|
The Federal Railroad Administration (FRA) has proposed a rule regarding occupational noise exposure for railroad operating employees that ASHA believes falls short of an effective hearing conservation program. In comments provided in September, ASHA recommended measures that would significantly strengthen the rule.
The agency has noted the many factors that contribute to noise levels over 85dB(A) for railroad workers-including the sounding of the horn, engine noise, and radio volume-and has stated the negative effects on workers' mental processes, fatigue, and an increase in on-the-job errors.
In its comments ASHA recommended revisions in the proposed rule in the following critical areas, among others:
- Revision of the exchange rate to 3dB as supported by the National Institute for Occupational Safety and Health (NIOSH). Every 3dB increase in level would require that the exposure duration be decreased by half to maintain the same noise dose.
- Annual audiometric testing. The proposed rule requires audiometric testing only every three years, during which time irreversible hearing loss can occur. Tracking compliance would be an administrative challenge with a three-year period between audiograms.
- An immediate retest if a standard threshold shift (STS) has occurred, as supported by NIOSH. The FRA proposed a retest within 90 days if an STS has occurred. ASHA also states that confirmation audiograms should be conducted again within 30 days of any monitoring or retest audiogram that continues to show an STS as the 90-day window in the proposed rule permits too much time to lapse to permit effective test comparisons.
- ANSI S12.6-1997 (R2002) (Method B) should replace the Noise Reduction Rating (NRR) as the method used to determine hearing protector effectiveness. The hearing protector ratings included in the NRR are based on data obtained under optimal laboratory conditions in which the experimenters are fitting trained listeners and differ markedly from the noise reduction that workers actually experience on the job.
- Revise the definition of "audiologist" to be consistent with that contained in ASHA's Scope of Practice in Audiology, namely a professional who provides comprehensive diagnostic and treatment/rehabilitative services for auditory, vestibular, and related impairments and who is certified by ASHA and, where applicable, licensed by the state.
- Phase-in period of no more than one year from the date of promulgation for all aspects of the proposed rule.
To view ASHA's comments in their entirety, visit the Legislation Advocacy page and select "ASHA Railroad Noise Exposure Comments."
|