OSHA’s current age-correction table, Appendix F, discontinues at age 60. More people are working into their sixties instead of retiring, and there is no adequate way to assess presbycusis (age-related hearing loss) in these workers using the current OSHA table. OSHA’s age-correction tables were based on a small sample size and research from the 1970’s. You advocate for the use of NHANES data-derived age-correction tables, stating that they are based on recent data with a much larger sample size and a wider age range sampled when compared to the OSHA age-correction tables. You provided a comparison of the OSHA age-correction tables and the newer NHANES data-derived age-correction tables that show age-related hearing loss continues to occur beyond age 60.
Will OSHA allow the use of the NHANES data-derived age-correction tables (hybrid data) for workers 61-75 years old when determining the cause and work relationship of hearing loss in this older age group?
Response: Paragraph (g)(10)(i) of OSHA’s noise standard provides that age correction for the change in hearing level may be made according to the procedure described in Appendix F. 29 CFR § 1910.95(g)(10)(i). OSHA will allow the use of the NHANES age-correction data for the creation and use of age-correction tables other than the ones in Appendix F under certain conditions. For any table based on NHANES data, all the values should be calculated from one dataset to avoid using values from different data sets. For example, the hybrid table listed in your letter’s reference is impermissible because it uses values from the OSHA data set while using the NHANES data for anyone over 60.
If an employer chooses to use age-correction tables other than the tables in Appendix F, then the decision to age-correct, and therefore, which table based on NHANES data to use, must be made by a certified audiologist, otolaryngologist, or other physician, and must take into account the employee’s noise exposure levels, years of exposure, inclusion in a hearing conservation program, use of hearing protection, and other medical history. OSHA recommends that one set of tables, such as the NHANES data, should be selected and applied equitably for all workers at the onset of their inclusion in a hearing conservation program starting with the baseline audiogram. The employer should maintain a copy of the published reference and tables with the audiometric records.
Regarding recording hearing loss, OSHA’s recordkeeping regulation at 29 CFR § 1904.10(a) requires employers to record hearing loss cases when an employee’s audiogram reveals that the employee has experienced a work-related standard threshold shift (STS) in one or both ears, and the employee’s total hearing level is 25 decibels (dBA) or more above audiometric zero (averaged at 2000, 3000 and 4000 Hz) in the same ear(s) as the STS. In addition, 29 CFR § 1904.10(b)(3) states, “While age-correction is allowed when determining whether an STS has occurred, an age-correction may not be used when determining whether the employee’s total hearing level is 25 dBA or more above audiometric zero.”
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