Execute Your Hearing Conservation Program

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Execute Your Hearing Conservation Program

Three key steps to get you headed down the right path.

You’ve assessed the noise levels in your plant and suspect that you have a noise exposure situation that calls for a hearing conservation program.

Here are three key steps to get you headed down the right path as you put your plan into practice.

1. Professional Assessment

David Strevig of Shelter Systems Limited has had a hearing conservation program in place for 15 years. When Shelter originally created the program, they knew they needed help from an outside consultant. “We asked our third party inspector to do our original monitoring,” Strevig said. Shelter works with retired Maryland OSHA Regional Supervisor Dale Valentine, and he “knows every rule and every law.” At the end of Valentine’s full eight-hour time study, the decibel readings from the professional meters indicated that the noise exposure was just shy of the OSHA-allowed maximum time-weighted average noise level of 85 decibels for an eight-hour shift. Shelter decided it wasn’t taking any risks.

2. Exposure Control

Hierarchy of ControlsIn an effort to regulate the amount of noise the employees were exposed to, Shelter started at the top of the hierarchy of controls, a system used throughout industrial management to effectively mitigate hazards. “We purchased between 200 and 300 baffles and hung them in our ceiling,” Strevig explained. Shelter hoped this engineering solution would absorb a portion of the sound bouncing around their shop, but with 30-foot ceilings, said Strevig, “it just didn’t work.” Unfortunately, large, open floor plans with tall ceilings can make it difficult for physical barriers to readily control the noise.

That said, Tom Christensen of PDJ Components notes that engineering controls are a critical part of what ensures noise exposure is limited to only one area of the plant. “Not all saws are created equally,” Christensen said. “You don’t get the same level of [noise] output from saws that have a cabinet built around them.” For PDJ, using saws that operate inside an enclosure means that the operator and catcher are exposed, but only the saw area is affected by the noise because the enclosure works as a sound damper.

For both Shelter and PDJ, measures beyond engineering controls are necessary to reduce the exposure to a safe level. Both companies have implemented a
program that uses one of the most popular forms of hearing protection: disposable foam ear plugs. For PDJ, the hazardous exposure is limited to the saw area; at Shelter, everyone wears hearing protection. Shelter tried a variety of styles and brands of ear plugs but “narrowed it down to a couple that everyone likes.” They go through numerous boxes of each type every month, but that doesn’t bother Shelter; they take hearing conservation seriously. “When we train,” Strevig said, “we encourage the guys to take extras home and wear them when they mow the lawn or go to rock concerts. I am always telling the team, ‘go ahead, take them home, I don’t care. We just want you to wear them.’”

Another thing, Christensen noted, is that it’s critical to safeguard employees from adding to noise levels unintentionally. “The guys like to crank up their music,” he said, which can add to the hazard if it’s not monitored carefully.

3. Constant Monitoring

Personal Protective EquipmentThe third, and likely most critical, piece of any hearing conservation program is monitoring its effectiveness. It’s easy for employees to overlook PPE, so making sure they’re wearing it, when required, is serious. Shelter’s policy is straightforward, Strevig explained: when employees come out of the locker room and go out on the floor, “I’m looking for head, eyes, ears, toes and gloves—no exceptions.” And there are clear-cut consequences for anyone found at a station without the appropriate PPE, penalties that range in severity from a verbal warning to unpaid time off.

No matter the repercussions, if you’re not doing something about hazardous noise exposure in your facility, the ultimate consequence could be hearing loss. Keep your team safe and your ears open because you never know what noise may be creeping into the mix. It might be a new piece of equipment…or a new album release from your sawyer’s favorite band.

About the Author: Molly E. Butz worked with CMs to develop the original SBCA Operation Safety Program and has over 12 years of experience helping CMs develop and maintain safety best practices.