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Hearing Conservation Program - Guideline

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Risk Management, Portland, OR


 City of Portland

Hearing Conservation Program (HCP)  Guidelines

 

Introduction:

The City of Portland values the health, safety and the well being of its workforce. Exposure to excessive levels of noise may put Affected Employees’ hearing at risk for damage and loss. The purpose of this document is to provide city bureaus with guidelines for establishing and maintaining a city-wide Hearing Conservation Program (HCP). 

The main objectives of the City’s HCP are to:

  1. Protect employees from noise hazards;
  2. Comply with OSHA regulations around workplace noise;
  3. Protect the City from workers' compensation claims due to noise-induced hearing loss brought about by occupational noise exposure;
  4. Minimize disruption and distress in the workplace caused by high noise levels.

For HCP Definitions See:  Appendix 1 - HCP Definitions in the Hearing Conservation Policy

 

HCP Elements Responsibility Procedure of Reference

HCP Administration:

City-wide HCP

 

City Risk

Develop, implement, administer, and maintain the City-wide HCP in compliance with:

  • Oregon OSHA’s Occupational Noise Exposure and Audiometric Testing rules:  http://www.orosha.org/pdf/rules/division_2/div2_g.pdf#page=33
  • 29 CFR 1910.95, OAR 437-002-0095, Division 2, Subpart G: Occupational Noise Exposure as adopted in Oregon;
  • OAR 437-002-0095 Audiometric Testing in Oregon, and
  • 29 CFR 1910.1020 Access to Employee Exposure and Medical Records.
  • City of Portland Charter (Section 2-504) Office of the City Auditor's Archives and Records Management Program in compliance with state law and administrative rules (ORS 192 and OAR 166).
Bureau specific HCP City Bureaus with
Affected Employees

Develop, implement, administer, and maintain the bureau specific HCP in compliance with:

  • Oregon OSHA’s Occupational Noise Exposure and Audiometric Testing rules:  http://www.orosha.org/pdf/rules/division_2/div2_g.pdf#page=33;
  • 29 CFR 1910.95, OAR 437-002-0095, Division 2, Subpart G: Occupational Noise Exposure as adopted in Oregon;
  • OAR 437-002-0095 Audiometric Testing in Oregon, and
  • 29 CFR 1910.1020 Access to Employee Exposure and Medical Records
  • City of Portland Charter (Section 2-504) Office of the City Auditor's Archives and Records Management Program in compliance with state law and administrative rules (ORS 192 and OAR 166).

HCP Services Contract Administration

Bureau of Internal
Business Services (BIBS) and City Risk
  • Main contact with OMF Procurement Services for Hearing Conservation Services Contract renewals, maintenance, amendments or changes, utilization, and clarifications. 
  • Develop solicitation documents and subsequent contract documents.
    • Six months prior to current contract expiration, organize a stakeholder task team to assist in the development of solicitation documents and subsequent contract.
    • Facilitate the selection vendors who are appropriately licensed or certified by the Council of Accreditation in Occupational Hearing Conservation. 
    • Ensure any of the vendor’s technicians performing hearing tests are responsible to an audiologist, otolaryngologist or physician.
    • Develop and utilize a schedule for monitoring the contract balance to ensure the contract budget amount is not exceeded.
  • Consult with city bureaus to ensure effective use of resources in using the HCP Services Contract.  
  • When necessary, convene a stakeholder task team to update this Policy to make appropriate adjustments based on changes to the HCP Services Contract.
Leadership and consultation to City Bureaus
related to HCP management.
City Risk
  • City Risk provides HCP policy, administration and overall framework to ensure city-wide OSHA Compliance related to Hearing Conservation. 
  • Hearing Conservation Loss Prevention services include:
  • Establishment and delivery of a city-wide HCP Implementation Plan Appendix 2 – Action Plan for Hearing Conservation Program.
  • Technical advice,  consultation, website, tools, and resources related to all areas of HCP;
  • Assistance with identification and coordination of technical expertise or contracted  services; and,
  • Ongoing Loss Prevention  consultation to ensure ongoing maintenance, updates, changes, and issues are  addressed. 
HCP services to smaller city bureaus. City Risk
  • In addition to routine City Risk HCP related Loss Prevention Services, ensure that adequate resources and technical expertise are available for OSHA compliance, consultation, leadership, facilitation, and a detailed level of service.
Monitor changes to the regulations, statutes, rules,
and requirements.
City Risk
  • Maintain knowledge of all applicable HCP regulations, statutes, rules, policies, procedures, and any other requirements.
    • Establish and maintain a check for upcoming changes to all areas.
    • Participate in professional organizations, e-mail groups, networking, etc. to find out about potential changes.
  • Establish and maintain an adequate communication method with bureaus for notification of changes.
  • Maintain training and education of Loss Prevention staff to ensure they maintain up-to-date knowledge and skills.
As needed, update the City-Wide HCP to reflect
changes e.g. contract, program, procedures, and regulations.
City Risk
  • Conduct annual program review in July; verify records have been received from the vendor, invoices have been processed correctly, the contract is being used efficiently, and bureaus are able to access services.
  • Update documents based on requirement or need. 
  • Communicate with bureaus, OSHA and professional organizations to ensure timely updates.
  • Timely notification to stakeholder bureaus on proposed changes

Noise Monitoring

Perform noise level surveys for job classifications,
individuals, work areas, equipment, mobile operations, or field-work with
suspected high noise levels having a time weighted average (TWA) noise exposure
of 85 dBA or higher for an 8-hour shift.

Bureaus & City
Risk. City Risk through the administration of the contractor/ vendors. Bureaus
work with City Risk to schedule resources & provide direction and guidance
to resources.
  • A rule of thumb: Suspected high noise levels may be present if the environment requires you to raise your voice in order to be heard.
  • Identify and document potential areas of noise using the Noise Level SOP and Survey Form, Appendix 3.
  • Arrange for noise level surveys to be performed in compliance with all applicable regulations, statute and rules pertaining to calibration and maintenance of equipment.
    • Use of the city-wide Hearing Conservation Services Contract unless your bureau has appropriate technical expertise and equipment to perform noise level surveys.
    • If bureau equipment is used to perform noise level surveys, it is the bureau’s responsibility to comply with applicable regulation, statute and rule pertaining to calibration and maintenance of equipment. 
  • For employees having fixed working locations near steady and continuously operating noise sources, a sound level measurement will be conducted for a representative period at the employee’s position to indicate the exposure level.
    • The measurement interval should be of sufficient duration to encompass a reasonable number of operating cycles for the task or machinery being considered.
  • Where work activities and resulting noise levels are variable, and particularly where individuals do not have fixed working locations, employee exposure levels noise levels will be determined by means of a personal noise dosimeter.
  • Gather and compile results of noise level surveys, retain a bureau file.

 

Additional noise monitoring will be conducted whenever employee exposures are expected to change (equipment changes, plant modifications, engineering control installations, etc.).

 Bureaus
  •  Develop, implement and maintain a process to:
    • Capture changes in employee exposures e.g. equipment changes, plant modification, and engineering or administrative control installations.
    • Ensure additional noise monitoring is completed and documented.
    • Ensure Affected Employee is appropriate notified of monitoring.

 Provide technical assistance to bureaus, vendor
communication, consultation, leadership, and facilitation services.

City Risk
  • Loss Prevention Specialists from City Risk will work with bureaus and the Hearing Conservation Services Contractor to ensure bureau HCP implementation and monitoring, including:
    • Workplace noise level testing, ongoing monitoring, hearing testing, and recordkeeping to ensure they are performed efficiently and in compliance with regulation, statute, rules, policies, and procedures.

 Mapping of work areas, equipment, mobile
operations, or field work with noise levels exceeding 85 dBA

Bureau
  • Bureaus will be organized and maintained in a manner that will allow:
    • Analysis of the results with the goal of achieving consistency in the application of HCP.
    • Sharing of information city-wide e.g. same or similar equipment or job classifications with nose level exposure.

 Affected Employees with a TWA noise exposure of
85 dB or higher for an 8-hour shift will be included in the HCP.

Bureau
  • Follow the notification, monitoring and observation process below.
  • Ensure HCP Hearing Testing, Hearing Protection, Employee Training, and Recordkeeping are in compliance and follow the guidelines below. 

 

Each Affected Employee exposed at or above an 8 hour time-weighted average of 85 dBA must receive the results of the noise monitoring.

 Bureaus
  •  Develop, implement and maintain an effective process to notify each Affected Employee exposed at or above an 8 hour time-weighted average of 85 dBA of the results of the noise monitoring.

Affected Employees or employee representatives will be notified of planned monitoring
and be permitted to observe

Bureaus
  • Develop, implement and maintain a process for notifying Affected Employees or employee representatives of any noise monitoring.  This process needs to include the:
    • The method of notifying the Affected Employee and/or representative;
    • Type of monitoring that will be performed;
    • Date, time and duration of the monitoring; and
    • Process for employee and/or representative to observe.
  • Documentation of the above

 Hearing Testing

For all Affected Employees working in areas with sound levels in excess of 85 dBA,
a baseline hearing test will be performed.

Bureau
  • The baseline test is used for comparison to all subsequent hearing tests.
  • All testing will allow for at least a 14-hour recovery period with no work place noise
  • Coordinate with HCP contractor or subcontractor to ensure testing is completed as required.

 

Subsequent annual hearing testing will be performed for Affected Employees with Time Weighted Average exposures which exceed 85 dBA.

  • Annual tests may be done at any time during the work shift.

Annual hearing exams must be done within 30-days of return to work when it comes due during a temporary layoff or termination.

 Bureau  
  • Review and implement the Affected Employees’ recommendations of the audiologist or physician.
  • Enroll Affected Employees in the HCP.
  • Ensure Affected Employees receive initial employment hearing tests and annual tests thereafter. 
  • Bureau will coordinate with current vendor to perform hearing evaluations unless previous arrangements have been made for equivalent testing, especially in remote field sites.
  • Hearing testing results provided by the current HCP vendor will be reviewed to ensure the appropriate follow-up actions are taken.

 Appropriate utilization of contractor

 Bureau  
  • Schedule HCP Contract services for their bureau employees.  In general, the bureau should not utilize the HCP Contractor to test employees as a wellness promotion.  Every effort should be made to schedule enough Affected Employees who are required to have hearing testing in a way that ensures all openings are filled.
    • They are not an Affected Employee under this policy;
    • They have requested testing as a voluntary action for health and wellness; and,
  • Other Employees tested as part of a wellness promotion do not qualify for the vendor-provided training, since there is an extra fee for that service.
  • Other Employees who have their hearing tested when  there are openings or cancellations will be given the handout Hearing Conservation Health Promotion Advisory and be required to sign a statement  recognizing and acknowledging that:
  • The employee is not exposed to hazardous noise in the workplace and holds the City harmless for any claims, actions or suits arising out of the testing.  See Appendix 4.

 

If a STS is identified, the Affected Employee will be:

  • Notified of the threshold shift within 21 days of this determination.
  • Informed of the need for further evaluation or retesting if a medical problem is suspected.
  • Re-tested within 30 days and the results of the re-test will be used as the annual hearing test.
  • Refitted or retrained in the use of hearing protection.
  • Required to wear hearing protection if exposures equal or exceed 85 dBA.

Referred for additional audiology or medical testing, if appropriate.

 Contractor and Bureau  
  • Notify and follow up with Affected Employees for whom a STS, invalid baseline and or/a Recordable Significant STS has been identified.   See Appendix 5 for the STS and/or Recordable STS Hearing Loss Retest Notification Procedure.
  • Schedule retests of Affected Employees with an invalid baseline or a STS.
  • Perform an incident analysis whenever an Affected Employee develops a Significant STS. 
  • Enter Significant STS's on the OSHA Form 300 if re-testing is performed within 30-calendar days and the re-test confirms the original tests findings.
  • Establish new baseline with confirmed STS results.
  • Follow-up is required if re-testing is not performed  within 30-calendar days.
  • Enter Significant STS's on the OSHA Form 300 if  re-testing is not performed within 30-calendar days.

 

 Hearing Protection

Personal hearing protection is required to be used
whenever an Affected Employee is exposed to the Action Level of 85 dBA.

 Bureau and Affected
 Employee
 
  • Research the most appropriate hearing protectors for individual bureau operations.
  • In jobs or areas where exposure may exceed a TWA of 85 dBA, until engineering and/or administrative controls reduce the amount of noise exposure to or below the allowed limits, appropriate personal hearing protective devices will be issued and worn by all Affected Employees.
  • Hearing protection is mandatory for any Affected Employee who has incurred a STS.
  • All visitors, management or employees who may enter or pass through a hearing protection required area will also be required to wear hearing protection. Provide a variety of appropriate hearing protectors at no cost to all employees, visitors and management as needed for high noise exposure.
  • Appropriately fit and train employees on the use of hearing protectors.
  • Require employees, visitors and management to use appropriate hearing protection.  
  • Post a notice of the Noise Hazard. See Section X “Noise Signs”

 All supervisors will properly enforce hearing protection requirements

Bureau
  • Develop, implement and maintain a communication process with supervisors to ensure they are appropriately notified, trained and prepared to enforce hearing protection requirements.
  • Consult with Bureau of Human Resources representatives to ensure there is a  process for addressing continued failure of an Affected Employee to properly wear the protection.

A variety of hearing protective options, including ear plugs and muffs, will be
made available at no cost to all employees.

Bureau
  • Employees can choose the type of hearing protection most comfortable for them.  
  • The procedure in Appendix 6 will be used to ensure that selected hearing protection devices reduce noise exposures to an acceptable level.  Customized protection devices should be made available, but only with a physicians authorization and after all other means of protection have been exhausted.

 Noise Signs

All work areas where noise exposures may exceed 85 dBA will be posted with noise warning signs at entrances with a visible sign that state “Hearing Protection Required.”

 

 Bureau  

Tools, machinery or equipment which generates sound levels in excess 85 dBA will be
labeled or marked.

Bureau
  • Hearing protection must be used by operator when these tools, machinery or equipment is used
  • Identify and require when performing tasks identified as excessive hazardous noise levels, i.e. pipe saws, backhoes, grinders, jack hammers, etc.

All Affected Employees in the HCP will wear ear protection when working in posted
areas or equipment.

Bureau
  • Provides training to employees and supervisors on fitting and use of hearing protection devices.
  • Supervisors enforce employees’ wearing of ear protection when working in posted areas or equipment.

All other employees or visitors passing through posted areas or equipment will also
be required to wear hearing protection.

Bureau
  • Develop and implement procedure to ensure all employees or visitors who will pass through posted noisy areas or equipment wear appropriate hearing protections.
  • Ensure a variety of appropriate hearing protection is available for use.
  • Provide training or self-directed instructions on fitting and wearing hearing protection. 
  • Enforce compliance with procedure and immediately address compliance issues.  

 Noise Control - Engineering & Administrative Controls

 On an on-going basis
reasonable efforts will be made to reduce employee noise exposure by applying Engineering or Administrative Controls to reduce the noise level below Action Level criteria.

 Bureau  

Engineering controls will be used to lower noise levels at the source or at the hearing point of all potentially exposed employees.  Examples of engineering controls are:

  • Redesign of existing equipment.
  • Partial or total enclosure of equipment.
  • Selecting less noisy equipment.
  • Using noise dampening barriers.
  • Increasing the employee’s distance from the source of the noise.

 If Engineering Controls are not feasible or do not fully reduce the exposure to high noise, Administrative Controls will be implemented.

Bureau

Administrative Controls differ from engineering controls in that they limit the time Affected Employees are exposed to high noise work sites. Examples of administrative controls are:

  • Rotating work shifts and scheduling rest periods to ensure employees are not exposed to greater than permissible accumulated noise levels during the work shift.
  • Limiting the amount of time employees’ work in areas above the Action Level criteria.

 Evaluation of noise levels prior to equipment purchases. 

Bureaus and City
Procurement
  • Feasible efforts will be made to purchase equipment with noise levels below the Action
    Level criteria.

 Employee Training 

Participation in an annual training program is required for Affected Employees exposed to noise at or above 85 dBA. The training will include information on:

  • Purpose of hearing testing and an explanation of test procedures;
  • Contents of OR-OSHA’s Occupational Noise Exposure Standard (29cfr 1910.95); and,
  • Purpose and use of hearing protectors, advantages and disadvantages of various types.
  • Instructions in selection, fitting, use and care of hearing protectors
  • Effects of exposure; signs and symptoms

 

 Bureau and contractor vendors  
  • Develop, deliver and maintain an annual training program as required for Affected Employees exposed to noise at or above 85 dBA. The training will include information on:
    • Purpose and use of hearing protectors, advantages and disadvantages of various types.
    • Instructions in selection, fitting, use and care of hearing protectors.
    • Purpose of hearing testing and an explanation of test procedures.
    • OR-OSHA Occupational Noise Exposure Standard (29cfr 1910.95).
A copy of the noise standard and the written training and instructional materials needs to be available to employees upon request.

 Recordkeeping

Hearing program records are to be maintained in the Affected Employee’s personnel file or employee Medical Record File and will be provided to employees upon request. Records applicable to employee monitoring and exposure records will be retained as follows:

  • Employee hearing test records (baseline and annual hearing test, retests, test room background levels, and audiometer calibration records) will be maintained for the duration of Affected Employees employment plus 30 years (29 CFR 1910.1020).  These records will include:
    • Name and job classification of the employee;
    • Date of the hearing test;
    • Examiners name;
    • Date of the last acoustic or exhaustive calibration of the audiometer; and,
    • Employee’s most recent noise exposure assessment.
  • Noise exposure measurement records will be maintained for 30 years.
  • Program audit records will be maintained for 3 years.
Bureau  
  • Retain all hearing test records electronically and/or in hard copy for each Affected Employee. 
  • Maintain current documentation of the City’s HCP information per requirements and be able to produce these documents for compliance inspections or audit purposes.  
  • Develop, implement and maintain a process to ensure all required information is gathered and retained.
    • Ensure vendor records for pre-employment hearing  testing is sent to current HCP vendor and maintained per requirements. 
  • Hearing test results will be stored in a confidential  medical record file located at the Affected Employee’s bureau for the duration of the employment plus 30 years (29 CFR 1910.1020). 
  • Maintain and retain all HCP employee training records for 3 years.
  • Records are also retained by the current vendor with City Risk maintaining periodic back up copies. 

Upon an employee’s first entering into employment, and at least annually thereafter, inform current Affected Employees covered by this section of the following:

  • The existence, location, and availability of any records covered by this section;
  • The person responsible for maintaining and providing access to records; and,
  • Each employee’s rights of access to these records.
 Bureau  
  • Develop, implement and maintain an effective process to inform each new or Affected Employee as required.
  • Include an effective annual audit process to ensure Affected Employees are always informed as required.
  • During audit processes, note any deficiencies and take corrective action to ensure compliance.       

 Provide all required records upon request to
employees, former employees, representatives designated by the employee, and
the Assistant Secretary of Labor.

Bureau
  • Develop, implement and maintain a process to ensure the ability to produce HCP information and documentation for audits and compliance inspections by regulatory authorities.
  • In consultation with bureau BHR Representative, upon request, provide all required records to employees, former employees, and representatives designated by the employee.

Receive periodic electronic back-up of HCP
records from the current contractor vendor

City Risk
  • Develop, implement and maintain a process to ensure hearing testing performed during employment
    pre-placement exams is sent to current HCP vendor for inclusion in required
    recordkeeping and back-up of records.

Transfer HCP records to new vendor when a different contractor vendor is selected. 

City Risk
  • Develop, implement and maintain a process to ensure appropriate contract language is continuously included in contract documents addressing HCP records transfer requirements.
  • This process should also address records transfer to city if HCP vendor goes out of business or contract is otherwise terminated before a new vendor is selected.

 Program Evaluation

The success of the HCP with regard to each Affected Employee is evaluated by comparing annual hearing tests to the baseline hearing test. This procedure, among others, helps to determine the effectiveness of the HCP, and, as a result, ensures the protection of employees' hearing.

 Bureau  
  • Develop, implement and maintain a process where each Affected Employee’s annual hearing tests are compared to their baseline hearing test.
  • Take appropriate action based on any STS or other issues associated with comparisons.
  • During annual comparison process, note any inconsistencies in recordkeeping that cause issues with completing the process. 
  • Implement corrective action to ensure inconsistencies and issues are addressed and appropriately resolved.

 Review, implementation and follow-up on recommendations of the audiologist or physician

 Bureau  
  • Establish, implement and maintain a process to:
    • Bureau to receive all audiologist or physician recommendations.
  • If private audiologist or physician is used by employee, ensure employees know process to forward recommendations to city.

Address employee concerns about hearing protection fit, comfort, or overprotection.
However, it is the responsibility of the employee to bring those concerns to
the attention of supervisors.

 Bureau  
  • Develop, implement and maintain a process to address employee concerns about hearing protection as required.
  • Inform employees of their responsibilities to bring concerns to the attention of supervisors. 

 If an employee experiences a STS, that employees’ workstation or work area will be specifically evaluated to determine if feasible Administrative or Engineering
Controls can decrease the noise levels.

Bureau and Contracted
HCP Vendor
 
  • Develop, implement and maintain a process to evaluate the workstation or work area of any Affected Employees with an STS.
    • Determine if there are any feasible Administrative or Engineering Controls to decrease the noise levels.
    • Test any proposed controls to ensure their effectiveness.
    • Document changes in a manner that ensure future Affected Employees or supervisors are able to determine the reasons, processes and effectiveness of the implemented controls.
  • Follow-up annually to ensure no changes have occurred, controls remain in place and continue to be effective.  

 Fully participate and cooperate with their
bureau’s HCP

 Employee  
  • Comply with the HCP requirements.
  • Take reasonable steps to protect health and safety by using hearing protective devices, attending and applying training, having their hearing tested and following-up as directed.