Twenty years ago, OSHA recognized the unique character of the construction industry when it exempted the industry from compliance with the hearing conservation provisions of the general industry standard. Unfortunately, OSHA never promulgated an alternative.
Hearing Loss in Construction
What the Data Show
Construction workers have a 3.5 times higher risk of hearing loss than white-collar workers (Waitzman & Smith; 1999).
Of 5000 construction workers in British Columbia in the 1980s, 49% had noise-induced hearing loss (Schneider, et al; 1995).
The average construction worker has the hearing of a non-exposed worker 20 years older (CPWR; 2002).
Construction workers in Sweden in the 1970s had significantly more hearing loss than white-collar workers (Schneider, et al; 1995).
A comprehensive hearing conservation program in Sweden produced dramatically reduced hearing loss among sheet metal workers (Bruhl & Ivarsson; 1995). · Though between five and six percent of the workforce in Washington, construction workers filed 11% of hearing loss claims (CPWR; 1998).
Of 2375 construction workers who worked at DOE facilities, 60.3% had significant hearing loss (CPWR; 2002).
“For different reasons, workers, management and the government have felt that, given the diverse conditions on construction worksites, the best we can do is supply ear plugs and rely on the workers to make good judgments as to when to use them,” says LHSFNA Senior Safety and Health Specialist Walter Jones. “In the union sector, we also have a lot of training to encourage their use. Nevertheless, too many workers don’t use them all the time or don’t use them correctly, and the noise exposure is slowly destroying their hearing.”
Indeed, serious hearing loss among construction workers is commonplace.
This year, OSHA started the process of creating a construction hearing conservation standard by requesting comments from interested parties.
Scott Schneider, the LHSFNA Occupational Safety and Health Division Director, has a long history of work on the problems of noise in construction. He and Jones drafted a fresh approach to the problem. Dr. Jim Melius, Director of the New York State Laborers Health & Safety Trust Fund and Research Director at the LHSFNA, also submitted comments to OSHA in support of a similar approach.
“There’s two things needed for effective hearing conservation programs in construction,” says Schneider, “First, we need a task- or area-based protection standard rather than the traditional time-weighted-average (TWA) approach. Second, we need annual audiometric testing.”
The LHSFNA team proposed that OSHA establish a presumption that certain construction tasks cause excessive noise exposures. Then, any worker performing those tasks or working in their vicinity would be required to wear hearing protection.
“Employers could rebut the presumption by doing their own noise sampling, but this system would ensure protection until its proven unnecessary, rather than the other way around,” says Jones. “We applied the same orientation-err to the side of safety-in proposing, essentially, that hearing tests and training be required for all employees.”
However, employer allies expressed concern about the feasibility of universal testing and record-keeping. Yet, studies from British Columbia (Canada) and Sweden show clearly that annual hearing tests are the key to successful hearing conservation programs in construction. This is because hearing loss usually occurs gradually and is not noticed by workers until it develops to a substantial and irreversible extent. Testing is the only way to make workers aware of their problem and, thus, motivate them to take corrective action.
“Because most workers are employed by several contractors each year, OSHA will need to modify its usual approach to medical testing to allow unions and their employer associations to establish joint testing programs rather than requiring each employer to repeat the testing,” says Melius. To avoid the unnecessary expense of testing casual workers, the LHSFNA plan would require tests only after 30 days of employment.
“We think mobile test vans and new technology can address the feasibility concerns of our employer allies,” says Jones. Already, a number of testing companies operate with mobile units and supply tests at rates in the $8 to $10 range. Record-keeping might be done through central, web-based repositories or through individual cards (such as are often used in drug-free workplace programs).
Hearing conservation experts agree with Jones and submitted supportive testimony to OSHA. The American Academy of Audiology, the American Association of Occupational Health Nurses, the American Speech-Language-Hearing Association, the Council for Accreditation in Occupational Hearing Conservation, the National Hearing Conservation Association and Self-Help for Hard of Hearing People, Inc. all supported the LHSFNA proposals. The Building Trades Council also commented in support of the LHSFNA’s approach.
The American Road and Transportation Builders Association urged adoption of a new standard that includes task- or area-based protection but expressed reservations about the feasibility of universal testing.
After reviewing comments, OSHA may issue a proposed standard, perhaps, this year or in 2004. More information on hearing conservation is available on the LHSFNA website: https://dev2prod.lhsfna.org.