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What Constitutes a Hearing Conservation Program for Construction?

According to OSHA what is an effective hearing conservation program for construction?

Employers who are required to follow General Industry standards for Occupational Noise Exposure have pages and pages of requirements and guidelines that are published by OSHA.  It lays out specific requirements and responsibilities for employers, employees, and audiometric testing personnel along with other details. 

What if you are in the construction industry and you know you have a noise problem?  The standard is pretty simple: determine your noise level and if it exceeds Table D2 then feasible engineering & administrative controls must be implemented and an effective and continuing hearing conservation program must be administered.  If these are not effective in bringing the noise to acceptable levels then hearing protection must be fitted and worn to reduce the noise.  If the person in charge of the construction safety program did not read anything more than the half page standard, things would seem pretty simple.  But what is an “effective hearing conservation program?”   Discussions have occurred about proposed revisions to this standard, but no official changes yet. However, OSHA has been asked this question before.

There are some standard interpretations published by OSHA which lay out additional requirements that are similar to the General Industry Requirements.  One letter states an effective hearing conservation program consists of the following elements:

  1. Monitoring of employee noise exposures.
  2. The institution of engineering, work practice, and administrative controls for excessive noise.
  3. The provision of each overexposed employee with an individually fitted hearing protector with an adequate noise reduction rating.
  4. Employee training and education regarding noise hazard and protection measures.
  5. Baseline and annual audiometry.
  6. Procedures for preventing further occupational hearing loss by an employee whenever such and event has been identified.
  7. Record keeping.

If you would like assistance or guidance on the implementation of an effective hearing conservation program feel free to contact Advanced Safety & Health at (502) 240-6910.




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