BCTD Testimony on Hearing Conservation Standard for Construction
THE BUILDING AND CONSTRUCTION TRADES DEPARTMENT OF THE AFL-CIO RESPONSE TO OSHA’S ADVANCED NOTICE OF PROPOSED RULEMAKING ON HEARING CONSERVATION IN CONSTRUCTION
Enclosed is the Building Construction Trades Department response [available here] to OSHA’s request for information and comments concerning the revision of the construction noise standard to include a hearing conservation component that provides a similar level of protection to construction workers as in the general industry.
We believe that the agency should develop a standard that would be at the same time protective and easy for both employers and employees to comply with. For that reason we have rejected the time-weighted-average (TWA) approach where workers are placed in the program based on their average exposures over 85 dBA. As workers in construction are constantly changing jobs (and often employers) and their work can vary from day to day, such an approach would necessitate using dosimeters to monitor every employee’s exposure every day. Workers may be in the program one day and not the next. This makes no sense. A more rational approach is to require hearing protection for any tasks that are presumed to expose workers to more than 85 dBA (based on existing monitoring data) or when they are in an area that is over 85 dBA. This can be easily and inexpensively determined using a sound level meter. Areas over 85 dBA can be cordoned off to restrict unnecessary personnel those who don’t have to be there from entering, with warning signs that alerts those entering that hearing protection is required.
Training is another important part of any effective hearing conservation program. The question is who should be trained and how often. Based on the data we have on hearing loss in construction, everyone is at risk. All workers should have some training on hearing loss prevention. We propose that all workers get some training at least annually. The training may be done as a series of toolbox talks, which increases the feasibility in construction. We recommend that the training be interactive and include demonstrations (such as audio demonstrations to simulate hearing loss and how to correctly wear hearing protection).
Hearing tests are also an integral part of an effective program. As hearing loss is gradual, too often workers don’t know they are losing their hearing until it is too late. An annual hearing test can make the situation real to workers, they can see how much hearing they have lost, speak with an audiologist, and become more motivated to protect their hearing. In other countries, this has been shown to be the key factor in the success of the program. With mobile vans and new technology, hearing testing has become affordable (about $8-10 per test) and feasible in construction.
Recordkeeping is another part of a good program. Hearing test records can be easily maintained by an employer, a central repository (like private medical records storage or an association), or even on the Internet. Workers should receive copies of their test results for their records. They should also get a card with both their test and training records to provide to their employers so that duplicate testing will not be conducted. It is important that during annual hearing tests workers have their previous records for comparison.
We believe this approach is feasible and protective and makes a lot of sense for the construction industry.