Hearing Conservation Plan
© 2018 Resource Training & Solutions
The Hearing Conservation Plan is designed to help the St Cloud School District comply with the Occupational Safety and Health Administration's (OSHA) Occupational Noise Exposure Standard (29 CFR 1910.95) . This Plan outlines standard operating procedures to protect the St Cloud School District employees from harmful exposures or overexposures to noise. A reference compliance checklist can be found in Appendix A.
This Plan is intended to be non-site specific and will need to be modified to adapt to specific conditions at each site or school district. In addition, the St Cloud School District is responsible for the implementation, enforcement and updating of their Hearing Conservation Plan. It is recommended that the plan be reviewed and updated annually or as noise conditions and operations change. Actual use of this plan is limited to Resources Training & Solutions and the St Cloud School District which it represents.
Plan Review and Updated Report
Hearing Conservation Management Plan Update Report
Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.
Date Updates/Notes Reviewer 5/27/16 Reviewed plan- no updates or changes Wayne Warzecha 3/8/21 Plan Review and Updated Report: Added - Appendix D: Audiometric Testing Roster and Appendix E: Noise Surveys and Dosimeter Readings. Wayne Warzecha 4/21/21 Updated Appendix D Wayne Warzecha 4/21/21 Updated Appendix E Wayne Warzecha 10/05/22 Reviewed plan and updated Audiometric testing roster in the update report Wayne Warzecha
The St Cloud School District shall reduce the level of noise to its lowest possible level through engineering or administrative measures. Where this is not feasible or during the time when such control measures are in the process of being implemented, the St Cloud School District shall provide an appropriate level of hearing protection at no cost to the employee. In most cases, where employee exposures exceed applicable OSHA noise exposure levels, the hearing protection will be worn to reduce the employee's exposure to noise levels below the limits designated in the OSHA standard.
Whenever employee noise exposures equal or exceed an eight-hour, time-weighted average (TWA) sound level of 85 decibels: A-Scale (dBA) or a percent noise exposure or dosage of 50% as specified by OSHA, the St Cloud School District shall administer a continuing, effective hearing conservation program as outlined in the Standard. For purposes of the hearing conservation program, employee noise exposures shall be computed in accordance with Appendix A and Table G-16a of the Standard, and without regard to any attenuation provided by the use of personnel protective equipment. A copy of the OSHA Occupational Noise Exposure Standard can be found in Appendix C.
The St Cloud School District shall conduct an inventory of their operations to identify noise conditions relative to job classifications/work tasks. Typical operations or work activities where noise exposures exceeding those specified in the Standard may exist include, but are not limited to the following:
- Maintenance Activities
- Power tool operation
- Groundskeeping Activities
- Power lawn maintenance and snowblower equipment operation
- Equipment Maintenance and Repair
- Cafeteria Monitor
- Band Teacher
- Shop Teacher
Noise Exposure Assessment
The St Cloud School District shall determine the noise exposure level for each duty identified in the job/work-task inventory where a high noise level is anticipated.
Where practical, employee exposure to noise should be evaluated to determine the average noise exposure over the entire work day or actual time period for the operation/work-task in question. The actual noise exposure can be evaluated in terms of percent noise exposure or dose by utilizing a noise dosimeter or an integrating sound level meter. In addition, noise exposure levels can be measured in terms of an eight-hour, TWA sound level utilizing a Type II sound level meter. A Type II sound level meter is appropriate for measuring exposure whenever the noise is fairly steady. In fluctuating noise, however, noise dosimeters or integrating sound level meters are preferable.
In situations where the employee exposures exceed the OSHA permissible noise exposure of 90 dBA for an eight-hour, TWA or a corresponding noise exposure for a shorter time duration as indicated in Appendix A : Table G-16a of the Standard, the St Cloud School District shall implement engineering and/or administrative standards to control the noise exposure level. When the employee noise exposure level cannot be reduced below respective permissible noise levels due to engineering and administrative controls not being feasible, or during actual implementation of the engineering or administrative controls, the St Cloud School District shall provide employees with the appropriate hearing protection equipment to reduce noise exposures to below the permissible exposure limit of 90 dBA or a percent noise exposure or dose of 100% as measured by personal noise dosimetry monitoring. The St Cloud School District shall make hearing protection available to all employees exposed to an eight-hour, TWA of 85 dBA or greater to the employees.
The St Cloud School District shall ensure that hearing protectors are worn by the following:
- Employees exposed to noise levels above 90 dBA or a percent noise exposure above 100% as measured by a personal noise dosimettry monitoring.
- Employees who are exposed to an eight-hour, TWA of 85 dBA or greater and who have not yet had a baseline audiogram or has experienced a standard hearing threshold shift.
Hearing Protection Selection Factors
Several factors come into play when selecting appropriate hearing protectors:
- Work or job task requirements and conditions
- Variability in the anatomical characteristics of the human head or ear
- Use with a combination of other safety equipment
In all cases, the St Cloud School District will provide appropriate or accepted hearing protection devices when required to be worn by employees. All hearing protection devices are to be approved by the National Institute for Occupational Safety and Health. Employees shall be given the opportunity to select their hearing protectors from a variety of suitable hearing protectors provided by the St Cloud School District.
Hearing Protection Device Types
Hearing protection devices may broadly be categorized into earmuffs which fit over and around the ears to provide an acoustical seal against the head, earplugs which are placed into the ear canal to form a seal, and semi-aural devices (also called semi-insert, conchaseated and canal caps), which are held against the canal entrance with a headband to provide an acoustical seal at that point. Due to the considerable variety among ear plugs, they can be further differentiated into three types: pre-mold, formable, and custom-mold.
Earmuffs normally consist of rigid molded plastic ear cups that seal around the ear using foam or fluid-filled cushions that are held in place with metal or plastic headbands. The cups are lined with acoustical material to absorb high frequency energy within the cup. Earmuffs are relatively easy to dispense since they are generally one-size devices designed to fit nearly all adult users. Nevertheless, earmuffs should be evaluated for fit when initially issued, since not every user can be fitted by all models. Earmuffs are good for intermittent exposures due to the ease with which they can be donned and removed. However, for long-term wearing it is often reported that earmuffs feel tight, hot, bulky and heavy, although in cold environments, the warming effect is appreciated.
Earplugs tend to be more comfortable than earmuffs for situations in which protection must be used for an extended period, especially in warm and humid environments. They can be worn easily and effectively with other safety equipment and eyeglasses and are convenient to wear when the head must be maneuvered in close quarters. However, they are less visible than muffs, and, therefore, their use can be somewhat more difficult to monitor. Earplugs come in a variety of sizes, shapes, and materials, but regardless of the particular model, care must be taken in inserting and sometimes preparing them for use.
When earplugs are initially dispensed, even when considering formable "One-size-fits all"- devices, the fitter must individually examine each person to insure that a proper seal can be obtained.
Premolded earplug devices are manufactured from flexible materials such as vinyls, cured silicones and other formations. Most models are available with attached cords to help prevent loss and to improve storage and reduce contamination by permitting hanging around the neck when not in use.
Formable earplugs may be manufactured from cotton and wax, spun fiberglass, silicone putty and slow-recovery foams. Life expectancies vary from single-use products such as some of the fiberglass down products to multiple-use products, such as the foam plugs which can be washed and relatively permanent items such as the encased putties. Formable plugs are generally not available with attached cords.
The primary advantage of formable earplugs is comfort, some of the products being among the most comfortable and user-accepted used today. Formable earplugs are generally sold in one-size that usually fits most but not all ear canals. This simplifies dispensing, recordkeeping and inventory problems, but when such products are used, special attention must be given to wearers with extra-small and extra-large ear canals to make sure that the canals are not too tightly or too loosely fitted. Since these plugs usually require manipulation by the user prior to insertion, during which time the hands should be relatively clean, they may not be the best choice for environments in which the devices have to be removed or re-inserted many times during the work shift by employees whose hands are contaminated with caustic or irritating substances. Custom earmolds are most often manufactured from two-part curable silicone putties, although some are available in vinyl. Silicones are cured either by a catalyst at the time of the impression as taken by the fitter or returned to the supplier for manufacturing. Most earmolds fill a portion of the ear canal as well as the concha and pinna. The canal portion of the mold is what makes the acoustical seal to block the noise. Considerable skill and time are required to take individual impressions for each employee. The fact that custom earmolds are user specific and intended to fit only the canal for which they are manufactured, does not assure that they will provide better protection than other well fitting earplugs.
Semi-aural Devices - Semi-aural devices, which consist of pods or flexible tips attached to a lightweight headband, provide a compromise between earmuffs and earplugs. They can be worn in close quarters, easily removed and replaced and conveniently carried when not in use. One size fits the majority of users. Their fit is not compromised by safety glasses or hardhats. These devices are usually available with dual position (under the chin and behind the head), or universal headbands made from either metal or plastic. The tips can be made from vinyl, silicone or composites such as foam encased in a silicone blotter, and may cap, or in some cases enter the ear canal.
Semi-aural devices are principally intended for intermittent use where they must be removed and replaced on a repeated basis. During longer use periods, the force of the caps pressing against the canal entrance may be uncomfortable, but for those who prefer this type of device for extended use, better ones can offer very adequate protection.
The St Cloud School District shall designate Resources Training & Solutions as hearing conservation program administrator. The administrator should conduct random inspections to evaluate if proper hearing protection practices are being used and to evaluate the overall effectiveness of this program. This includes periodic review of noise levels present, engineering or administrative controls in place, changes in processes or equipment, any job function impairments while utilizing hearing protection devices, discuss with employees any other issues associated with hearing protection device use, ensure employees are provided training in the proper use and care of hearing protection and ensure the proper initial fitting and the correct use of all hearing protectors.
Audiometric Testing Program
The St Cloud School District shall establish and maintain an audiometric testing program making audiometric testing available to all employees whose exposures are equal or exceed the action level, which is an eight-hour, TWA noise exposure of 85 dBA. This program shall be provided at no cost to the employees.
The audiometric tests shall be performed by a licensed or certified audiologist, otolaryngologist, or other physician or technician who is certified by the Council of Accreditation and Occupational Hearing Conservation. All audiograms conducted on employees shall meet the requirements specified in Appendix C of the Standard.
Within six months of an employee's first exposure at or above the action level, the St Cloud School District shall establish a valid baseline audiogram against which all subsequent audiograms can be compared. At least annually after obtaining the baseline audiogram, the St Cloud School District shall obtain a new audiogram for each employee exposed at or above the action level of an eight-hour, TWA noise exposure of 85 dBA. Testing to establish baseline audiogram shall be preceded by at least 14 hours without exposure to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline audiograms be preceded by, 14 hours without exposure to workplace noise.
Each employee's annual audiogram shall be compared to that employee's baseline audiogram to determine if the audiogram is valid and if a standard threshold shift is encountered as defined in the Standard in paragraph (g)(10): Standard Threshold Shift. If the annual audiogram shows that the employee has suffered a standard threshold shift, the St Cloud School District may obtain a retest within 30 days and consider the results of the retest as the annual audiogram. The audiologist or physician shall review problem audiograms and determine whether there is a need for additional evaluation. If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold shift as defined in the Standard, that employee shall be informed of this fact in writing within 21 days of the determination.
Unless a physician determines that the standard threshold shift is not work related, the St Cloud School District shall insure that the following steps are taken when a standard threshold shift occurs:
- Employees not using hearing protectors shall be fitted with hearing protectors, trained in their use and care, and required to use them;
- Employees already using hearing protection shall be refitted and retrained in the use of hearing protectors, and provided with hearing protectors offering greater attenuation if necessary;
- The employee shall be referred for clinical audiological evaluation or an otological examination as appropriate, if additional testing is necessary or if the St Cloud School District suspects that a medical pathology of the ear is causing or is aggravated by the wearing of hearing protectors; and
- The employee is informed of the need for a otological examination if a medical pathology of the ear that is unrelated to the use of hearing protection is suspected.
All St Cloud School District employees required to wear hearing protection devices shall receive training prior to initial use and annually thereafter. The primary components of the training program include the following:
- Job classification and work-task activity which require the use of hearing protection devices;
- The effects of short-term and long-term noise exposure on hearing;
- The purpose of hearing protectors, the advantages, disadvantages and the attenuation of various types of protectors;
- Selection, fitting, use and care of hearing protection devices;
- Audiometric testing program, purposes of the program, explanation of the test procedures; and
- Training records must be made available to employees or their representatives. A hearing protection training log can be found in Appendix B.
The St. Cloud Area School District shall retain the following records associated with their hearing conservation program:
- All employee exposure measurements;
- All employee audiometric records including the name and job classification of the employee, the date of the audiogram, the examiner’s name, the date of the last acoustic or exhaustive calibration of the audiometer, and the employees most recent noise exposure assessment.
- Measurements of the background sound pressure levels in the audiometric test room.
The St. Cloud Area School District shall retain the records for at least the following periods:
- Noise exposure measurements shall be retained for two years; and
- Audiometric test records shall be retained for the duration of the effective employee’s employment.
The St. Cloud Area School District shall, upon request, provide to employees, former employees, representatives designated by the individual employees, and OSHA all records applicable to this hearing conservation program.
Appendix A: Compliance Checklist
Appendix B: Training Log
Appendix C: OSHA Standard
Occupational Noise Exposure - OSHA 29 CFR 1910.95
Appendix D: Audiometric Testing Roster
Appendix E: Noise Surveys and Dosimeter Readings