The following is a sample hearing conservation program that you may use as a guide in developing your program.  (A Microsoft Word version of this program is included at the end of this section).  Your written program should convey what you are doing to prevent noise-induced hearing loss, and comply with the OSHA Noise Standard.

Our Hearing Conservation Policy

General Company Policy
The purpose of this notice is to inform you that our company is complying with the OSHA Noise Standard, Title 29 Code of Federal Regulations 1910.95, by including all employees exposed to noise above 85 dBA (50% noise dose) for 8-hour average exposures in this program.  The program will include engineering and administrative controls to reduce noise exposures, noise monitoring to determine how much noise our employees are exposed to, an audiometric testing program to check on hearing ability, providing hearing protection devices, and employee training.  The purpose of the program is to prevent noise-induced hearing loss from noise generated in the workplace.

The program applies to the employees in the following departments in our company:

• Maintenance
• Fabrication
• Department 356

The safety and health manager, Joan Johnson, is the program coordinator, acting as the representative of the plant manager, who has overall responsibility for the program.  Ms. Johnson will review and update the program, as necessary.  Copies of the written program may be obtained from Ms. Johnson in Room 555.

Under this program, you will be informed of the contents of the OSHA Noise Standard, the effects of noise on hearing, the purpose of hearing protectors and the advantages, disadvantages and attenuation of various types, instructions on the selection, fitting, use and care of hearing protectors, and the purpose of audiometric testing and an explanation of test procedures.

Compliance with our company's safety and health requirements, including the hearing conservation program, is a condition of employment.  Failure to comply with the requirements of this program will result in disciplinary action outlined in the company's safety and health program.

Noise Monitoring
Noise surveys are conducted using a combination of personal monitoring with audio dosimeters and sound pressure level measurements using sound level meters.  Representative employees in each department are sampled using audio dosimeters to evaluate 8-hour average exposures to noise in those departments.  Sound pressure level measurements provide information about the noise levels generated by the equipment and machines in operation.  The monitoring results are used to:

1. Determine which employees should be included in the Hearing Conservation Program;
2. Prioritize machines/employee locations/areas for engineering control work; and,
3. Select hearing protection devices based on employee exposures.

All noise survey equipment must meet ANSI Type 2 requirements, and are calibrated before and after the survey to ensure validity of the measurements.

Our insurance company's Risk Engineering department performs the noise surveys at this location.  A complete report is provided and available to employees.  Any employee wishing to obtain further information of the monitoring results should contact Joan Johnson.

An initial survey was conducted at the startup of operations at this facility.  Additional surveys are conducted if changes in production, equipment, or controls are implemented to determine the effects of those changes on employee noise exposures.

Engineering and Administrative Controls
If noise exposures exceed 85 dBA, feasible engineering and/or administrative controls are implemented to reduce employee noise exposures to nonhazardous levels.  The ultimate goal is to eliminate employee exposures to hazardous noise.  However, where this is not feasible, measures to reduce employee exposures to noise are implemented.  For example, the following controls have been implemented to date:

1. In the Packing Department, air exhaust nozzles on the packaging machines were fitted with mufflers to reduce noise levels generated by escaping air.  This reduces employee exposures below 85 dBA, so employees in this area did not need to be included in the HCP.
   
   
2. In the Fabrication Department, sound absorbent enclosures were installed around the cutters to reduce the noise levels in the fabrication area.  This significantly reduced the operator's exposures to noise.
   
   
3. In the Assembly Department, a job rotation schedule was implemented to reduce the amount of time employees spent at the Enielk machine.  Final assembly operators spend only 30 minutes per person per day at this machine.  The lower average exposure meant that none of the final assembly operators needed to be included in the Hearing Conservation Program.
   
   
4. An equipment maintenance program was established to reduce noise levels generated by poorly maintained equipment.  Periodic inspections are conducted to ensure equipment is operating properly with all sound reduction controls in place.

An outside acoustical engineering firm and contractor will continue to work with us on designing and installing engineering controls.  As equipment wears out or becomes obsolete, quieter models will be obtained where available.

Employee Training
Employees working in areas where exposures to noise exceed 85 dBA will receive initial training on the hearing conservation program elements by the safety and health manager during employee indoctrination.  A program that uses both audiovisual materials and classroom type training has been prepared for this purpose.

Regular safety meetings will also be used to review the information presented in the initial training, at least annually.  Foremen and other supervisors will be extensively trained regarding hazards and appropriate protective measures so they will be available to answer questions from employees and provide daily monitoring of safe work practices.  Employee participation in training sessions will be documented.

The training program will emphasize these items:

• The effects of noise on hearing;
• The purpose of hearing protectors;
• The advantages, disadvantages and attenuation of various types of hearing protectors;
• Selection, fitting, use, and care of hearing protectors;
• The purpose of audiometric testing; and,
• Contents of the OSHA noise standard and this written program.

The safety and health manager will review our employee training program and advise the plant manager on training or retraining needs.  As part of the assessment of the training program, the safety and health manager will obtain input from employees regarding the training they have received, and their suggestions for improving it.

Audiometric Testing Program
All employees exposed to noise at or above 85 dBA as an 8-hour Time-Weighted Average will be included in the audiometric testing program.  Employees assigned to the following departments or areas are included in the program:

• Maintenance
• Fabrication
• Department 356

Our company has contracted with Audiometrics, Inc. to perform audiometric testing, evaluate the audiograms, and advise of any action needed as a result of the evaluation.  The audiometric testing is performed by a licensed or certified audiologist, otolaryngologist, physician, or by a technician certified by the Council of Accreditation in Occupational Hearing Conservation (CAOHC).  All audiometric tests are air conduction pure-tone threshold tests which include the frequencies 500 Hz, 1000 Hz, 2000 Hz, 3000 Hz, 4000 Hz, and 6000 Hz.

Baseline and annual audiograms are performed by our mobile testing service, XYZ Occupational Health, Inc.  XYZ comes to the plant to perform audiometric evaluations in April and October of each year.  If new employees are hired more than 60 days prior to the testing van visit, the employee is referred to the E.A.R. Clinic for their baseline audiogram.  Baseline audiograms are preceded by at least 14 hours without exposure to workplace noise, and all employees are informed of the need to avoid high levels of nonoccupational noise during this 14 hour quiet period.

An audiologist, otologist, or qualified physician employed by XYZ evaluates the annual audiograms (compares annual to baseline audiograms) to determine if the audiogram is valid and if a Standard Threshold Shift has occurred.  Problem audiograms are reviewed to determine if further evaluation is needed.  If an STS occurs, the following steps are taken:

• Employees are referred for an audiological evaluation or otological examination;
• Employees shall be refitted and retrained in the use of HPDs and provided with HPDs offering greater attenuation if needed; and,
• Employees are informed of the existence of an STS, in writing, within 21 days of the determination.

The company's policy is to inform employees of the results of their audiometric evaluations, in writing, whether an STS has occurred or not.  We want to secure day-to-day cooperation from our employees to ensure the success of the program.  All audiometric records are retained for the duration of employment.

All equipment used for audiometric tests meets ANSI standard S3.6-1969.  Tests are conducted in a room meeting OSHA requirements, and ambient noise levels are recorded.  Biological audiometer calibrations, including listening checks are performed each day prior to testing, and all audiometers are calibrated electroacoustically at least once a year.  These records are provided to us after each visit by the testing company and are kept on file by the Safety and Health Manager.

Hearing Protection Devices
All employees exposed to noise above 85 dBA for 8-hour average exposures are required to wear hearing protectors when working in posted areas.  Although the OSHA Noise Standard only requires HPDs when employees are exposed to noise above the 90 dBA 8-hour average, our company has opted to enforce the use of HPDs for all employees included in the Hearing Conservation program.

Employees are involved in the selection of appropriate hearing protectors.  Two types of HPDs, disposable insert-type and ear muffs, are made available in a variety of sizes.  XYZ Occupational Health Inc., assists in the selection of appropriate hearing protectors during baseline audiograms.  Employees are then trained in the use and care of hearing protectors as part of the training program.

Noise monitoring results are used to determine the amount of noise reduction needed to reduce exposures below 85 dBA-TWA.  The hearing protectors provided are selected for their ability to attenuate noise below this level.

Additional Information
All employees or their designated representatives can obtain further information on the written program, the OSHA Noise Standard, or records of noise monitoring results or audiometric tests at the Safety and Health Office, Room 555.

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