Hearing Conservation

By Bob DelPrete

Former Southern Region Safety/Health Rep

At times, members ask about their rights on the workroom floor with regard to hearing protection. I believe the reprint of the letter that appears below should answer any general questions that may arise. If not, please feel free to get in touch with me to answer any specific questions you may have that are not adequately addressed in this letter.

July 12, 2001

Mr. Bruce Wolanin
PO Box 21831
Waco, Texas 76702

Dear Bruce:

Thank you for attending the safety issues workshop on June 27 in Houston, Texas. I hope you found the sessions to be informative and useful. At the workshop, you expressed an interest in receiving additional information related to hearing protection. While you were not specific with regard to the questions you needed answered, OSHA hearing protection for workers is detailed in 29 CFR 1910.95.

 This standard mandates that an employer shall institute a hearing conservation program whenever employee noise exposures equal or exceed an 8-hour time weighted average sound level of 85 decibels. A decibel (dB), as you probably know, is the unit used to measure sound intensity. Hearing experts agree that exposure to this much sound over an 8-hour day will cause gradual hearing loss in a significant number of individuals. Such a sound level of this magnitude would equal that of a lawnmower, the sound of shop tools, or truck traffic. 

For comparison purposes, normal conversation is rated at 60 dB and a car horn is rated at 110 dB. Experts agree that if you need to raise your voice to be heard by another worker on the workroom floor, there is a good possibility the sound level is at or above 85 dB. Sounds that approach 130 dB are sounds that will cause pain for most individuals, and immediate damage.

If you believe that the noise in your particular workplace is a safety problem, you can proceed with the following courses of action (assuming you’re a steward):

1. You could request in writing (with proof of receipt) that your Human Resources/Safety person conduct sound level readings (with affected workers or their stewards as witnesses, as provided for in the standard) at various places on the workroom floor where it is believed the sound is excessive, OR …
   
2. You or your local could purchase your own sound level meter and take your own readings at various places on the workroom floor (with permission to conduct such an investigation) where it is believed the sound is excessive; then …
3. File a grievance if management refuses to do #1 above, refuses to allow you to do #2, or if the readings taken are at, or above, 85 dB. If the readings are close to the 85 dB range, grieve that an agreed upon contractor conduct a noise survey to determine accurate, indisputable readings, with affected workers or their stewards as witnesses.
   
4. File a complaint with OSHA if any of the above grievances are denied. Ask that OSHA conduct a noise survey and that the USPS conform to 29 CFR 1910.95. If you attended the session in Houston entitled "How to File a Complaint with OSHA" you should be familiar with this procedure. If not, contact me and I can provide details. If the specified level is reached or exceeded, the standard states that management, in addition to the hearing conservation program, must so inform each affected employee and also institute engineering or administrative controls to resolve the situation. Some examples of "engineering controls" that seem most applicable in postal situations are as follows:

Absorption: a process whereby material is used to absorb sound energy inside a building; the material could be fiberglass, mineral wool, or foam.

Cladding: structural members are covered to reduce sound; the material is a heavy blanket made from fibrous material mixed with another more substantive material.

Damping: a plastic based material is applied to various steel panels to reduce vibration; an acoustical engineer decides which panels will receive the material.

Effective maintenance: well-maintained machinery and equipment can produce lower sound levels, as can the replacement of worn parts. Rubber mounts: a small quantity of rubber is placed between vibrating surfaces to reduce sound levels.

An example of an "administrative control" applicable to this particular circumstance is the effective rotating of employees in and out of high and low noise areas. If such engineering or administrative controls are cost prohibitive or simply inadequate, management must then issue personal protective equipment, i.e. hearing protectors.

In general, hearing protection comes in two forms: earplugs (disposable or reusable pre-molded) and earmuffs. Earplugs are small inserts that fit into the outer ear canal, blocking the ear canal with an airtight seal; they can be utilized with a headband device or with a cloth cord that drapes over the shoulders. Earmuffs fit over the outer ear so the entire ear canal is blocked, and they are held in place with an adjustable band. Note that radio headphones or cotton balls are not considered a form of hearing protection. Properly fitted earmuffs or earplugs reduce noise 15 to 30 dB, and they must be worn continuously around noisy machinery to be most effective. Furthermore, they must also provide the wearer with a complete air seal to afford the most protection. If properly adorned, hearing protectors will make your own voice sound deeper and louder.

Also, workers shall be provided a choice of hearing protection as per the standard. Combined use of earmuffs and earplugs should be considered when sounds approximate 105 dB.

Should sound level readings in a workplace equal or exceed an 8-hour time weighted average sound level of 85 dB, the employer must also conduct audiometric (hearing) tests. A baseline audiometric test must be done within 6 months of an employee’s exposure to noise levels at or
above the "action level" of 85 dB, and then, at least annually, the employer shall obtain a new audiogram for each exposed employee.

While the information taken from the standard represents its key points, there are other parts that could also apply, in time. If familiarization of any of these other parts of the standard becomes
necessary, contact me and additional clarification will be provided. If after reviewing this information additional questions develop, again please do not hesitate to communicate with me and answers will be provided as soon as possible.

Very truly yours,

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Last modified: July 13, 2007