Pamela Gordon duPont and Carol Snyderwine
As a clinical audiologist, you may be asked to provide services to local industries that must comply with the Occupational Safety and Health Administration (OSHA) noise exposure standard 1910.95, which was enacted in 1983. These industries may ask you to determine whether an employee's hearing loss is work related. The OSHA recordkeeping rule (Recording Criteria for Cases Involving Occupational Hearing Loss, 2001) states that physicians or other licensed health care professionals may determine if a hearing loss is related to workplace exposure (see §1904.10(b)(6), sentence 2). Employers may wish to consult you as one of the licensed health care professionals who determine whether a hearing loss needs to be recorded on OSHA Form 300 (OSHA, n.d.-b), a form that employers use to record occupational illness and injuries throughout the year. In this article, we attempt to help audiologists determine how they may assist employers who need to ascertain whether their employees' hearing losses are work related per the OSHA noise exposure standard. Although physicians can determine whether the loss is work related, audiologists may determine whether the hearing loss is work related for OSHA recordability purposes.
Exposure to high sound levels can cause hearing loss. An individual's noise exposure encompasses myriad sounds at varying intensity levels. Besides the work environment, this may include noisy hobbies such as woodworking, rock concerts, and target shooting. The individual may listen to music on or off the job using earbuds or other headphones. Perhaps after working a noisy 7:00 a.m.–3:00 p.m. shift, the individual may proceed to a second job.
All of these activities can possibly cause or add to noise-induced hearing loss. In most cases, the hearing loss is the result of a compilation of many different kinds of occupational and nonoccupational sounds over a number of years. It can become a difficult task for anyone to discern how much of a hearing loss was caused by the employee's exposure to noise in the work environment. However, your job is to determine whether it is "more probable than not" that the hearing loss is related to workplace noise exposure.
The audiologist needs to request various documents from the employer. These include all of the employee's past hearing tests, daily and annual calibration records of the audiometer, and the octave band sound levels of the background noise where the hearing tests were conducted. The audiologist needs a detailed history on the employee. The history should include the person's medical history related to hearing loss, any nonoccupational noise exposures, military history, and former employment history. Data related to the noise and potential ototoxic exposures in the work environment are needed. This includes the dates worked in various departments, the employee's time-weighted average (TWA) exposure level in those departments, and documentation of any hearing protection type and attenuation used. In addition to the Noise Reduction Rating, it is helpful to have hearing protection fit-test results such as Personal Attenuation Ratings (PARs).
The worker may report, "I got the hearing loss in the Gulf War." The worker may have arrived at the industry with a pre-existing hearing loss, in which case this would be evident on the baseline audiogram. Our major concern is to determine whether the noise at the current employer caused or contributed to the hearing loss. In §1904.5(a), the requirement states that "you must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness" (Determination of Work-Relatedness, 2001, sentence 1). The standard goes on to say, "Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in §1904.5(b)(2) specifically applies" (Determination of Work-Relatedness, 2001, sentence 2).
You may have been consulted to determine work-relatedness because the employee's hearing loss has initially been flagged as an OSHA-recordable standard threshold shift (STS). This means that not only has a threshold shift (decrease in hearing threshold, relative to the baseline audiogram, of an average of 10 dB or more at the frequencies 2000, 3000, and 4000 Hz in one or both ears) occurred, but the hearing threshold levels on the annual audiogram in the affected ear show that the person's average hearing levels at frequencies of 2000, 3000, and 4000 Hz are at 25 dB or more. A company may apply significant internal pressure to keep their employees' OSHA-recordable shifts in hearing to a minimum, due to reasons such as management bonuses for achievement of safety goals. The employer may come to you with the hope that the employee's hearing loss will not have to be recorded on the OSHA 300 log so that a certain safety goal can be achieved. The audiologist will then need to educate the employer on OSHA recordkeeping, including that the intent of OSHA Form 300 is to gather data for statistical purposes and to glean opportunities for improvement in health and safety (see, e.g., OSHA, n.d.-a).
Although it is not a regulatory requirement, it is best practice to recommend that a comprehensive audiology evaluation be conducted to properly diagnose the hearing loss. Perhaps after completing the audiometric testing, your results indicate a moderate, flat conductive loss in the ear with the STS. In this case, you can make the appropriate medical referrals, but it is unlikely that this recordable STS would be considered "work related" or consistent with noise-induced hearing loss. If the employer has already recorded (documented) the STS on the OSHA 300 log, the recording can be removed by placing a line through the original documentation.
Unfortunately, reviewing hearing loss cases is seldom straightforward. Upon review of the OSHA recordkeeping regulation (Recording Criteria for Cases Involving Occupational Hearing Loss, 2001), which outlines OSHA recordability, we see that "If an event or exposure in the workplace either caused or contributed to the hearing loss, or significantly aggravated a pre-existing hearing loss, you must consider the case to be work related" (29 C.F.R. § 1904.10(b)5, sentence 2). In other words, even if there is a mixed loss from a number of different causes, if any part of the hearing loss could have been caused by exposure to noise at the workplace, then the hearing loss must be recorded on the OSHA 300 log.
Audiologists can learn more about determining work-related hearing loss by attending the Professional Supervisor of the Audiometric Monitoring Program Workshop offered by the Council for Accreditation in Occupational Hearing Conservation.
Pamela Gordon duPont, MS, CCC-A, is an audiologist as well as president and founder of Gordon Hearing Conservation, Inc. She has worked in occupational hearing conservation since 1979. Pamela represents ASHA on the Council for Accreditation in Occupational Hearing Conservation (CAOHC). She has been a CAOHC course director since 1977. She is a Certified Professional Supervisor of the Audiometric Monitoring Program (CPS/A).
Carol Snyderwine, MHA, MA, CCC-A, is an audiologist who has provided mobile hearing conservation services in the greater Cleveland area since 1986. She works for the Cleveland Clinic Health System. Carol also represents ASHA on the Council for Accreditation in Occupational Hearing Conservation (CAOHC). She is an active CAOHC course director and Certified Professional Supervisor of the Audiometric Monitoring Program (CPS/A).
Determination of Work-Relatedness. (2001). 29 C.F.R. § 1904.5 (2001). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9636.
Occupational Safety and Health Administration. (n.d.-a). OSHA injury and illness recordkeeping and reporting requirements: How does OSHA define a recordable injury or illness? Retrieved from https://www.osha.gov/recordkeeping/.
Occupational Safety and Health Administration. (n.d.-b). Injury & illness recordkeeping forms—300, 300A, 301. Retrieved from https://www.osha.gov/recordkeeping/RKforms.html.
Occupational Safety and Health Administration. (2001a, January 19). Occupational Injury and Illness Recording and Reporting Requirements [Final Rules]. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=16312&p_table=FEDERAL_REGISTER.
Occupational Noise Exposure, 29 C.F.R. § 1910.95 1983. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9735.
Recording Criteria for Cases Involving Occupational Hearing Loss, 29 C.F.R. § 1904.10 (2001). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9641.
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