OSHA Recordkeeping Handbook - Msabc.net

average of 10 decibels or more at 2000, 3000 and4000 Hertz (Hz) in one or both ears.” The recordkeepingrule itself does not require the employer to testemployee’s hearing. However, OSHA’s occupationalnoise standard (29 CFR 1910.95) requires employersin general industry to conduct periodic audiometrictesting of employees when employees’ noise exposuresare equal to, or exceed, an 8-hour time-weightedaverage of 85dBA. Under the provisions ofSection 1910.95, if such testing reveals that anemployee has sustained a hearing loss equal to anSTS, the employer must take protective measures,including requiring the use of hearing protectors, toprevent further hearing loss. Employers in the construction,agriculture, oil and gas drilling and servicing,and shipbuilding industries are not covered bySection 1910.95, and therefore are not required byOSHA to provide hearing tests. If employers in theseindustries voluntarily conduct hearing tests they arerequired to record hearing loss cases meeting therecording criteria set forth in the final Section 1904.10rule.[67 FR 77169, Dec.17, 2002]D. Other Hearing Loss IssuesOSHA would like to clarify three matters in relation torecording occupational hearing loss in conjunctionwith the Section 1904.10 final rule issued July 1,2002. First, the preamble to the final rule stated thatemployers in the shipbuilding industries are not coveredby OSHA’s noise standard Section 1910.95 andare therefore not required to perform audiometrictests. (67 FR 44038, 44040). This statement was anerror. OSHA Directive STD 0.2 Identification ofGeneral Industry Safety and Health Standards (29CFR 1910) Applicable to Shipyard Work specificallystates that employers in the shipbuilding industrythat are covered by the 29 CFR part 1915 Standardsare required to comply with a number of 29 CFR Part1910 standards, including the Section 1910.95 requirementsfor occupational noise.[67 FR 44038-44044, July 1, 2002]II. Recording Occupational Hearing Loss Cases(continued)One of the major issues in the recordkeeping rulemakingwas to determine the level of occupationalhearing loss that constitutes a health condition seri -ous enough to warrant recording. This was necessarybecause the final rule no longer requires recording ofminor or insignificant health conditions that do notresult in one or more of the general recording criteriasuch as medical treatment, restricted work, or daysOSHA RECORDKEEPINGaway from work (See, e.g., 66 FR 5931). In its 1996Federal Register notice OSHA proposed a requirementto record hearing loss averaging 15 dB at 2000,3000 and 4000 Hz in one or both ears (61 FR 4040).OSHA adopted the lower 10-dB threshold in the finalrule based in part upon comments that “(a)n age-correctedSTS is a large hearing change that can affectcommunicative competence” (66 FR 6008).OSHA’s DecisionFollowing consideration of the comments received inresponse to the July 3, 2001 proposal to modify thehearing loss recording criteria, OSHA has decided torequire employers to record audiometric results indicatinga Standard Threshold Shift (STS) only whensuch STS cases also reflect a total hearing level of atleast 25 dB from audiometric zero. The STS calculationuses audiometric results averaged over the frequencies2000, 3000 and 4000 Hz, using the originalbaseline and annual audiograms required by theOSHA noise standard Section 1910.95. The rule alsoallows the employer to adjust the employee’s audiogramresults used to determine an STS to subtracthearing loss caused by aging, allows the employer toretest the workers’ hearing to make sure the hearingloss is persistent, and allows the employer to seekand follow the advice of a physician or licensedhealth care professional in determining whether ornot the hearing loss was work-related.The approach adopted in the final rule has severaladvantages. By using the STS definition from theOSHA noise standard Section 1910.95, the Section1904.10 regulation uses a sensitive measure of hearingloss that has occurred while the employee isemployed by his or her current employer. By requiringall STSs to exceed 25 dB from audiometric zero,the regulation assures that all recorded hearing lossesare significant illnesses. OSHA received no commentssuggesting that a shift of 25 dB from audiometriczero was anything less than a serious hearingloss case. While there is little consensus among thecommenters concerning the appropriate level thatshould be used to record hearing loss cases, there iswidespread agreement that a 25-dB shift from audiometriczero is a serious hearing loss.The hearing loss recording level is also compatiblewith the final rule’s definition of injury or illness,“an abnormal condition or disorder” (Section1904.46). Various scales used to rate hearing lossconsider hearing levels less than 25 dB to be withinthe “normal range” (American Medical AssociationGuidelines to the evaluation of Material Impairment,American Academy of Family Physicians, AudiologyHANDBOOK89§1904.10