Sample Written Program
This sample program has been prepared
to provide assistance in compliance with USA OSHA standards
and/or Best Management Practices. It should not be used
without consideration of the unique conditions and requirements
at each site. It may be necessary to modify the program
for your specific needs. You remain under obligation
to comply with all applicable standards, and use of this program
should not be considered to be a guarantee that compliance
with applicable requirements will be achieved. It is
strongly suggested that your final program be reviewed by
a qualified person. The best written program without
implementation is inadequate.
I. HEARING CONSERVATION
Hearing conservation is an important
aspect of the overall safety and health program. Workplace
noise can cause hearing loss, create physical and psychological
stress, and contribute to accidents by making it difficult
to communicate. An estimated 14 million employees throughout
the United States are exposed to hazardous noise.
Fortunately, noise exposure can
be controlled. Every effort is made to use quieter processes,
machinery, and equipment. When feasible engineering controls
do not reduce the noise level to or below the OSHA permissible
exposure limit (PEL) of 90 dB, proper hearing protectors are
used. Also, all employees exposed to noise levels above 85
dB are included in a hearing conservation program. There are
many reasons for providing an effective hearing conservation
- protecting the organization's most important
resource - employees,
- providing a safe and healthful workplace,
- complying with governmental regulations.
Management, supervisory, and employee
commitment to hearing conservation and positive attitude are
important aspects of the overall hearing conservation program.
The key elements of the organization's hearing conservation
1. Noise exposure measurements,
2. Engineering and administrative noise exposure control,
3. Personal hearing protection,
4. Audiometric testing and follow-up, and
II. NOISE EXPOSURE MEASUREMENT
The success of the company's hearing
conservation program depends on an accurate knowledge of the
existing noise environment. Accurate surveys define areas
within acceptable guidelines for noise exposure and those
areas where potentially harmful noise exposure exists. Effective
noise exposure measurement prevents possible loss of hearing
by detecting work areas where employees must wear hearing
protectors and must be tested. Therefore, the company conducts
detailed noise surveys using sound level meters that meet
the appropriate ANSI standard and are calibrated acoustically
before and after each survey. The initial area survey was
performed using measurement techniques prescribed in the OSHA
regulations. Measurements are made at employees' normal working
positions. This procedure allows an accurate estimation of
the employees' daily exposure except in instances where an
employee is required to move from one working location to
another in his/her daily routine, or when an employee's instantaneous
noise exposure levels vary markedly during the shift because
of machine cycling. In these cases, noise dosimetry is performed.
Follow-up measurements are made whenever changes in work practices
or methods may change workplace noise exposures. The results
of all measurements are recorded, and employees are notified
of their exposure level.
Noise exposure measurements have
been completed and are available for review.
III. EMPLOYEE EDUCATION
recognizes the need for a strong educational program. Therefore,
_________________________________ properly educates its noise-exposed
employees. At least annually, all new employees and those
with a time-weighted average exposure level of 85 dBA and
above are reminded of the need for an effective hearing conservation
program. The educational program consists of an initial presentation
by company personnel concerning the need for an effective
hearing conservation program. During this program an explanation
of company policy relative to the requirements of wearing
hearing protective devices is given. All employees are encouraged
to ask questions concerning the program. Topics covered include
the effects of noise on hearing, the purpose of hearing protectors,
the advantages, disadvantages, and attenuation of various
types, and instructions on the selection, fitting, use, and
care of protectors. The purpose and procedures of audiometric
testing are also discussed.
recognizes the need for continuing education in the implementation
of any safety program and, therefore, will regularly remind
employees of the necessity for preserving their hearing. This
is achieved by posting educational materials at appropriate
locations. All areas where hearing protection is required
are posted with appropriate signs in order to alert employees
to the need for wearing protective devices.
Employees not exposed to noise
levels exceeding the accepted guidelines are encouraged to
participate whenever possible in the educational programs
the fact that a loss of one's ability to hear can occur from
many causes other than industrial noise exposure, and that
for this reason all employees benefit from the educational
programs described above. Since the hearing conservation program
described in this plan protects employees' hearing from potentially-harmful
environments and could possibly alert them to potentially-harmful
physical disorders, the program is considered an additional
benefit program for employees.
The Educational Phase begins when
employees are hired and continues annually thereafter.
Until such time as engineering
and/or administrative controls reduce the amount of noise
exposure to or below the allowed limits, appropriate personal
hearing protective devices are made available and issued to
noise-exposed employees. It is recognized that the use of
these devices is considered a temporary solution to the problem
of overexposure until feasible controls are provided.
As with all safety equipment,
the wearing of hearing protection in required areas is mandatory.
All supervisors properly enforce hearing protection requirements.
Continuing failure of an employee to properly wear the protection
provided could result in the termination of employment with
The individual responsible for
issuing and fitting hearing protection has been trained by
and is under the supervision of an audiologist or physician.
Fitting and issuing of hearing
protective devices begins when employees are hired.
V. AUDIOMETRIC TESTING
The objective of the hearing conservation
program developed by ___________________ is the preservation
of the hearing of its employees. In order to achieve this
goal, an effective audiometric testing program has been implemented.
This program includes audiograms at time of hire, an initial
survey of the existing work force whose exposures equal or
exceed a TWA of 85 dBA in order to establish baselines, and
termination audiograms when possible. All employees exposed
to levels equal to or exceeding a TWA of 85 dBA receive an
annual audiometric test.
The success of the hearing conservation
program with regard to each individual employee is evaluated
by comparing annual audiograms to the baseline audiogram.
Audiogram review is performed by an audiologist or physician,
and recommendations regarding the audiometric results are
followed. This procedure, among others, helps to determine
the effectiveness of the hearing protection program, and,
as a result, ensures the protection of employees' hearing.
Initial testing of current employees
has been completed, and testing of new employees is conducted
when they are hired. Annual testing is conducted when they
are hired. Annual testing is conducted for all employees whose
8-hour TWA exposure level is 85 dBA or higher.
VI. ENGINEERING AND ADMINISTRATIVE
the desirability of controlling the existing noise levels
by engineering and/or administrative controls. Therefore the
feasibility of such controls is carefully considered. Due
to the complexity of some machinery used by the company and
in view of economic limitations, some noise levels cannot
currently be reduced to below acceptable limits. In those
cases, suppliers of machinery purchased which produces noise
levels exceeding the accepted guidelines have been notified
of the high noise levels directly by the company or indirectly
through the appropriate association(s) of which this company
is a member. The supplier has been requested to redesign machinery
where possible to meet the defined regulations. As an interim
solution, the company has considered possible redesign of
existing machinery, the building of partial or total enclosures,
and other engineering noise control procedures for reducing
the existing noise levels, where such procedures are deemed
technologically and economically feasible.
Within the limitation of work
schedules and employee skills and training background, administrative
controls have been considered. Where feasible, over-exposed
employees are moved to other areas having noise levels below
the required levels. In addition, operational procedures are
modified as necessary so that during any one twenty-four hour
period the allowed exposure times will not be exceeded.
Engineering and administrative
controls are being considered and implemented where feasible
on a continuing basis.
As indicated by the program described
above, it is the full intent of _________________ to protect
and preserve the hearing of its employees. This company routinely
reviews the program developed and outlined in this compliance
plan and attempts within the company's financial and technical
capability to improve the program where feasible.
If and when the work area noise
levels are reduced below the accepted guidelines, the company
reserves the right to terminate any or all of the phases of
the program described herein.
Since the company is also interested
in maintaining and improving the human resources of the surrounding
community, it makes available as speakers, when practical,
company employees trained in the various phases of an effective
hearing conservation program to schools, civic clubs, and
other public organizations.
(Ranking Company Official)