As I have said before, these OSHA “Approval of Information Collection (Paperwork) Requirements” request for comments is such a nice summary of what we have to do to just meet OSHA minimums and properly manage some of our programs. So many non-safety managers have no idea what their safety professionals do day-to-day, so I like to highlight these activities. This month it is OSHA’s Hearing Conservation Program (1910.95) and anyone who has an HCP knows the time demands in PROPERLY MANAGING this program, but here is how OSHA breaks it down:
The collection of information specified in the Noise Standard (29 CFR 1910.95) protects workers from suffering material hearing impairment. The collection of information contained in the Noise Standard includes:
(PLEASE NOTE I have added some “details” to these requirements for those not quite sure about what it means to manage a hearing conservation program)
- conducting noise monitoring (including updating the monitoring whenever a change in production, process, equipment or controls increases noise exposures to the extent that:
- Additional employees may be exposed at or above the action level; or
- The attenuation provided by hearing protectors being used may be rendered inadequate
- notifying workers when they are exposed at or above an 8-hour time-weighted average of 85 decibels (dBa);
- providing workers with initial (baseline) and annual audiograms;
- notifying workers of a loss in hearing based on comparing audiograms (BOTH verbally AND in writing within 21 days);
- maintaining records of workplace noise exposure and workers’ audiograms; and
- allowing workers access to materials and records required by the Standard.
And if you will allow me to add one (1) more; the TOP HCP audit finding in my career…
1910.95(l)(1) The employer shall make available to affected employees or their representatives copies of this standard and SHALL ALSO POST A COPY IN THE WORKPLACE.
And for those who wonder if “electronic access” to 1910.95 is an acceptable alternative to paper posting in this day and age of computers, here is what OSHA said in a 2016 LOI… (emphasis by me)
Question: Is it acceptable to utilize electronic access to a resource such as OSHA.gov to comply with 29 CFR 1910.95(l)(1)?
Response: The Noise standard at 29 CFR 1910.95(l)(1) states, “The employer shall make available to affected employees or their representatives copies of this standard and shall also post a copy in the workplace.” OSHA’s policy regarding the intent of posting the noise standard remains the same as that stated in the February 9, 1988 letter of interpretation. This letter, however, updates that policy for the use of electronic posting. Electronic posting of the Noise standard will meet the posting requirement of 29 CFR 1910.95 (l)(1) ONLY IF THE FOLLOWING CONDITIONS ARE MET:
- The employer’s hearing conservation program TRAINING INCLUDES SPECIFIC INFORMATION to affected employees ON WHERE AND HOW TO ACCESS the Noise standard electronically.
- The link provided to affected employees to access the OSHA Noise standard electronically is NOT to a main web page, such as the employer’s web site, or OSHA’s home page, but DIRECTLY TO THE OSHA NOISE STANDARD at [https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95].
- Computers are located within the affected employees’ work area so that they have access to the noise standard WITHOUT HAVING TO REQUEST ACCESS TO A COMPUTER OR ASK FOR ASSISTANCE RETRIEVING THE OSHA NOISE STANDARD ELECTRONICALLY.