T K Group
Answers to the most common hearing conservation questions.
Effective 1/1/2003, each ear must maintain its own baseline per OSHA mandate. A baseline is revised upon a persistent 10 dB STS in the affected ear(s).
OSHA permits age correction to account for the potential decline in hearing associated with the natural aging process (presbycusis). Unless otherwise requested, T K Group age corrects all data except for data residing in Washington or Oregon, as age correction is not permitted in the 10 dB STS analysis in those states.
OSHA suggests that all records be retained for the employee's duration of employment. NIOSH recommends retaining records for the duration of employment plus 30 years. T K Group recommends perpetual maintenance of records in the event of subsequent compensation litigation.
A 10 dB Standard Threshold Shift (STS) is a 10 dB or greater shift as averaged at 2000, 3000, and 4000 Hz referenced to the baseline (first test) or revised baseline. Comparison calculations incorporate age correction.
A 10 dB STS may indicate early stage noise-induced hearing loss; hence OSHA developed the 10 dB STS criteria to serve as an early indicator of noise-induced hearing loss. This is not to say, however, that all shifts are noise induced.
A persistent shift event suggests a permanent shift in hearing at 2000, 3000, and 4000 Hz in the affected ear(s).
A non-persistent event suggests no permanent change in hearing at 2000, 3000, and 4000 Hz in the affected ear(s). A non-persistent shift status may be attributed to acute pathology, waning attention span, or an early indicator of noise-induced Temporary Threshold Shift (TTS).
Schedule a retest within 30 days to determine if the shift is persistent or non-persistent. OSHA Permits a retest within 30 days after the date of the shift to determine shift persistency.
Yes. It is always best to obtain a retest.
No. The end result is still valid regardless of the date of the retest.
1. Deliver written notification of the event to the employee within 21 days of the shift date.
CONTRACTUAL MOBILE SERVICE CAVEAT: If your contract included on-board Employee Notification Letters, applicable employees received the OSHA mandated 21-day written notification requirement on the van.
2. Ensure the employee wears hearing protection if working in an 85 dB or greater noise environment (8-hour time weighted average).
3. If protection was previously used, refit the employee for protectors and re-train on proper preventive measures. If protection was not previously used, the employee must be fitted with, and required to use, appropriately attenuating hearing protection.
CONTRACTUAL MOBILE SERVICE CAVEAT: If your contract included on-board training, applicable employees received OSHA mandated training/hearing protector check/re-fit consultation and thus the training/hearing protector check/re-fit requirement has already been satisfied. *** If your contract did not include on-board Employee Notification Letters, the OSHA mandated 21-day written notification of 10 dB STS has not yet been satisfied and the provided Employee Notification Letter must be distributed. Retain a SIGNED copy in your records. *** If your contract did not include on-board training, employees with persistent 10 dB STS status upon retest must be fitted with and required to use appropriately attenuating hearing protection AND receive retraining on proper preventive hearing loss measures. If hearing protectors are already in use, the protectors must be checked and re-fitted if necessary to assure protective adequacy.
A Potential (OSHA) Recordable Shift is a 10 dB Standard Threshold Shift (STS) with a pure average equal to or greater than 25 dB at 2000, 3000, and 4000 Hz. All states recognize the federal recordable criteria.
A recordable STS is an STS where the average of 2K, 3K, and 4K Hz thresholds is equal to or greater than 25 dB. In abstract terms, it's an STS where the scores indicate the test subject's hearing has fallen outside the range of normal hearing acuity. Recordable STSs may be required to be reported on OSHA's 300 Log, whereas non-recordable STSs are not so required. See "Is every potential recordable event recordable" below for more information.
It is quite possible to sustain a 10 dB STS without sustaining Recordable status; that employee's hearing remains essentially within normal range despite a shift.
Changes in hearing are not always noise-induced; likewise, each Recordable event should not automatically be considered "occupationally" related-hence the term "Potential" Recordable is preferred.
No. If a 30-day retest is anticipated, Recordable events need not be posted to the OSHA 300 Log until the shift is shown persistent by retest.
The event must be posted to the OSHA 300 log within 7 days of official notification of the persistent shift status.
Technically, 37 days from the date of the shift.
A non-persistent shift status automatically eliminates any obligation to post that event to the OSHA 300 log and/or determine work-relatedness.
There is no "statute of limitations" associated with non-persistent "lineouts", such that a non-persistent shift status on a test two years previous, for example, may be lined off that year's log.
While the 10 dB STS proved persistent, the Recordable component (i.e. 25 dB or greater average at 2000, 3000, and 4000 Hz) did not persist.
No; there is no OSHA Requirement to make written notification of Recordable events, and for this reason, Employee Notification Letters make no reference to Recordable status.
No; barring occupationally related trauma (blast trauma, etc), non-noise exposed employees do not fall under the federal noise regulation umbrella.
A certified occupational hearing conservationist (COHC) is a hearing technician who has passed a certification course organized by the Council for Accreditation in Occupational Hearing Conservation (CAOHC). CAOHC courses provide in-depth instruction in the many areas of hearing conservation, including ear anatomy, physics of sound, regulations, audiometric testing, audiometric evaluation, noise measurement, hearing protector fitting, and recordkeeping.
A physician, audiologist, or other licensed and "qualified" health care professional may determine work relatedness.
1. A Work Relatedness Determination is requested by submitting a Work-Relatedness Determination (WRD) Questionnaire. The questionnaire form is available for download from this website.
2. Fax, mail, or email the Extended Questionnaire to the attention of DATA PROCESSING. The reviewing T K Group Audiologist will review the case and render a written determination. A determination deemed non-occupationally related may be lined off the OSHA 300 Log.
Determination outcomes have no relationship to shift status. T K Group must identify all 10 dB STS and Recordable shift activity. A Work Relatedness Determination deemed nonoccupationally related serves as your basis not to log that individual to the OSHA 300 log.
No; each new event requires a new determination.
The reviewing audiologist must render a decision based upon evidence provided (audiometric data, dosimetry, Extended Questionnaire). If significant new information is discovered post determination, forward that information to the audiologist for a second review. Neither T K Group, nor the T K Group audiologist, possesses a regulatory enforcement function. An occupationally or non-occupationally related determination conveys a professional "best practice" recommendation based upon all known evidence provided. In the end, the decision to log or not to log must be left to the discretion of (client) corporate authority.
A Medical Referral recommendation suggests potential pathology related to the ear and/or associated neural pathways. Persons on the Medical Referral listing satisfied our adopted criterion to necessitate a Medical Referral Recommendation based upon audiometric characteristics and/or case history responses. Since OSHA does not mandate medical referral criteria, T K Group adopted the American Academy of Otolaryngology (AAO) Otologic Referral criteria for use in occupational hearing loss prevention programs.
OSHA mandates that Medical Referral recipients be notified of the need to seek further medical consultation. Applicable workers may choose on their accord to seek physician consultation.
Contractual Mobile Service Caveat: If your contract included on-board Employee Notification Letters, applicable Medical Referral recipients received Medical Referral Notification on the van and thus referral notification requirement has already been satisfied. ***If your contract did not include on-board Employee Notification Letters, referral notification has not been satisfied and Employee Notification Letters provided in the report must be distributed to employees. Retain a SIGNED copy in your records.
No, unless an ear condition is determined work-related. Consult your corporate authority, however, since unique corporate-specific protocols may apply.
No. Medical Referral recipients DO NOT require a retest unless they are also listed on the 10 dB STS and/or OSHA Recordable listings. There is no relationship between shift status and referral status. A worker may satisfy the referral criterion without sustaining a shift; conversely, a worker may sustain a shift without a Medical Referral.
A Medical Referral Advisory is a supplemental referral recommendation issued by the reviewing T K Group audiologist when an acute and/or potentially emergent loss pattern is noted. Advisories have no relationship to current Medical Referral and/or shift status.
For First Test Audiograms: 1. An averaged hearing level at 500, 1000, 2000, and 3000 Hz greater than 25 dB, in either ear. 2. A difference in average hearing level between the better and poorer ears of more than 15 dB at 5000, 1000, and 2000 Hz. 3. A difference in average hearing level between the better and poorer ears of more than 30 dB at 3000, 4000, and 6000 Hz.
For Annual Audiograms: 1. A change for the worse in average hearing level, in either ear, compared to the baseline audiogram of more than 15 dB at 500, 1000, and 2000 Hz. 2. A change for the worse in average hearing level, in either ear, compared to the baseline audiogram of more than 20 dB at 3000, 4000, and 6000 Hz. Case History Criteria: Report of the following ear-related complaints in the preceding 12 months for which NO medical consultation has transpired: Ear Pain; Drainage; Dizziness; Ringing; Sudden, Fluctuating, or Rapidly Progressive Hearing Loss; or Feeling of Fullness.
