1. Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
Best Practices in Hearing Conservation
Richard L. Stepkin, MS, CCC-A
Occupational Audiologist, President
Enviromed Corp
Phone:
Website:
Richard Stepkin, Audiologist

2. Hearing Conservation Objectives
Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
Hearing Conservation Objectives
Protect employees hearing
Comply with OSHA criteria
Stabilize Worker’s Compensation
Which is the most Important ??
Employees are always our primary concern, but OSHA regulations do not protect all employees for Noise Induced Hearing Loss. By setting up a Hearing Conservation Program to stabilize liability, we will more than protect employees hearing and OSHA criteria.
Unfortunately - OSHA Compliance is not a Best Practice in Hearing Conservation
Richard Stepkin, Audiologist

3. Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
OSHA Workers Comp
STS = 2k, 3k, 4kHz
Allows Age Adjustment to Age 60
Allows Waivers
85dBA(TWA) Mandatory Action Level – must have HC Program
85-90dBA(TWA) Voluntary HP
90dBA(TWA) Mandatory HP
Baseline to compare Annually
MD = .5K, 1K, 2kHz
PA = .5k, 1k, 2k, 3kHz
NJ = 1k, 2k, 3k
MD allows Age Adjustment
PA/NJ No Age Adjustment
Not tied to 85dBA(TWA)
Voluntary HP suggests it may cause a problem
Baseline to identify Pre-Existing loss
Different perspectives in looking at hearing loss from the OSHA & Worker’s Comp point of view.
Richard Stepkin, Audiologist

4. Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
OSHA NIOSH
Action Level = 85dBA(TWA)
PEL = 90dBA(TWA)
5dB Exchange Rate
85dBA = 16hrs
90dBA = 8hrs
95dBA = 4hrs
Noise Surveys = 1x
Update Periodically as needed
Hearing Protection
85dBA Voluntary except with STS
90dBA Mandatory
Hearing Protection Derating NRR
50% all type earplugs
REL = 85dBA(TWA)
PEL = REL 85dBA(TWA)
3dB Exchange Rate
85dBA = 8hrs
88dBA = 4hrs
91dBA = 2hrs
Noise Surveys = 1x
Every 2 years
Hearing Protection
85dBA Mandatory
100dBA Double Protection
Hearing Protection Derating NRR
50% Foam; 70% all other earplugs
25% Earmuffs
Different perspectives in looking at hearing loss from the OSHA & Worker’s Comp point of view.
Richard Stepkin, Audiologist

5. Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
OSHA NIOSH
Audiometric Technican
CAOHC Certified or Equivalent Certification
Hearing Testing
Baseline within 30 days of Exposure
12 Hour Quiet Time – no HP
No Mobile Service exception
Annual thereafter
+100dBA(TWA) every 6 months
Test Environment
Must meet ANSI Criteria
Audiometric Technician
CAOHC Certified; Competence to Supv; Microprocessor Audiometer
Hearing Testing
Baseline within 6 months of hire
14 Hour Quiet Time – incl HP
Mobile Services – up to 1 year
HP is Mandatory
Annual thereafter
Test Environment
Well above ANSI Criteria
Different perspectives in looking at hearing loss from the OSHA & Worker’s Comp point of view.
Richard Stepkin, Audiologist

6. Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
OSHA NIOSH
Audiogram Review
Employee Notified if STS
STS = 15dB from Baseline at any one test frequency .5k-6kHz
Retest within 30 days
STS Follow-up Action
Notify EE within 30 days
Educate effects of Noise on Hearing
Re-Fit HP – Select Higher NRR
STS Log 300 Recordable
Not indicated – a Non-NIOSH issue
Use OSHA Form for Work Injury
Audiogram Review
Employee Notified if STS
STS = 10dB Avg above Baseline at 2k, 3k, 4kHz.
Retest within 30 days
STS Follow-up Action
Notify EE within 21 days
Re-Fit HP – Select Higher NRR
STS Log 300 Recordable
Current Test = 25dB Avg – no age
Difference between Baseline and Current Test is 10dB – with age
Different perspectives in looking at hearing loss from the OSHA & Worker’s Comp point of view.
Richard Stepkin, Audiologist

7. Who Uses NIOSH Criteria
Military
3dB Exchange Rate
No TWA – simply exposed – protect
European Union
80dBA(TWA) Hearing Protection available
Includes Annual Hearing Testing
Noise Survey data for all EE at or above 80dBA
85dBA Hearing Protection Mandatory
87dBA under HP is the max allowed

8. STS Determination The Facts
When is an STS Log 300 Recordable?
25dB Avg on Current Test at 2k, 3k, 4kHz – not Age adjusted
PLUS a 10dB Avg shift from Baseline – Age adjusted
OSHA assumes all STS’s are Work-Noise Related
Recordable even if part of the STS is due to work noise
Hearing Protection alone will not be a reason
How to prove the STS is “other” than work noise
Noise levels are below 82dBA
Medical and/or Audiologic Evaluation justifying why the STS is not work-noise related

9. STS Determination The Professional
Work closely with an Audiologist or Physician:
Company controls the Referral Source & Pays for Evaluation
Not Insurance – Not a HIPAA issue – Gets you a Report
This is about Surveillance – Not a Medical referral
Educate them on your product operation & HCP
Know they understand the intent of the referral & Log 300
Provide them good Job Description info (past & present)
Provide them Current Noise Levels (Dosimetry and SLM)

10. STS Determination Audiologist Evaluation
Evaluation includes as a minimum:
Air-Bone-Speech Audiometry
Otoscopic Exam
Detailed Hearing History
Employee one-on-one consultation

11. STS Determination The Report
Look at all factors affecting hearing, not just work noise.
Consider all noises: military, recreational, prior jobs, hunting or target shooting, lighting firecrackers etc.
Threshold patterns relative to noise exposures, length of employment, use of hearing protection
Does the Report “justify” why the STS is or is not work noise related

12. Best Practices in Loss Prevention
Best Practices in Hearing Conservation
ASSE Luncheon Salisbury MD Wed May 7th, 2014
Best Practices in Loss Prevention
Noise Surveys every 2-3 years – the more data the better
Mandatory HP at 85dBA regardless of time exposed
Mandatory Audiometry at 85 dBA regardless of time exposed
Professional Reviewer of test data beyond OSHA criteria
Ask for an “Early Warning” of EE’s getting close to STS (8.6 – 9.9 shifts)
Consider the State Compensation criteria in the review process
Use a dependable Referral Source for STS Determinations
Education the Professional and provide all information necessary to make a justifiable Professional Opinion based upon all facts
Richard Stepkin, Audiologist