in each workplace where exposures exceed an OSHA PEL even with all feasible engineering and administrative controls?
Does the organization retain records for each employee who has received testing and/or is covered by a hearing conservation program?
Where Do I Go For More Information?
Information available via the Internet includes:
- OSHA
- Occupational Noise Exposure webpage
- Region 3 REM announcement (11/28/23)
- NIOSH Noise and Hearing Loss Prevention webpage
- Canadian Centre for Occupational Health and Safety Noise webpage
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 30 years.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com