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OSHA Recordkeeping Handbook - Msabc.net

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§1904.1088<strong>OSHA</strong> RECORDKEEPINGcorrection values to actual employee audiometricdata. However, since the Occupational Noise standarditself permits employers to adjust the interpretationof audiograms for the effects of aging, it wouldbe inconsistent and administratively complex to prohibitthis practice in the recordkeeping rule. Accordingly,Section 1904.10(b)(3) allows the employer toadjust for aging when determining the recordabilityof hearing loss. The adjustment is made using TablesF-1 or F-2, as appropriate (table F-1 applies to menand F-2 applies to women), in Appendix F of 29 CFR1910.95. However, use of the correction for aging isnot mandatory, just as it is not mandatory in theNoise standard itself…....[I]n the final rule, at paragraph 1904.10(b)(4),employers are permitted, if they choose, to retest theemployee to confirm or disprove that an STS reflectedon the first audiogram was attributable to a coldor some other extraneous factor and was not persistent.If the employer elects to retest, the employerneed not record the case until the retest is completed.If the retest confirms the hearing loss results, thecase must be recorded within 7 calendar days. If theretest refutes the original test, the case is not recordable,and the employer does not have to take furtheraction for <strong>OSHA</strong> recordkeeping purposes. The 30 daylimit in the final recordkeeping rule is consistent withthe 30 day retest provision of Section 1910.95(g)(5)(ii),which allows the employer to obtain a retest within30 days and consider the results of the retest as theannual audiogram if the STS recorded on the firsttest is determined not to persist.<strong>OSHA</strong> believes that the 30 day retest optionallows the employer to exclude false positive resultsand temporary threshold shifts from the data whileensuring the timely and appropriate recording of truepositive results. Adding language to the final recordkeepingrule to specify different procedures, dependingon whether the employer chooses to conduct are-test within 30 days, adds some complexity to thefinal rule, but <strong>OSHA</strong> finds that this added complexityis appropriate because it will reduce burden for someemployers and improve the accuracy of the hearingloss data…....For workers who are exposed to the noise levelsthat require medical surveillance under Section1910.95 (an 8-hour time-weighted average of 85dB(A) or greater, or a total noise dose of 50 percent),it is highly likely that workplace noise is the cause ofor, at a minimum, has contributed to the observedSTS. It is not necessary for the workplace to be thesole cause, or even the predominant cause, of thehearing loss in order for it to be work-related. Becausethe final recordkeeping rule relies upon thecoverage of the Occupational Noise standard, it isalso not necessary for <strong>OSHA</strong> to include a minimumtime of exposure provision. The Occupational Noisestandard does not require a baseline audiogram tobe taken for up to six months after the employee isfirst exposed to noise in the workplace, and the nextannual audiogram would not be taken until a yearafter that.For any worker to have an applicable change inaudiogram results under the Occupational Noisestandard, the worker would have been exposed tolevels of noise exceeding 85 dB(A) for at least a year,and possibly even for 18 months.In addition, the provisions allowing for review by aphysician or other licensed health care professionalallow for the exclusion of hearing loss cases that arenot caused by noise exposure, such as off the job traumaticinjury to the ear, infections, and the like. <strong>OSHA</strong>notes that this presumption is consistent with a similarpresumption in <strong>OSHA</strong>’s Occupational Noise standard(in both cases, an employer is permitted to rebut thispresumption if he or she suspects that the hearingloss shown on an employer’s audiogram in fact has amedical etiology and this is confirmed by a physicianor other licensed health care professional)….Shifts in hearing must be calculated separately foreach ear, in accordance with the requirements ofSection 1910.95. However, if a single audiogramreflects a loss of hearing in both ears, only one hearingloss case must be entered into the records. Theissue of revising baseline audiograms to evaluate theextent of future hearing loss pertains to a hearingloss case that has been entered on the Log. If a single-earSTS loss has been recorded on the Log, thenthe baseline audiogram should be adjusted for thatear, and that ear only. If an STS affecting both earshas been recorded on the Log, then the baselineaudiogram may be revised and applied to both ears.This means that there should be no cases where thebaseline audiogram has been adjusted and the casehas not been recorded on the Log.[67 FR 44038, July 1, 2002]II. Recording Occupational Hearing Loss CasesSection 1904.10 of the January 19, 2001 final recordkeepingrule required employers to record, by checkingthe “hearing loss” column on the <strong>OSHA</strong> 300 Log,all cases in which an employee’s hearing test (audiogram)revealed that a Standard Threshold Shift (STS)in hearing acuity had occurred. An STS was definedas “a change in hearing threshold, relative to themost recent audiogram for that employee, of anHANDBOOK

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