Charles N. Jeffress
Laborer's Health and Safety Fund
National Conference on Preventing
Hearing Loss in Construction
Washington, D.C.
March 30, 2000
- Last year a Princeton music history professor made the news when he sued the
rock band, Smashing Pumpkins. After taking his son to a concert, this man
suffered a hearing loss in one ear and ringing in both ears-despite wearing
industrial-strength hearing protection. And that's just one exposure!
- Yet construction workers are bombarded by noise day in and day
out-jackhammers, chipping guns, bulldozers-the list goes on and on. So it's not
surprising that several recent studies have shown that a large number of
construction workers experience work-related hearing loss. In fact, we estimate
that 750,000 construction workers are currently exposed to hazardous levels of
noise on the job. That's about 15% of all construction workers.
- We need to address this health concern on several fronts. We need a stronger
standard. We need to look at enforcement of the current requirements. And we
need to vigorously pursue cooperative approaches, creative strategies and outreach
and education as well.
- When it comes to occupational hearing loss, there are two enemies-noise and time.
The louder the noise and the longer the time, the greater the risk of loss.
- Already, too much time has passed since OSHA adopted the hearing conservation
standard for general industry in 1983. At that time, we pledged to develop a
separate, similar requirement for construction. But we've yet to deliver on that
promise.
- Someone once said, "You will never find time for anything. If you want time, you
must make it." I want you to know that OSHA is determined to make the time to
develop a more detailed hearing conservation standard for construction. And we
intend to issue an advance notice of proposed rulemaking this year.
- To preserve worker hearing, we need to move beyond a simple exposure standard
and a brief notice that employers need a hearing conservation program. That's just
not enough. Employers need more guidance, and workers need more protection.
- Our general industry standard is much more specific. It includes requirements for
noise monitoring and audiometric testing. It requires employers to notify
employees of overexposures and train them about the dangers of noise. The
general industry standard lists detailed requirements for hearing protection
devices. It includes an action level as well as a permissible exposure limit, so that
employees get the benefits of baseline testing and hearing conservation programs
earlier. And it requires employers to keep records so that hearing loss can be
measured.
- The construction standard includes none of these requirements. And that means
far too many workers don't have the protection they need.
- Highway and street construction workers, carpenters and those involved in
concrete work are the most likely to be exposed. But boilermakers and iron
workers face the highest exposure levels, primarily as a result of pneumatic tool
use.
- The highest exposures are most likely to occur during the structural stage of
construction work, during concrete work and when workers are using heavy
equipment. Finding ways to reduce noise during these activities could
significantly reduce noise levels for all workers at the site.
- We know that implementation of engineering or work practice controls to limit
noise is spotty. While everyone may don a hard hat, too few workers are wearing
the hearing protection they need.
- Noise-induced hearing loss is 100 percent preventable. But once hearing is
damaged, it cannot be restored. The loss is permanent and irreversible.
- This is a problem that has taken a backseat for far too long. And we are going to
do something about it. Our goal is to issue an advance notice of proposed
rulemaking this summer.
- We'll be asking many questions to find out the best way to proceed. Some of
these questions are very technical-such as whether the agency should adopt a
lower exchange rate. The current standard cuts permissible exposure time in half
for every increase of 5dB in noise levels. There's evidence to indicate that the
time should be halved for every 3-dB increase. That's something we need to take
a look at.
- How much hearing loss is just a part of getting older? OSHA's general industry
standard allows an age correction to account for a gradual decline in hearing, but
some recent data suggest that's inappropriate. We'll want to review the evidence
available on this issue.
- Other questions relate specifically to construction. How can we track noise
exposures and hearing loss in an industry where the average worker stays on the
job three to five years? What about the fact that many workers are employed by
very small firms?
- Another issue we need to address is accidents that occur on construction sites
because workers can't hear back-up alarms or warning signals due to excessive
noise. Or because they've already experienced hearing losses, they cannot hear
these signals if they're wearing hearing protection.
- Enforcement of the current standard poses additional problems. The construction
worksite is constantly changing. We may not inspect on a day when the noise
levels exceed the standard. But that doesn't mean that noise isn't a problem at that
site.
- Last year, federal OSHA conducted more than 18,000 construction inspections.
The great majority focused primarily on safety issues. We only cited the
construction noise standard 45 times and the hearing conservation requirements 19
times.
- Part of the enforcement difficulty is the standard itself. It's too general. That
makes violations tough to prove.
- Another problem is the changing nature of the worksite. There may be serious
noise problems at the site-but they aren't observed during an inspection.
- Nevertheless, enforcement alone is not the answer. We need to consider
alternatives as well. Just the possibility of an inspection is not going to motivate
stronger hearing protection.
- We need to explore cooperative approaches to reduce noise on construction sites.
OSHA's Voluntary Protection Program has a proven track record for reducing
injuries and illnesses of all kinds. We have expanded it to include short-term
building projects. We have other construction partnerships as well-C.A.R.E. in
Florida and PRIDE in the St. Louis area.
- We signed a partnership agreement with AGC two years ago and one with the
Associated Builders and Contractors six weeks ago. Through these agreements
we will establish additional local partnerships with OSHA area offices, contractor
groups and unions.
- All of these partnerships share one common denominator-they require a strong
safety and health program. And that program should cover noise along with other
hazards.
- The Laborers have also been forging partnerships. I was delighted to learn about
the "buy quiet" initiative that The Laborer's Health & Safety Fund is working on.
- Engineering controls are certainly the best way to go. Reducing noise at the
source is so much more effective than personal protective equipment, even though
it's difficult. But we know that's possible, thanks to noise control research on
mining equipment. Mufflers and insulation can reduce noise significantly for
operators.
- We also know that low-noise equipment sells. Europe is ahead of us in this
regard. Germany's Blue Angel program is one example-ranking equipment for
noise much like we evaluate fuel efficiency for cars or electricity consumption for
household appliances. And then encouraging manufacturers to market and
contractors to buy the quiet equipment.
- I also like the idea of developing maintenance guides for equipment purchasers. If
contractors maintain equipment properly, that can reduce noise as well.
- Initiatives like this-involving federal authorities such as the Army Corps of
Engineers, manufacturers, unions and contractors-can effect significant changes
more rapidly than rulemaking. I encourage you to keep pursuing them.
- OSHA is also looking at hearing loss as part of its recordkeeping rule revision.
When we publish a final recordkeeping rule this summer, you will see a new
emphasis on recording hearing loss.
- We know that hearing loss is seldom recorded. So the best estimates we have
represent an undercount. In 1997, employers reported that fewer than 500 workers
experienced hearing losses that required them to take time off work. Clearly this
approach doesn't come close to capturing the real extent of the problem. We
hope that the new recordkeeping requirements, which take effect next January,
will improve reporting and improve the statistics from BLS.
- Another goal of mine is to expand OSHA's ability to provide outreach and
education. We know we need to do more to help employers who want to do the
right thing.
- With additional funds in 1999 and this year, OSHA has added 44 new compliance
assistance officers in its area offices. These specialists are the point of contact for
employers and employees looking for information on workplace safety and health
or seeking specific training, like help in reducing noise on a construction site.
- The President's budget for 2001 includes a $12 million increase for outreach and
education, including more staffers dedicated to compliance assistance. This will
enable OSHA to put a compliance assistance specialist in every area office as well
as fund development of training and outreach materials for these staffers to use.
That means that virtually every business covered by federal OSHA will have
someone nearby to call for help. And we will be encouraging them to do that.
- Excessive noise is a problem that affects more Americans than any other
occupational injury. It's also harder to address than almost any other hazard on
construction sites.
- But it's a critical issue. How many retired construction workers miss their
grandchildren's first words because their hearing has been damaged during a
lifetime devoted to building for others? Too many.
- Together we can find solutions to send every construction worker home whole,
healthy-and hearing well. I applaud your bringing this issue to the forefront. And
I promise to work with you.
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