Issues: Occupational and Environmental Hearing Conservation
Relevant Paper
Ad Hoc Committee on Occupational and Environmental Hearing Conservation
About this Document
This report was prepared by the American Speech-Language-Hearing Association (ASHA) Ad Hoc Committee on Occupational and Environmental Hearing Conservation and approved by the ASHA Executive Board in August 1996 (EB 39-96). Committee members included Derek E. Dunn; Rena H. Glaser; Theresa Y. Schulz, chair; Andrew P. Stewart; Maureen E. Thompson, ex officio; and Vickie L. Tuten. Lawrence W. Higdon served as monitoring vice president.
Introduction
This report summarizes the major issues affecting occupational and environmental hearing conservation service delivery by audiologists. Each issue is summarized, a strategy is suggested, and specific Association actions are recommended. Recent actions taken by ASHA are noted as well. This has been done to provide concrete examples of each issue. Such activities should continue and evolve to meet the ever-changing environment. The major issues identified relate to coalition activity, continuing education, professional education and training, public awareness, and legislation/regulation.
Coalition Activity
Issue
Cooperation among professional organizations has been critical to the success of many hearing conservation initiatives. Most professional organizations have limited resources to accomplish their missions. Collaborative agreements, partnering, and coalition activities allow those limited resources to go farther.
Strategy
Continue and develop additional cooperative efforts with such organizations as the Acoustical Society of America (ASA), the American Academy of Audiology (AAA), the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS), the American Association of Occupational Health Nurses (AAOHN), the Air Force Audiology Association (AFAA), the American Industrial Hygiene Association (AIHA), the Association for Research in Otolaryngology (ARO), the Council for Accreditation in Occupational Hearing Conservation (CAOHC), the U.S. Environmental Protection Agency (EPA), the Institute for Noise Control Engineering (INCE), the League for the Hard of Hearing, the Military Audiology Association (MAA), the National Hearing Conservation Association (NHCA), the Navy Audiology Association (NAA), the National Institute of Deafness and Other Communication Disorders (NIDCD), the National Institute for Occupational Safety and Health (NIOSH), the Occupational Safety and Health Administration (OSHA), and Self Help for Hard of Hearing People, Inc. (SHHH).
Recommended Actions
Establish a research and information coordinating committee composed of representatives from ASHA and selected allied and related professional organizations (ARPOs) to
survey relevant activities from each organization,
explore opportunities for collaboration in the areas of research or information dissemination (e.g., publications, presentations, meetings),
establish formal collaborative agreements,
provide recommendations to ASHA regarding the appropriate academic requirements for hearing conservation in graduate audiology programs,
develop hearing conservation program guidelines for referral that are cost-effective and that have a low false positive rate,
gather outcomes data for implementation of hearing conservation strategies, and
solicit funding for research in the area of hearing conservation.
Continue interactive meetings with ARPOs.
Maintain ASHA representation on CAOHC and ensure that ASHA's representatives are knowledgeable in the practice of occupational hearing conservation — particularly in training occupational hearing conservationists.
Recent Actions Taken
See Legislation/Regulation Section for recent coalition actions in which ASHA has been involved.
Continuing Education
Issue
Hearing conservation is an evolving field. Increasingly, audiologists are being asked to (a) provide consultation and testimony regarding the ability of employees with hearing loss to work in hearing hazardous jobs; (b) evaluate the effectiveness of hearing conservation programs; (c) consult on issues of community and/or environmental noise; and (d) understand the synergistic effects of noise with physical and chemical exposures.
Strategy
Ongoing continuing education opportunities must be provided to ensure that audiologists are prepared adequately to identify noise induced hearing loss and to provide hearing conservation services. These continuing education opportunities could be developed and hosted in partnership with ARPOs.
Recommended Actions
ASHA could host or cohost a conference to address emerging and ongoing issues in hearing conservation (e.g., nonoccupational noise exposure, forensic audiology, the effect of hearing loss in hearing critical jobs, hearing conservation program effectiveness [i.e, outcomes data], community noise, synergistic auditory effects of physical and chemical exposures).
Ensure adequate hearing conservation programming at the annual ASHA Convention by cohosting special sessions with ARPOs (e.g., AFAA, AIHA, ARO, CAOHC, NHCA, ASHA Special Interest Division (SID) 8) and governmental agencies (e.g., NIOSH, OSHA).
Recent Action Taken
ASHA SID #8 presents a short course annually at the ASHA Convention on hearing conservation.
Professional Education and Training
Issue
Action is required to ensure that professional graduate education for audiologists includes the requisite training and experience for providing hearing conservation services.
Strategy
The Council on Professional Standards (Standards Council) should be made aware that the absence of required semester hours of professional coursework in noise measurement/control and hearing conservation provide does not allow for even a minimum program of study for audiology students interested in providing hearing conservation services.
Recommended Actions
The Standards Council should establish a minimum required semester hours of professional coursework and practicum hours in noise and hearing conservation for graduate training programs in audiology.
The Standards Council should develop methods for graduate education programs to evaluate current course and practicum requirements in noise and hearing conservation and, where necessary, increase the minimum required semester hours.
ASHA SID #8 should consider developing and promoting a partnership between industries and universities to provide students with adequate internships in hearing conservation.
Recent Actions Taken
The ASHA Committee on Bioacoustics Standards and Noise Standards provides ASHA members with the opportunity to participate in the development of national (American National Standards Institute Standards [ANSI]) and international (International Electrotechnical Commission [IEC], International Organization for Standardization [ISO]) standards in areas that influence the practice of audiology and the safety of the general public. The chair of the Committee also represents ASHA's position on Accredited Standards Committee S3, Bioacoustics, and Accredited Standards Committee S12, Noise.
Participation in the standards development and approval process is very important for ASHA and its members because these standards have an impact on professional practice and consumer protection. Current standards undergo regular review and revision. In addition, there is ongoing development of new standards. In order to apply the most current standards to clinical practice, ASHA members and regulatory bodies should be familiar with current acoustical standards.
In March 1995, ASHA appointed the first Clinical Specialty Board (CSB) consisting of four audiologists, four speech-language pathologists, one member of the Board of Division Coordinators, and two consumers. The Committee was charged with examining ASHA's position in regard to specialty recognition and developing recommendations for ASHA's Executive Board. ASHA recognizes that specialty recognition can be an advantage when applying for a new position or trying to secure a particular contract. The Specialty Recognition program developed by the CSB is completely voluntary and is not exclusionary. NHCA, ASHA SID #8, MAA, and AFAA have initiated a coalition application for Hearing Conservation Audiologist to be a recognized specialty.
Public Awareness
Issue
Excessive noise in nonoccupational settings can be hazardous. The general public needs to be educated regarding the actions necessary to prevent noise induced hearing loss.
Strategy
Provide information to the general public about hazardous noise and its deleterious effects on hearing health.
Recommended Actions
ASHA should produce public service announcements, brochures, and videotapes to educate the public about hazardous noise and its deleterious effects on hearing health.
ASHA should participate with ARPOs and coalitions in public awareness campaigns.
ASHA should produce public service announcements, brochures, and videotapes and participate with ARPOs and coalitions to educate children of all ages about loud noise, the damage it can cause and how to prevent noise induced hearing loss.
ASHA should consider participating in “International Noise Awareness Day” sponsored annually on April 24 by the League for the Hard of Hearing.
Recent Action Taken
As part of a continuing effort to inform the public about the profession of audiology, noise-induced hearing loss, hearing conservation, and hearing protection, ASHA joined forces with ASA, AIHA, INCE, and MAA in a Coalition for Hearing and Noise to co-sponsor National Save Your Hearing Day on May 31, 1995 at the annual ASA meeting in Washington, DC. The National Mall in Washington, DC was the site for the principal event, free hearing screenings, provided to visitors on the Mall.
Legislation/Regulation
Issue #1
ASHA member audiologists need to be informed about regulatory/legislative issues regarding noise and hearing conservation, specifically those initiatives that threaten OSHA, NIOSH, the Mine Safety and Health Administration (MSHA), and occupational hearing conservation programs. Also, legislators need to be made aware that the missions of OSHA, NIOSH, and MSHA are vital to minimizing workplace hazards, of which noise is the most prevalent.
Strategy
ASHA must take a proactive approach on regulatory reform initiatives to ensure that regulators are aware of the benefits of safety regulations.
Recommended Actions
ASHA and ARPOs should ensure that its member audiologists are kept informed of legislative/regulatory issues and actions related to noise measurement/control and hearing conservation through action alerts and articles in ASHA publications.
ASHA should continue its participation in the Coalition to Preserve OSHA and NIOSH.
ASHA should provide key members of Congress with an analysis of the benefits of the hearing conservation standard, including data on (a) the cost savings related to decreased workers' compensation awards, (b) increased productivity, and (c) decreased noise-related accidents.
Recent Actions Taken
In August 1995, the NHCA Task Force on Hearing Protector Effectiveness petitioned the EPA to review and revise the current EPA regulation concerning the labeling of hearing protection devices. In a letter to the EPA, ASHA supported NHCA's petition to review and revise the current EPA Hearing Protector Labeling Regulations and Procedures.
Bills have been introduced in the U.S. House and Senate that would substantially alter the missions of OSHA and NIOSH and the role of OSHA in enforcement of noise standards and occupational hearing conservation regulations. ASHA organized a coalition of professional and consumer organizations, the Coalition to Preserve OSHA and NIOSH, and submitted testimony to the two committees of jurisdiction.
Coalition members include ASHA, ASA, NHCA, AAO-HNS, and CAOHC. INCE endorsed the Coalition's testimony with members of Congress. ASHA's Governmental Affairs staff, working with the Audiology Division staff, will continue to lobby on OSHA/NIOSH reform and will monitor Congressional activity that effects funding and missions of these agencies.
In a letter to NIOSH, the Coalition to Preserve OSHA and NIOSH commended NIOSH for identifying work-related hearing loss research as a priority for the Agency. The Coalition recommended that NIOSH investigate further a variety of issues as they pertain specifically to the proposed research priority on hearing loss due to noise and nonauditory exposures.
In March 1996, the Coalition to Preserve OSHA and NIOSH testified before OSHA regarding the Notice of Proposed Rule, Occupational Injury and Illness Recording and Reporting Requirements (29CFR Parts 1904 and 1952). The Coalition went on record as applauding the Agency's proposed rule for recording hearing loss as an occupational injury. The Coalition urged regulators to reduce the proposed recordability criterion to standard threshold shift (an average of 10 dB at 2000, 3000, and 4,000 Hz in either ear) and presented extensive data-based testimony to support the recommendations. Member organizations of the Coalition who signed on to the comments include ASHA, AIHA, ASA, NHCA, AAO-HNS, and SHHH.
In November 1994, NHCA and ASHA presented comments and recommendations regarding workplace hazards or issues that “might warrant appropriate action” to the OSHA Standards Planning Committee during a public hearing. The primary task of the Standards Planning Committee was to develop a list of 50 workplace hazards or issues that warrant OSHA action.
In May 1994, representatives of NHCA and ASHA met with Joseph Dear, Assistant Secretary of Labor for Occupational Safety and Health, to discuss OSHA's authority for updating regulations and standards for noise hazards in the workplace. NHCA and ASHA outlined three areas that need attention: (a) OSHA policies; (b) the 1983 Department of Labor, OSHA, Occupational Noise Exposure, Hearing Conservation Amendment; and (c) the Noise Standard.
Issue #2
Worker's compensation data should be routinely updated and disseminated.
Strategy
An ongoing program to update and disseminate information on workers' compensation claim criteria and data should be developed.
Recommended Action
ASHA should collaborate regularly with ARPOs (e.g., NHCA, American College of Occupational and Environmental Medicine [ACOEM], AAO-HNS) to update and disseminate information on workers' compensation claim criteria and data for occupational noise-induced hearing loss. The updating and dissemination of tasks will be assigned to participating organizations on a rotating basis.
Issue #3
Many workers who are exposed to hazardous noise and other hearing health hazards in the workplace are not covered by regulatory protections.
Strategy
Establish working groups to identify worker populations and develop prevention strategies tailored to the specific population.
Recommended Action
Use the proposed ASHA coordinating committee to access information (e.g., national surveys, union databases, federal and state agencies/health departments) that can identify worker populations or job categories at risk that are not covered by hearing conservation regulations. In partnership with the appropriate groups, determine if special hearing conservation strategies are needed for the population and implement the strategies. Secure necessary support for changes in the current regulations to accommodate underserved populations and incorporate improved or appropriate hearing conservation strategies.
Recent Action Taken
In a letter to NIOSH, the Coalition to Preserve OSHA and NIOSH and Protect Workers' Hearing commended NIOSH for identifying work-related hearing loss research as a priority for the Agency and for extending coverage to the construction industry. The Coalition recommended that NIOSH investigate further a variety of issues as they pertain specifically to the proposed research priority on hearing loss due to noise and nonauditory exposures.
Issue #4
The Noise Reduction Rating (NRR) is an inadequate predictor of “real” hearing protector effectiveness.
Recommended Action
ASHA should continue to lobby the EPA to revise the Hearing Protector Labeling Regulation to include the provision of a new number on the primary label, and the use of a new test method to obtain more realistic values of hearing protector attenuation.
Recent Action Taken
The Task Force on Hearing Protector Effectiveness, which included an ASHA representative, was formed and coordinated by NHCA to reach consensus to revise the EPA's Hearing Protector Labeling Regulation. Recommendations included the use of a new test method to obtain more realistic hearing protector attenuation data, a new computerized scheme (NRR Subject Fit) to compute a single number rating from those data, an expanded secondary label to provide more comprehensive guidance on hearing protector selection, requirements for testing by accredited laboratories, and a recommendation to mandate periodic retesting to ensure data would reflect current production products. The Task Force prepared a report and explicit recommendations which were approved by the ASHA Executive Board and published in 1995.
Index terms: hearing conservation, legislation and regulation
Reference this material as: American Speech-Language-Hearing Association. (1997). Issues: occupational and environmental hearing conservation [Relevant Paper]. Available from www.asha.org/policy.
© Copyright 1997 American Speech-Language-Hearing Association. All rights reserved.
Disclaimer: The American Speech-Language-Hearing Association disclaims any liability to any party for the accuracy, completeness, or availability of these documents, or for any damages arising out of the use of the documents and any information they contain.
doi:10.1044/policy.RP1997-00021
