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At-Work Solutions for Noise
Hearing Conservation Program Evaluation Checklist
Training and Education
Failures or deficiencies in hearing conservation programs (hearing
loss prevention programs) can often be traced to inadequacies in
the training and education of noise-exposed employees and those
who conduct elements of the program.
- Has training been conducted at least once a year?
- Was the training provided by a qualified instructor?
- Was the success of each training program evaluated?
- Is the content revised periodically?
- Are managers and supervisors directly involved?
- Are posters, regulations, handouts, and employee newsletters
used as supplements?
- Are personal counseling sessions conducted for employees having
problems with hearing protection devices or showing hearing threshold
shifts?
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Supervisor Involvement
Data indicate that employees who refuse to wear hearing protectors
or who fail to show up for hearing tests frequently work for supervisors
who are not totally committed to the hearing loss prevention programs.
- Have supervisors been provided with the knowledge required to
supervise the use and care of hearing protectors by subordinates?
- Do supervisors wear hearing protectors in appropriate areas?
- Have supervisors been counseled when employees resist wearing
protectors or fail to show up for hearing tests?
- Are disciplinary actions enforced when employees repeatedly
refuse to wear hearing protectors?
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Noise Measurement
For noise measurements to be useful, they need to be related to
noise exposure risks or the prioritization of noise control efforts,
rather than merely filed away. In addition, the results need to
be communicated to the appropriate personnel, especially when follow-up
actions are required.
- Were the essential/critical noise studies performed?
- Was the purpose of each noise study clearly stated? Have noise-exposed
employees been notified of their exposures and appraised of auditory
risks?
- Are the results routinely transmitted to supervisors and other
key individuals?
- Are results entered into health/medical records of noise exposed
employees?
- Are results entered into shop folders?
- If noise maps exist, are they used by the proper staff?
- Are noise measurement results considered when contemplating
procurement of new equipment? Modifying the facility? Relocating
employees?
- Have there been changes in areas, equipment, or processes that
have altered noise exposure? Have follow-up noise measurements been
conducted?
- Are appropriate steps taken to include (or exclude) employees
in the hearing loss prevention programs whose exposures have changed
significantly?
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Engineering and Administrative Controls
Controlling noise by engineering and administrative methods is
often the most effective means of reducing or eliminating the hazard.
In some cases engineering controls will remove requirements for
other components of the program, such as audiometric testing and
the use of hearing protectors.
- Have noise control needs been prioritized?
- Has the cost-effectiveness of various options been addressed?
- Are employees and supervisors appraised of plans for noise control
measures? Are they consulted on various approaches?
- Will in-house resources or outside consultants perform the work?
- Have employees and supervisors been counseled on the operation
and maintenance of noise control devices?
- Are noise control projects monitored to ensure timely completion?
- Has the full potential for administrative controls been evaluated?
Are noisy processes conducted during shifts with fewer employees?
Do employees have sound-treated lunch or break areas?
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Monitoring Audiometry and Record Keeping
The skills of audiometric technicians, the status of the audiometer,
and the quality of audiometric test records are crucial to hearing
loss prevention program success. Useful information may be ascertained
from the audiometric records as well as from those who actually
administer the tests.
- Has the audiometric technician been adequately trained, certified,
and recertified as necessary?\
- Do on-the-job observations of the technicians indicate that
they perform a thorough and valid audiometric test, instruct and
consult the employee effectively, and keep appropriate records?
- Are records complete?
- Are follow-up actions documented?
- Are hearing threshold levels reasonably consistent from test
to test? If not, are the reasons for inconsistencies investigated
promptly?
- Are the annual test results compared to baseline to identify
the presence of an OSHA standard threshold shift?
- Is the annual incidence of standard threshold shift greater
than a few percent? If so, are problem areas pinpointed and remedial
steps taken?
- Are audiometric trends (deteriorations) being identified, both
in individuals and in groups of employees? (NIOSH recommends no
more than 5% of workers showing 15 dB Significant Threshold Shift,
same ear, same frequency.)
- Do records show that appropriate audiometer calibration procedures
have been followed?
- Is there documentation showing that the background sound levels
in the audiometer room were low enough to permit valid testing?
- Are the results of audiometric tests being communicated to
supervisors and managers as well as to employees?
- Has corrective action been taken if the rate of no-shows for
audiometric test appointments is more than about 5%?
- Are employees incurring STS notified in writing within at least
21 days? (NIOSH recommends immediate notification if retest shows
15 dB Significant Threshold Shift, same ear, same frequency.)
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Referrals
Referrals to outside sources for consultation or treatment are
sometimes in order, but they can be an expensive element of the
hearing loss prevention program, and should not be undertaken unnecessarily.
- Are referral procedures clearly specified?
- Have letters of agreement between the company and consulting
physicians or audiologists been executed?
- Have mechanisms been established to ensure that employees needing
evaluation or treatment actually receive the service (i.e., transportation,
scheduling, reminders)?
- Are records properly transmitted to the physician or audiologist,
and back to the company?
- If medical treatment is recommended, does the employee understand
the condition requiring treatment, the recommendation, and methods
of obtaining such treatment?s
- Are employees being referred unnecessarily?
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Hearing Protection Devices
When noise control measures are infeasible, or until such time
as they are installed, hearing protection devices are the only way
to prevent hazardous levels of noise from damaging the inner ear.
Making sure that these devices are worn effectively requires continuous
attention on the part of supervisors and program implementors as
well as noise-exposed employees.
- Have hearing protectors been made available to all employees
whose daily average noise exposures are 85 dBA or above? (NIOSH
recommends requiring HPD use if noises equal or exceed 85 dBA regardless
of exposure time.)
- Are employees given the opportunity to select from a variety
of appropriate protectors?
- Are employees fitted carefully with special attention to comfort?
- Are employees thoroughly trained, not only initially but at
least once a year?
- Are the protectors checked regularly for wear or defects, and
replaced immediately if necessary?
- If employees use disposable hearing protectors, are replacements
readily available?
- Do employees understand the appropriate hygiene requirements?
- Have any employees developed ear infections or irritations associated
with the use of hearing protectors? Are there any employees who
are unable to wear these devices because of medical conditions?
Have these conditions been treated promptly and successfully?
- Have alternative types of hearing protectors been considered
when problems with current devices are experienced?
- Do employees who incur noise-induced hearing loss receive intensive
counseling?
- Are those who fit and supervise the wearing of hearing protectors
competent to deal with the many problems that can occur?
- Do workers complain that protectors interfere with their ability
to do their jobs? Do they interfere with spoken instructions or
warning signals? Are these complaints followed promptly with counseling,
noise control, or other measures?
- Are employees encouraged to take their hearing protectors home
if they engage in noisy non-occupational activities?
- Are new types of or potentially more effective protectors considered
as they become available?
- Is the effectiveness of the hearing protector program evaluated
regularly?
- Have at-the-ear protection levels been evaluated to ensure
that either over or under protection has been adequately balanced
according to the anticipated ambient noise levels?
- Is each hearing protector user required to demonstrate that
he or she understands how to use and care for the protector? The
results documented?
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Administrative
Keeping organized and current on administrative matters will help
the program run smoothly.
- Have there been any changes in federal or state regulations?
Have hearing loss prevention program’s policies been modified
to reflect these changes?
- Are copies of company policies and guidelines regarding the
hearing loss prevention program available in the offices that support
the various program elements? Are those who implement the program
elements aware of these policies? Do they comply?
- Are necessary materials and supplies being ordered with a minimum
of delay?
- Are procurement officers overriding the hearing loss prevention
program implementor's requests for specific hearing protectors or
other hearing loss prevention equipment? If so, have corrective
steps been taken?
- Is the performance of key personnel evaluated periodically?
If such performance is found to be less than acceptable, are steps
taken to correct the situation?
- Safety: Has the failure to hear warning shouts or alarms been
tied to any accidents or injuries? If so, have remedial steps been
taken?
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Noise and Hearing Loss Prevention
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