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Prepared by Laborers' Health and Safety Fund of North America:

Scott Schneider, MS, CIH
Director of Occupational Safety and Health

Walter A. Jones, MS
Senior Safety and Health Specialist

Travis Parsons, MS
Safety and Health Specialist

Hearing Conservation Program Provisions

Do the general industry requirements need to be altered to reflect the unique characteristics of the construction industry? For example, what methods have construction employers adopted to obtain baseline and periodic audiograms and to keep the records of these tests up-to-date and accessible? What approaches have employers found useful in achieving effective hearing protection device use in this industry? OSHA is particularly interested in receiving information on the results of hearing loss prevention program evaluations in the construction industry.

Hearing loss in construction is rampant. Data from audiometric testing of members of the Laborers’ Union has shown 39% of members (average age 51) have significant loss. NIOSH has estimated that a 25-year-old construction worker has the hearing of a 50 year old without occupational noise exposures. And the impact of their health and quality of life is enormous. As attested to at our National Conference on Preventing Hearing Loss in Construction (March 2000) (co-sponsored by NIOSH and OSHA), the impact of a worker’s career and life can be devastating. Every activity of their daily lives is affected, from talking on the phone to medical encounters, their lives are made more difficult and quality of life suffers. The lack of a specific hearing conservation standard for the past 19 years (since the general Industry Requirement was promulgated) has been a big impediment. This problem is enormous and it is essential that we move forward quickly and start to solve it.

The General Industry Standard would not be practical in construction. All the elements of a good hearing conservation program (e.g., monitoring, hearing protection, training, audiometry, etc.) are still necessary, but they have to be implemented in a manner to suit the unique characteristics of the construction industry. Workers are changing jobs, tasks and employers on a regular basis. Some jobs may last only a day. Others can last several years. Many workers will work for 6 or more different employers each year. Others may stay with one employer for 20 years. A worker’s noise exposure can be unpredictable as their tasks change from day to day. If we were to trigger coverage based on a TWA of 85 dBA or above, every worker in construction would have to be monitored every day on the job. That would be unworkable and infeasible.

Given the small size of most construction companies it is not possible for them to dedicate a full-time safety and health professional to exposure monitoring, noise control efforts, audiometric testing and training. Therefore, it is important that a standard for the construction industry give contractors practical guidance on how to best protect its workforce and to give contractors the flexibility to join together to provide monitoring, testing, training, and recordkeeping.


There is substantial evidence that hearing loss is a major problem among construction workers and that a comprehensive hearing conservation program can effectively reduce hearing loss in this industry.

  • Waitzman and Smith (1999) reviewed data from the 1960-1975 NHANES survey and found that construction workers had a 3.5 times higher risk of hearing loss than white collar workers.
  • Hearing loss among construction equipment operators was recognized as a problem 35 years ago in studies by LaBenz, Cohen and Pearson (AIHA Journal March-April 1967) and Ottoboni (1967) of 56 operators.
  • In British Columbia, a study of 5,000 construction workers in the 1980s found 49% had a noise-induced hearing loss (Schneider, et al 1995). More recent data from British Columbia showed that the average construction worker has the hearing of a non-exposed worker 20 years older (Center to Protect Workers Rights [CPWR], 2002). Even electricians and truck drivers, who tend to have lower exposures, had significant hearing loss. The data also show that over the past 15 years a comprehensive hearing conservation program had significantly reduced hearing loss among construction workers in British Columbia.
  • In the 1970s over a million hearing tests were given to construction workers in Sweden (about 90% of all construction workers in the country) and they were found to have significantly more hearing loss than white collar workers (Schneider, et al, 1995). Following this population over a 17-year period showed that a significant hearing conservation effort dramatically reduced hearing loss among construction workers.
  • Brühl and Ivarsson (1995) also reported on hearing loss among sheet metal workers in Sweden and, following them over a 15 year period, showed the effectiveness of a comprehensive hearing conservation program.
  • Workers compensation data from Washington State (Daniell, et al, 1998) show that from 1984-1991 construction trades filed 11% of hearing loss claims. Construction normally represents about 5-6% of workers nationwide (CPWR, 1998).
  • Hattis and Makri (1999) did an analysis of expected hearing loss in construction for OSHA and showed hearing loss in construction to be a “significant national problem” and that a “serious hearing conservation effort involving annual audiometric exams and other noise control and hearing protection measures can yield demonstrable reductions in hearing loss.”
  • In 2001, the Laborers Union had hearing tests performed at their annual Trifund Conference. Of 255 people tested (average age 51.6 years old), 36% met the NIOSH definition (1998) of hearing impairment (average loss of 25 dB at 1,2,3,and 4 KHz) and many of those tested were no longer working at the trade (e.g., were business agents) and had not been for several years. In 2002, another hearing screening at the Laborers Training Center in West Virginia showed similar results with 46% of those tested having material impairment (average age 48).
  • A recent survey of 2,375 construction workers in the US who worked at DOE facilities (average age= 58, average years at the trade= 23) showed that 60.3% had significant hearing loss (by the NIOSH 1998 criteria). Even 9% of workers under 35 had hearing loss and by age 50 half of all workers experience hearing loss (CPWR, 2002).

Methods of Compliance

In paragraphs (c) and (d) of the general industry noise standard (29 CFR 1910.95), OSHA requires the employer to conduct an initial noise evaluation when exposure is expected to exceed 85 dBA. If this requirement was applied in a construction setting, a new evaluation might be required for each new construction site. Alternatively, in the asbestos standard (29 CFR 1926.1101(e)) and lead standard (29 CFR 1926.62(d)(2)) for construction activities, OSHA adopted a different approach of identifying tasks that are presumed to have high exposures and workers engaged in these tasks are protected by a combination of engineering and administrative controls supplemented by the use of personal protective equipment. Which approach is more appropriate to evaluate and control noise exposures in construction? Please provide noise data from construction sites to support your position. If a certain set of procedures or tasks were identified by OSHA as having presumed significant noise exposure, which are the best criteria to use: Equipment type, task type, or job title by type of construction and phase of work? OSHA also believes that the time of tool use or time spent at a task is an essential or required element in any exposure calculation. Please provide your experience and data regarding the relative efficacy of the above criteria. The British Columbia regulation requires employers to implement a written program that includes noise measurement, education and training, engineered noise control, hearing protection, posting of noise hazard areas, hearing tests, and annual program review (Ex. 2-9).

The British Columbia program presumes that employees in specific construction occupations are routinely exposed to noise in excess of the exposure limits. These occupations are carpenters, plumber pipefitters, sprinkler installers, mobile equipment operators, steel erectors, welders/fabricators, sandblasters, drillers, electricians, concrete workers operating concrete pumps, vibrators, jack hammers or powered finishing equipment, and drywallers shooting track or boarding (Ex. 2-10). Are the trades identified in British Columbia as highly exposed, and therefore presumptively covered under the HCP, reasonable and comparable to United States conditions? Are there other occupations that should be presumed to be noisy enough to be a part of a hearing conservation program?

Investigators at the University of Washington are also conducting a series of studies on Washington state construction apprentices and journeymen. These study populations include bricklayers, carpenters, operating engineers, ironworkers, electricians, insulation workers, sheet metal workers, laborers and cement masons. (Ex. 2-12, 2-13) These studies will provide additional noise-related risk data on a current U.S. construction population. Are there any other investigations on the effects of hearing conservation programs in other populations of U.S. construction workers? If so, please provide study descriptions and data.

The approach the agency has taken to reduce occupational noise hazards in the general industry would not be practical for construction. Washington State requires construction industry compliance with the general industry standard. However, the standard has proven to be unenforceable in construction, and as a result, excessive noise exposures are common (as documented by the University of Washington) and hearing loss is epidemic (as documented by the Center to Protect Workers Rights and the University of Washington). The best approach to address the distinctive characteristics of construction worksites is for the agency to develop a task-based standard, like in lead and asbestos, where hearing protection is triggered by tasks or work areas where exposures are presumed to be over the action limit (85 dBA). The agency should allow the employer to rebut a presumption by taking exposure measurements using a sound level meter (instead of a dosimeter). By allowing the employer to use a sound level meter instead of a personal dosimeter the employer would be able to dramatically reduce the costs associated with compliance monitoring and make protection easier.

Training should be provided to all construction workers. All construction workers are at risk of hearing loss over their career and the cost of providing hearing conservation training to all workers is likely to be less than the cost of determining who is most at risk and only providing training to that subset. That risk determination would likely be wrong as the following day that worker could easily be doing a riskier task and qualify.

Audiometry is an essential part of any hearing conservation standard. The insidious nature of hearing loss means that only by testing can you show exactly how much loss is occurring and make the risks real to workers. The experience in Sweden and British Columbia, where annual testing was provided to all construction workers, has been that the annual test was the most important motivating factor for workers for proper use of hearing protection, allowing the audiologist an annual opportunity to reinforce and educate workers on the need for protection.

The cost of audiometry has dropped dramatically to about $8 a test. Mobile vans and improvements in technology make provision of audiometry in construction much easier. Hearing tests can be required just as exams are required now for asbestos, lead or hazardous waste work or for respirator use. Workers will likely get the hearing tests and carry a card to document the test date, and an employer will not have to pay for a test if the worker has had one in the past year.

We believe that all construction workers should have a hearing test each year because most workers are occupationally exposed to hazardous noise levels and they are not aware of the amount of hearing loss that has occurred until it is too late. The costs associated with addressing the needs of the hearing impaired (e.g. hearing aids start at $1,500.00, etc.) is much greater than annual tests for their career in construction ($300- $400 over career).

Record keeping also will require an innovative approach. Under the current system, construction workers working less than one year for an employer can be given a copy of their medical records. Hearing test records are not very complicated. Systems have been developed for electronic storage of these records on a “smart card.” Alternatively, there are web sites that exist solely for the storage and retrieval of audiometry records (e.g. The costs are minimal (less than $2 a year) and are likely to come down as more people use the system. It is important, however to retain audiometric records for at least 10 years so the progression (e.g. deterioration) from year to year can be identified and comparisons can be made at the time of the subsequent exam.

As in General Industry, employers should still be required to evaluate annually the efficacy of their program. This can be accomplished through a variety of means. Reviewing audiometric test results is a good measure for those contractors whose employees have been with them over a year (probably a small percentage). Other measures contractors can use are, charting the percentage of workers wearing hearing protection appropriately and/or the percentage of workers that have been trained.

In those places where comprehensive hearing loss prevention programs have been implemented in construction (e.g. British Columbia and Sweden), they have had dramatic successes reducing hearing loss significantly. Data from these programs is attached. Hearing conservation programs in construction can work and a sensible program could do a lot to attack this major problem in the industry.

Monitoring/ Repeat Noise Monitoring

Paragraph (d)(1)(i) of the general industry noise standard (29 CFR 1910.950 addresses noise exposure monitoring. It requires monitoring when information indicates that any employee's exposure may equal or exceed an 8-hour TWA of 85 dBA. Employers may design their own sampling strategy so long as employees above this action level are included in the program. How much noise monitoring is currently being done at construction sites? Should OSHA provide specific sampling strategies for the construction industry? Should these strategies be mandatory or recommended? When is exposure monitoring appropriate in the construction industry? What criteria should trigger noise exposure monitoring? Are there any circumstances in the construction industry where area monitoring would be appropriate?

Would employers know when to repeat noise exposure monitoring? Should there be a more specific requirement, such as the NIOSH recommendation for re-monitoring every 2 years or if workers are developing significant threshold shifts (STSs)(Ex. 2-1)? Would such a requirement be useful, feasible, or effective in the construction industry? Are there any alternative monitoring schemes that would be easier for construction employers to follow that would obtain the same objective?

There is very little noise monitoring being conducted on construction worksites. A worker’s noise exposure is unpredictable because their exposure changes from day to day. The construction noise standard requires contractors to monitor noise exposure levels in a manner that will accurately identify employees who are exposed to noise at or above 90 decibels (dB) averaged over 8 working hours (the 8-hour time-weighted average [TWA]) For construction contractors, this is unworkable and it is infeasible to monitor each task at every noisy worksite to determine if workers are exposed to a 90 dB 8-hour TWA.

Most construction jobs and tasks are varied and short-term. By the time an exposure determination has been made with a dosimeter, the job or task has been concluded. To the contractor, the importance of conducting such measurements is pointless.

Therefore, we recommend that OSHA require specific work procedures in lieu of the sequence of noise monitoring with comparison to permissible exposure limits to determine initiation of controls.

Given that construction workers perform a variety of tasks and work around a variety of machinery at variety worksites, OSHA should require workers to wear hearing protection devices when they:

1) use or work near certain equipment that exposes them to noise levels of 85 dBA noise levels or above; and

2) work in other high noise jobs or areas, such as enclosed areas (tanks, boilers, etc.), that expose them to noise levels of 85 dBA.

Determining which workers should be protected on the basis of tasks rather than exceeding the OSHA TWA will be more practical and less costly for contractor compliance and more protective for workers. Also, employers will not have to obtain a personal dosimeter reading for each task on a noisy worksite, it will be less costly in both time and money.

Because of the transient nature of working conditions in construction, both the worker and the employer would be better served in most cases by simply adopting acceptable work procedures at the start of a job where potential exposure exists and dispensing with the costly and time consuming monitoring process. The advantage is that the worker is protected from the beginning, and the employer is not required to pay for monitoring a work operation, which may be completed before the results of the monitoring are available.

In order to implement this strategy, OSHA, relying on the many different studies that have been conducted on occupational noise sources in construction, should develop a list of construction tools and tasks (as in figure 1) that are commonly associated with excessive noise levels. Employers should be required to provide protection to all workers who perform the tasks listed. Enclosed are several such studies for the agency to use in defining the list of Common Construction Tasks.

Figure 1:
Common Construction Tools or Tasks Common Construction Tools or Tasks


Common Construction Tools or Tasks

Noise Level
dBA, Leq.


Air Arching Gouging



Air Grinder



Air Track Drill



Bobcat Driver



Bulldozer - No Cab



Bulldozer - Insulated Cab



Bulldozer - No Muffler



Chipping Concrete



Circular Saw and Hammering






Compactor on Cab



Compressed Air Blower (100 PSI) Blowing Out Cuts




62-92 (79 avg)


Concrete Finishing - Electric Grinder, Chipping and Patching



Crane - Uninsulated Cab



Crane - Insulated Cab



Dozers, Dumpers



Electric Drill






Foreman (Concrete Vibrator Used for Pour)



Front-End Loaders



Grader, Trucks, Concrete Pumps & Mixers, Generators



Hammer Drill, 1/4" Bit Drilling Holes into Concrete



Hydraulic Breakers



Impact Wrench



Jack Hammer




*CSM – Dru Sahai, “Hearing Conservation- How to Prevent Noise-Induced Hearing Loss in Construction,” Construction Safety Magazine, August, 2000.
**BC – Heather Gillis and Christine Harrison, “Hearing Levels and Hearing Protection Use in the British Columbia Construction Industry – 1988-1997,” Workers’ Compensation Board of British Columbia.
***AIHA – Richard Neitzel et al., “An Assessment of Occupational Noise Exposures in Four Construction Trades,” American Industrial Hygiene Association Journal, 60: 807-817 (1999).

Because the possibility exists that a particular worker, task, or worksite or a piece of equipment does not expose the worker to 85 dBA, the employer should be allowed to perform exposure monitoring to rebut the presumption.

A sound level meter can be used to survey an area to identify work areas where employees’ exposures are above or below 85 dBA. Instruments used for monitoring employee exposures should be carefully checked or calibrated before use to ensure that the measurements are accurate. Monitoring should be repeated whenever a change in process or equipment has occurred in order to establish whether tasks that were previously assumed to be below 85 dBA may now exceed the limit.

Secondary Noise Sources and Hazard Communication

Are there other methods, besides direct employee noise monitoring on a site-by-site basis that would characterize elevated noise exposure to other or co-workers who are not using tools or equipment generating loud noise? Also provide, if available, information on the trades, type of construction, tasks, tools or equipment used, and the range of exposure levels and distances from noise source. Has any exposure or prediction modeling been done in this area? How can information concerning expected or measured secondary exposure be incorporated into training requirements, hazard warnings and the general phasing of work in different types of construction?

Many of OSHA health standards require the employer to establish “regulated areas.” The regulated area is defined somewhat differently in each standard, but in general the boundaries are defined either by the permissible exposure limit or action level or simply as a geographical area where there is the potential exposure to the subject material. Arsenic, asbestos, DBCP and benzene are examples of standards where regulated areas are defined as areas where airborne exposure is in excess of the PEL without regard to the use of respiratory protection.¹ The segregation of certain areas where potential exposure to toxic material exists is a good approach to worker protection in the construction industry. Access restrictions limit the number of exposed workers, and cut the costs of protective equipment and other cost items associated with supervision of exposed workers.

Bystander exposures to noise are common in construction. Workers are as likely to be exposed from noise generated by other workers or trades, as they are to be exposed to noise generated by their own work. Therefore, it is imperative that the agency require employers to establish Noise Perimeter Zones (NPZ) to protect employees as well as co-workers who are not using tools or equipment generating loud noise. This means places where noise levels are 85 dBA or more should be roped off and marked to keep out all workers who do not have to be there. All workers who need to work within the zone, must wear hearing protection.

A NPZ can be established by using a sound level meter. The safe distance from the source of the noise can be measured, and the NPZ can be set up at that distance. Measurements can be taken at several points in an area where people might be working. The employer should determine the points where the noise levels are 85 dBA or more and rope off this area as the NPZ. The area can be marked "Noise Hazard Area - Hearing Protection Required" in the same way that a "Hard Hat Area" is marked off.

This approach will work well for stationary noise sources. For mobile noise sources, like construction vehicles, noisy areas may have to be defined as adjacent to a roadway through the work area. For some sites, like building construction, vehicular traffic is mostly confined to the early stages of a project when few workers (other than the operators) are on site.

Another way for the employer to set up a NPZ is to measure the sound pressure level, using a sound level meter (SLM), at a distance from a noise source.² Measure the distance between the noise source and measurement point. Convert the sound pressure to the estimated sound power using the tables below and then calculate a Noise Perimeter.³

Another way of letting workers know hearing protection is required (other than perimeter signs) is a warning label. Build It Smart, a Building Trades Labor-Management Organization of Washington State, has developed bright yellow caution stickers to be placed on noisy equipment. The sticker specifies the measured noise level of the equipment and t


Construction sites are noisy places. Today, as a result of noise exposure, thousands of construction workers are hearing impaired, and thousands more are destroying their hearing through everyday work in the industry.

Research shows that hearing loss is a gradual and irreversible process. Without the use of audiometric tests, few workers will realize that they are losing their hearing until it is too late. This is why the LHSFNA recommends comprehensive hearing conservation programs on all construction worksites, despite the fact that OSHA currently requires only minimal protection.

Controlling noise is a challenge for construction contractors. Based on experience and feedback from contractors, Laborers and professionals across North America, the Construction Noise Control Partnership is assembling a Best Practices Guide.

The project is a living document. Click on the headings at right to see where it now stands. Click here to see or print the entire document.


Improving hearing conservation programs in construction a top priority. The Fund sponsored the first national conference on the issue and facilitated the formation of the national Construction Noise Control Partnership to advance best practices. It also provided written testimony to OSHA opposing the agency’s reversal of an earlier decision to require separate record keeping of hearing loss injuries on the OSHA Form 300 (Hearing Tests Confirm Stance), and it urged OSHA to require hearing protection for workers, not based on time-weighted average noise exposures, but on the noise levels of specific tasks and specific areas (BCTD Response to OSHA's Notice of ANPRM).

The Fund also provides training in the proper use of hearing protection. It provides a model program, Hearing Conservation for Construction Workers, to guide contractors and their safety officers in the establishment of company hearing conservation programs, and, when a signatory employer asks, the Fund’s OSH Division staff supports the model program with on-site consultation and testing.


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