Evaluate your hearing conservation program

By: Ray Chishti

Publication: Employee Safety Management Today

Date Posted: 07/14/2021

Five key areas to avoid in hearing conservation programs

Failures or deficiencies in hearing conservation programs are often a result of several inadequacies in managing the program. To effectively manage a program, employers should begin by reviewing the following five areas:

  1. Training and education,
  2. Supervisor involvement,
  3. Noise measurement,
  4. Monitoring and recordkeeping, and
  5. Administration.

Managing a hearing conservation program is often a time-consuming task that requires multiple company resources. Use the lists below as a convenient way to assess any gaps in your workplace’s program.

Training and education

Inadequacies in the training and education of noise-exposed employees and those who conduct elements of the program are often critical factors in an ineffective hearing conservation program. Ask:

  • Has training been conducted at least once a year?
  • Did a qualified instructor provide the training?
  • Was the success of each training program evaluated?
  • Is the content revised periodically?
  • Are posters, regulations, handouts, and employee newsletters used as supplements?

Supervisor involvement

Data indicates that employees who refuse to wear hearing protectors or fail to show up for hearing tests frequently work for supervisors who might not be committed to the employer’s hearing loss prevention programs. Ask:

  • Have supervisors been provided with the knowledge required to supervise the use and care of hearing protectors by subordinates?
  • Do supervisors wear hearing protectors in appropriate areas?
  • Have supervisors been counseled when employees resist wearing protectors or fail to show up for hearing tests?
  • Are disciplinary actions enforced when employees repeatedly refuse to wear hearing protectors?
Noise measurement

For noise measurements to be helpful, they need to be related to noise exposure risks or the prioritization of noise control efforts rather than merely filed away. In addition, the results need to be communicated to the appropriate personnel, especially when follow-up actions are required. Ask:

  • Were the essential/critical noise studies performed?
  • Was the purpose of each noise study clearly stated? Have noise-exposed employees been notified of their exposures and appraised of auditory risks?
  • Are the results routinely transmitted to supervisors and other key individuals?
  • Are results entered into health/medical records of noise-exposed employees?
  • Are results entered into shop folders?
Monitoring and recordkeeping

The audiometric technician’s skills, the audiometer’s status, and the quality of audiometric test records are crucial to hearing loss prevention program success. Use information from audiometric records and those who administer the tests to help answer the following questions. Ask:

  • Has the audiometric technician been adequately trained, certified, and recertified as necessary?
  • Do on-the-job observations of the technicians indicate that they perform a thorough and valid audiometric test, instruct and consult the employee effectively, and keep appropriate records?
  • Are records complete?
  • Are follow-up actions documented?
  • Are hearing threshold levels reasonably consistent from test to test? If not, are the reasons for inconsistencies investigated promptly?
Administration

Keeping organized and current on administrative matters will help the program run smoothly. Ask:

  • Have there been any changes in federal or state regulations? Have the hearing loss prevention program’s policies been modified to reflect these changes?
  • Are copies of company policies and guidelines regarding the hearing loss prevention program available in the offices that support the various program elements? Is the company attentive to requests for hearing protectors or other hearing loss prevention equipment?
  • Is the performance of key personnel evaluated periodically?
  • Is there any link between the failure to hear warning shouts or and accidents or injuries occurring?

About the author
Ray Chishti - EH&S Editor

Ray is an editor at  J. J. Keller & Associates, Inc. and has over 12 years of EH&S experience in a variety of industries, including EPC projects, fossil fuel power plants, gas distribution and transmission, and electrical transmission work.

Expert Help Icon

Have a compliance question for Ray? The J. J. Keller Expert Help tool provides you direct access to Ray and other trusted experts to help answer your toughest compliance questions.