U. S. Department of Labor
Occupational Safety and Health Administration
Directorate of Science, Technology and Medicine
Office of Science and Technology Assessment
Innovative Workplace Safety Accommodations
for
Hearing-Impaired Workers
Safety and Health Information Bulletin
SHIB 07-22-2005
This Safety and Health Information Bulletin is not a standard or regulation, and
it creates no new legal obligations. The Bulletin is advisory in nature,
informational in content, and is intended to assist employers in providing a
safe and healthful workplace. Pursuant to the Occupational Safety and Health Act,
employers must comply with hazard-specific safety and health standards
promulgated by OSHA or by a state with an OSHA-approved state plan. In addition,
pursuant to Section 5(a)(1), the General Duty Clause of the Act, employers must
provide their employees with a workplace free from recognized hazards likely to
cause death or serious physical harm. Employers can be cited for violating the
General Duty Clause if there is a recognized hazard and they do not take
reasonable steps to prevent or abate the hazard. However, failure to implement
any recommendations in this Safety and Health Information Bulletin is not, in
itself, a violation of the General Duty Clause. Citations can only be based on
standards, regulations, and the General Duty Clause.
Introduction
Approximately 28 million Americans have some
degree of hearing loss [1,9]. Hearing loss can result
from a variety of factors, including: heredity, disease,
physical trauma, and exposure to loud noises. The
National Institute for Occupational Safety and Health
(NIOSH) estimates that 10 million American workers
have permanent hearing loss resulting from exposure
to excessive noise at work [2]. The number of
American workers with hearing loss from all sources is
expected to increase over time as the workforce ages.
Hearing-impaired workers face challenges responding
to emergencies, working safely around machinery,
communicating with coworkers, and receiving training.
Accommodations necessary to address these
challenges may not be part of an employer’s current
hearing conservation practice. This Safety and Health
Information Bulletin (SHIB) focuses on (1)
Emergency/Evacuation Response Considerations
for Hearing-Impaired Workers; and (2) Workplace
Safety and Health Considerations for Hearing-
Impaired Workers.
Purpose
The purpose of this SHIB is to provide employers,
workers and professional organizations guidance on
accommodating the safety and health needs of
hearing-impaired individuals in the workplace.
Specifically, this SHIB:
Raises awareness about the safety and health
challenges faced by hearing-impaired workers.
Informs employers of the wide range of
accommodations available for the hearing-impaired
worker and their application in the workplace as they
relate to emergency evacuation, training, responding to
safety hazards and communication.
Encourages employers to develop and establish
procedures for hearing-impaired workers that further
safety and health in their workplaces.
Encourages worker participation in the
development, planning, and implementation of these
accommodations.
Background
The Occupational Safety and Health Administration’s
(OSHA) Occupational noise exposure standard
includes requirements for a hearing conservation
program (29 CFR 1910.95(c)). It covers employers
in general industry with employees exposed to noise at
85 decibels (dBA) or above measured as an 8-hour
time-weighted average sound level (TWA). It
requires these employers to include their noise-exposed
employees in a hearing conservation program
that consists of noise exposure assessment,
audiometric testing, hearing protection and training. The nature of the workplace has changed since the
standard took effect; many workers in the United
States are aging and have some degree of hearing
loss. There is also greater concern among workers
about readiness to safely react to catastrophic events.
In addition to emergencies caused by natural
disasters, and technological accidents; possibility of
acts of terrorism have become a concern.
Accommodations are available to enable hearing-impaired
workers to evacuate safely, and certain
accommodations may benefit workers with no hearing
loss, since some emergencies may adversely impact all
workers’ ability to hear or communicate. Accommodation measures in the workplace are an
extension of good communication and safe practices for all workers.
Hearing-impaired workers also face routine workplace safety and health challenges. In particular,
hearing-impaired workers may have difficulty
understanding audible warning signals and alarms
designed to indicate the approach of motorized
vehicles. For those with severe and profound hearing
losses, a common safety concern is localization. For
example, "I know there are forklifts in the area but I
do not know where they are coming from." Other
concerns expressed by hearing-impaired workers
include difficulty understanding conversation on the
telephone, at meetings and in training sessions [16].
Fortunately, accommodations and equipment
modifications are available to assist hearing-impaired
workers to perform their jobs safely [4,9].
A. Emergency/Evacuation Response
Considerations for Hearing-Impaired Workers
Customizing Worksite Emergency Preparedness
for Hearing-Impaired Workers
The OSHA Emergency action plans standard (29
CFR 1910.38) requires an employer to develop a
written emergency action plan when such a plan is
required by a specific OSHA standard, such as 29
CFR 1910.120 hazardous waste operations and
emergency response, and 29 CFR 1910.160 fire
extinguishing systems. When the plan is required, it
must describe the actions employees should take to
ensure their safety if a fire or other emergency situation
occurs. At a minimum, the plan must include:
emergency escape procedures; procedures for
employees who remain to operate critical plant
operations before they evacuate; procedures to
account for all employees after emergency evacuation;
and procedures for reporting fires and other
emergencies. The plan must also include the types of
evacuation to be used in emergency circumstances.
The employer must review the plan with each
employee covered by the plan when it is developed,
whenever the plan changes and upon an employee’s
initial assignment. Employers must consider
employees with disabilities in the development of an
emergency action plan when such a plan is required by
a specific OSHA standard.
The plan must be in writing, kept in the workplace,
and available to employees for review. For employers
with 10 or fewer employees, the plan may be
communicated orally and the employer does not have
to maintain a written plan. The Appendix to 1910,
Subpart E, Exit Routes, Emergency Action Plans, and
Fire Prevention Plans is a nonmandatory guideline to
assist employers in complying with the requirements of
the employee emergency plan [3].
The Americans with Disabilities Act (ADA) does
not require employers to have an emergency
evacuation plan, but if an employer decides to have
such a plan, they are required to include people with
disabilities [10,14].
To help prepare workers for emergencies, the Office
of Disability Employment Policy (ODEP), at the U.S.
Department of Labor, provides recommendations on
emergency preparedness for people with disabilities.
The ODEP report suggests three essential parts to an
emergency evacuation plan: plan development, plan
implementation and plan maintenance [4].
Plan development includes identifying the potential
hazards, the accommodation needs of persons with
disabilities, and key personnel who will be involved in
an emergency. In developing a plan, employers
should ask their employees for their input, and
workers with disabilities should take responsibility for
their safety by offering their ideas and input. The plan
should address after-hours situations, and include a
method to identify visitors with special needs. The
plan also should include details on how information
will be conveyed to hearing-impaired workers when
they are away from their work areas. Finally, the plan
should be easy to read and understandable.
Employers should consult with local fire, police and
emergency departments as well as community-based
organizations in developing the plan. While the plan
should be in writing, it should be viewed as an ongoing
process, periodically revised and updated to reflect
changes in technology, personnel and procedures.
Plan implementation involves distribution of the plan
in an accessible format to all employees and the
integration of the plan into the employer’s standard
operating procedures. Drills, both scheduled and
unscheduled, should be performed regularly. Such
practice drills should encompass the needs of all
individuals, including workers with disabilities, to
ensure familiarity with the procedures and to
determine where improvements are needed.
Plan Maintenance involves developing a system for
identifying new safety concerns and the needs of new
disabled employees, reviewing and modifying plans
after practice drills, and ensuring that emergency
equipment is being properly maintained in good
operating condition [4,5,9,10].
Alerting Device Options
Traditionally, notification of an emergency has been
done through the use of auditory devices which are
effective for most workers. OSHA’s Employee Alarm
Systems standard (29 CFR 1910.165), addresses all
emergency alarms required to be installed by specific
OSHA standards. The standard indicates that an
alarm system must provide warning for necessary
emergency actions and be capable of being perceived
above ambient noise by all employees. Since hearing-impaired
employees may not be able to hear auditory
alarms, OSHA considers strobe lights or similar
lighting devices and tactile devices to meet the
requirement of the standard [3].
Hearing-impaired workers may also have difficulty
understanding voice communication over the public
address (PA) system. The alarm may interfere with or
drown out voice announcements, making the
emergency voice communication system ineffective.
Alerting device accommodations are available to
notify hearing-impaired workers of emergencies, and
they cause minimal distraction to other workers.
Visual alarms equipped with flashing strobe lights or
vibrating alerting devices can be hard-wired into the
existing emergency notification system. The
Underwriters Laboratories Standard for Emergency
Signaling Devices for the Hearing-Impaired (UL
1971), establishes criteria for systems used for
emergency notification [5].
Section 4.28 of the ADA Accessibility Guidelines
(ADAAG)2 specifically addresses specialized alarms
(www.access-board.gov/adaag/html/adaag/
htm#4.28). To be effective for notification, visual
alarms must be installed where hearing-impaired
persons can see them [6].
Many alerting device options are available for use in
the workplace, depending on the particular needs of
the hearing-impaired worker. However, not all of the
devices listed below are appropriate for every
hearing-impaired worker. Some of the devices are
more appropriate for individuals with a severe-to-profound
hearing loss, while others are appropriate for
workers with a mild hearing impairment. The
employer should work together with hearing-impaired
employees, and perhaps with an occupational
audiologist, in determining the device or combination
of devices that work best for their particular situation.
Some alerting device options include:
Exit signs set to flash when an emergency
alarm sounds. These signs are typically
connected to the emergency power system.
Strobe lights [7] or vibrating alarm signals
placed in all areas occupied by hearing-impaired
workers.
Visual or vibrating alarm signals at the
worker’s workstation.
Vibrating pagers worn by hearing-impaired
workers.
Vibrating watches or other type of body alarm
that is strapped on to the individual to alert a
hearing-impaired worker.
Two-way vibrating pagers that receive text
messages and have the ability to respond in
full length text.
"Hearing Dogs"- trained to alert the hearing-impaired
worker to a person entering the
room, abnormal machinery sounds,
malfunctioning equipment, the telephone
ringing or other alerting needs.
Buddy systems [5,7] where a coworker alerts
a hearing-impaired worker to an emergency
situation. This system should not be relied on
as the sole means of alerting the hearing-impaired
worker to an emergency situation
because of the relatively low reliability of this
approach.
Amplified telephone ring signaler to alert the
worker to a phone ringing.
A modem that converts the personal computer
into a Telecommunications Device for the
Deaf (TDD).
Instant messaging or e-mail pop-up.
A flashlight provided to hearing-impaired
individuals for signaling their location in the
event they are separated from the rescue team
or buddy.
The Job Accommodation Network (JAN)
website, a service of the Office of Disability Employment Policy, has a wealth
of information on alerting devices. JAN’s "Employers’ Guide to
Including Employees with Disabilities in Emergency
Evacuation Plans" covers requirements for including
people with disabilities, guidelines and accommodation
considerations. Toll-free (800) 526-7234 [14].
The United States Fire Administration
publishes many guides on the subject of disability and related emergencies, toll-free (800)
561-3356 [5,6,8].
Other Safety and Health Workplace
Accommodations
TTY: A teletypewriter (TTY) is a telephone
device that enables hearing-impaired
individuals to make and receive telephone
calls. The device requires two TTY users to
type messages back and forth to
communicate. When messages are typed on
the TTY keyboard, the information is
displayed on the TTY display panel and
transmitted through the phone line to a
receiving TTY.
TRS: The Telecommunications Relay Service
(TRS) is a 24-hour, 7 day a week, free
nationwide relay network service that handles
voice-to-TTY and TTY-to-voice calls. Using
a TTY or other mechanism (Voice Carry Over
phone, voice phone or videophone), an
individual dials the toll-free number to contact
the TRS system which will connect the caller
to a communications assistant (CA) who
directs the call. When the recipient answers
the call, the CA explains his or her role in the
call and will relay the communication between
the two parties exactly as stated by both
parties, either in text or voice. For more
information about Telecommunications Relay
Services, link to: http://www.nidcd.nih.gov/health/hearing/telecomm.asp, and
http://www.fcc.gov/cgb/dro.
Cell phone with a portable TTY. It is
important to make sure that the cell phone is
TTY compatible.
Wireless TTY. Provides instant TTY access
anywhere within a selected wireless data
network. Such TTYs have e-mail, fax, text-to-speech and speech-to-text message
capabilities.
The ADA Standards for Accessible Design, as well as
other technical assistance materials, can be obtained
from the U.S. Department of Justice ADA website. The Department of Justice operates a
toll-free ADA Information Line at (800) 514-0301
(voice), or TTY (800) 514-0383, which directs
callers to an ADA specialist [5,6,10,12,14].
B. Workplace Safety and Health Considerations
for Hearing-Impaired Workers
Responding to Vehicles in the Workplace
Workers with hearing loss working around or
operating powered industrial trucks (e.g., forklifts) or
other heavy equipment may be concerned about their
ability to detect dangerous situations. The employer
should work together with hearing-impaired
employees in determining the accommodation or
combination of accommodations that work best for
their particular situation. The following are suggested
accommodations that can be made to minimize such
safety risks:
Use tape, paint or ropes to highlight paths of
travel for forklifts, vehicles and heavy
equipment.
Designate separate doors for mechanized and
people traffic.
Establish rules requiring that all forklifts and
vehicles must stop at all intersections.
Install sensor warning lights that blink as the
vehicle approaches. Directional warning lights
such as the left light signals traffic on the left,
and the right light signals traffic on the right,
may be beneficial.
Install flashing strobe lights on vehicles or
forklifts to alert hearing-impaired workers to
oncoming vehicles.
Install mirrors at all intersections within the
warehouse. Dome mirrors situated along
aisle ways may be beneficial.
Use vibrating pagers - place a transmitter in
the moving equipment so that the driver can
press a button that sends a signal to the
vibrating receiver worn by the hearing-impaired
employee to alert the worker to the
approaching forklift.
Position a rear vision camera so that a vehicle
operator will be able to see behind him/her.
Training Accommodations
Training is an integral component of a safe workplace,
yet training may pose unique challenges for employers
who have workers with hearing impairments. Training
programs that ensure that procedures are understood
and followed are paramount to creating a safe work
environment [15].
Hearing-impaired workers often need customized
training tools to ensure their safety. There are a
variety of training mechanisms that can be tailored to
hearing-impaired individuals in the workplace. Again,
the decision to use a particular training
accommodation is one that should be made by the
employer and employee after considering the needs of
a specific situation.
Assisted Listening Devices (ALDs). These
devices amplify sound and transmit it to a
person’s hearing aid or to a receiver worn by
the individual. The speaker talks into a
microphone or transmitter and the listener
either uses the telecoil (t-coil) on their own
hearing aid or wears a receiver designed to
work with the specific ALD.
Captioned videotapes; open or closed.
Closed captioning requires the use of a
decoder to view the captions, while open
captioning displays the text automatically.
These captions are identical to captions
displayed at the bottom of the screen in
foreign language films. No special equipment
is required to view open captioning.
Scripting. A script of the video might be
provided as a last resort if there is no
captioning, and if the visual content is not of
great significance to the information provided
through the video. However, providing the
script as a supplement to the captioned video
in advance of viewing the video gives the user
additional preparation time to understand what
will be communicated.
Communication Access Realtime Translation
(CART) Services. CART is a service in
which an operator types the spoken word into
a computer that instantly displays the typed
words in English on a monitor or other display.
This service is useful during small and large
group situations when verbatim conversation is
essential to effective communication. CART
offers word-for-word translation. This service
typically needs to be scheduled in advance of
a meeting.
Computer-Assisted Notetaking. This service
can be used to provide effective
communication during group training sessions.
It involves the use of a laptop or personal
computer, word processing software, and
possibly a PC projector. Typically, a typist
who participates in the group activity acts as a
notetaker while the hearing-impaired individual
either watches the computer monitor or the
text projected onto a wall or screen.
Web-based training. Use web-based meeting
software or video conferencing.
Tape recorded meetings. After the training
session, the tape can be listened to separately
in a controlled listening environment with the
ability to rewind and playback as often as
necessary. The tapes can also be transcribed.
TTY Videophone in a video conferencing
format. This allows for full view of the group in
addition to TTY communication directly on the
TV monitor.
Communication Access Software. Currently,
there are innovative systems that provide
multisensory, interactive communication by
converting speech to text, and to real-time onscreen
sign language. More information about
these products is available on the internet.
Area and meeting room systems. Options
may include: FM desktop systems: portable
sound field-desktop or tote bag; FM System
with Speakers–Wireless; Conference
Microphone; Ceiling Speakers.
[9,12,13,14,16].
Tips for Assisting People with Hearing
Impairments
Speak in a clear, normal tone; do not overenunciate
or exaggerate words.
Speak directly to the individual, even if there is
a sign language interpreter present.
Face into the light when speaking and do not
cover or turn your face away.
Flick the light on and off when entering a room
to draw attention to your presence.
Offer pencil and paper. While writing a
message, do not talk; a hearing-impaired
person cannot read a note and your lips at the
same time.
In situations where lights may be inadequate,
provide the individual with a flashlight to help
the hearing-impaired person lip-read in the
dark. [5,8,13].
Use a microphone when speaking to a group.
A presenter should repeat a question raised by
the audience into the microphone before
answering the question.
Conclusion
The risk of miscommunication, injury, and other
dangers presented to hearing-impaired workers in the
workplace can be minimized through the
implementation of the practical steps described above.
The best way to help hearing-impaired employees feel
prepared for a workplace emergency and be
motivated to use safe work practices is to
solicit their input and provide knowledge, information,
and accommodation choices.
References
Northern Virginia Resource Center for Deaf and Hard of Hearing Persons.
"Emergency Preparedness and Emergency Communication Access" December 2004.
U.S. Department of Labor, Office of Disability Employment Policy.
"Emergency Preparedness for People with Disabilities, Summary Report". April
2004.
Federal Emergency Management Agency, U.S. Fire Administration. Emergency
Procedures for Employees with Disabilities in Office Occupancies.
U.S. Fire Administration. Fire Risks for the Deaf or Hard of Hearing.
Publication FA-202, December 1999.
USDA Employee Emergency Response Guide. Emergency Evacuation Suggestions for
Individuals with Disabilities, pp. 29-30.
U.S. Fire Administration. Orientation Manual for First Responders on the
Evacuation of People with Disabilities. Publication FA-235, August 2002.
National Organization on Disabilities. Emergency Preparedness Initiative:
Guide on the Special Needs of People with Disabilities for Emergency Managers,
Planners and Responders 2002. (202) 293-5960, TDD: (202)
293-5968.
U.S. Equal Opportunity Commission. U.S. Department of Justice, Civil
Rights Division. "Americans with Disabilities Act: Questions and Answers."
August 23, 2002.
U.S. Department of Justice, Civil Rights Division, Disability Rights
Section. Enforcing the ADA: A Status Report
from the Department of Justice. Issue 4, 2003.
U.S. Department of Justice, Civil Rights Division, Disability Rights
Section. ADA Business Brief: Communicating
with People Who Are Deaf or Hard of Hearing in Hospital Settings, October
2003.
NJ Arts Access Task Force. ADA Self-Assessment Survey and Planning Tool.
March 2003.
Job Accommodation Network. "Employers’ Guide to Including Employees with
Disabilities in Emergency Evacuation Plans". Linda Batiste and Beth Loy.
Occupational Health and Safety. "Safety First". Jennifer Juergens, June
2004, Vol. 73, No. 6, p. 94.
ADA and Accommodation of the Hard of Hearing. Presentation at the National
Hearing Conservation Association Conference, February 2005. George R. Cook, Au.D. CCC-A,
Occupational Audiologist. Workplace Group (336) 931-0300.
Other Useful Resources
U.S. Department of Justice, Civil Rights
Division, Disability Rights Section. "ADA
Information from the Department of Justice".
The Department of Justice answers questions
about the ADA and provides free publications
by mail and fax. This 7-page document lists
pertinent ADA legal documents, general
publications and guides, Technical Assistance
Publications for Businesses and Non-Profit
Service Agencies, and Technical Assistance
Publications for State and Local
Governments.
The Access Board, An independent federal
agency devoted to accessibility for people
with disabilities. Provides technical assistance
in ADA and ADAAG.
U.S. Department of Transportation, Federal Transit Administration,
Easter Seals Project ACTION. ACTION is a
national technical assistance program to
facilitate cooperation between the disability
and transportation communities. It offers
various resources, training and technical
assistance to make the ADA work for everyone.
Federal Agency Resources-Public Education
Websites
-------------------------- 1 OSHA’s standard at 29 CFR 1926.52 addresses occupational noise exposure in the construction industry.
2 ADAAG contains scoping and technical requirements for
accessibility to buildings and facilities by individuals with
disabilities under the ADA. These scoping and technical requirements are to be
applied during the design, construction, and
alteration of buildings and facilities covered by Titles II and III of the ADA
to the extent required by regulations issued by
Federal agencies, including the Department of Justice and the Department of
Transportation, under the ADA.
