o are losing their hearing have a baseline that is already degraded," he explains. "This expands my mind about the amount of hearing loss going on in hearing protection programs."
There are a number of reasons why workers do not wear hearing protection, or wear it properly. Poor education, awareness and training are common problems, as is the failure of the employer to provide a sufficient variety of protective devices. If a worker can't find a device that fits, it won't be comfortable and it won't be worn.
Protecting workers who already have hearing loss can be especially challenging, according to Laura R. Ray, associate professor at the Thayer School of Engineering of Dartmouth College. "In occupational environments, you do need to hear certain things, such as warning bells or your co-workers. Many people already have hearing loss, so these devices makes the problem worse."
Fortunately, there are some new products on the market that can increase the chances workers will use hearing protectors and that will not block out sounds they need to hear (see sidebar on page 28).
Given how well the problem is understood, some occupational health experts express frustration at the persistence of hearing loss, more than three decades after OSHA issued its standard.
Dr. Michael Metz, director of audiology for Ear Professionals International Corp., a consulting firm headquartered in Industry, Calif., puts it this way: "We know what causes hearing loss, what controls to use, and how to fix noise, but what we don't know is how to make anybody in industry or government give a darn."
Government and industry may soon have some good reasons to "give a darn."
Risks for Employers
Rampant hearing loss is confronting companies with at least two risks. First, workers are losing their hearing, and many are suing their employers. Second, employers may have grown too complacent about the way OSHA interprets and enforces 1910.95.
"Hearing protection has come to be considered an appropriate way to protect your employees, but that's not the way the standard was written," says Dan Belcher, president of Noise Suppression Technologies Inc. based in Columbus, Ohio. Originally, the standard was intended to compel employers to reduce noise levels. "We're in this situation because many employers aren't well-educated about the standard, and OSHA is not enforcing it."
The standard states that when employees are exposed to noise that exceeds 90 dB TWA (time-weighted average for an eight-hour period), "feasible administrative or engineering controls shall be utilized." If such controls fail to bring noise down to the permissible exposure level, "personal protective equipment shall be provided and used to reduce sound levels."
The preamble to the hearing conservation amendment to 1910.95, published in the Federal Register Jan. 16, 1981, states: "The agency continues to support the policy, reflected in the existing standard and not affected by this amendment, that engineering control of noise is preferable to the use of personal protective devices."
But because of the difficulty of determining when engineering controls are "feasible," since the 1980's in most cases OSHA has in fact focused on personal protective equipment.
"I have seen no evidence that OSHA is motivating companies to do noise engineering controls," says Robert Anderson, principal with James, Anderson, and Associates, a consulting firm specializing in noise control management that is based in Okemus, Mich.
It is the fear of legal liability, rather than an OSHA citation, that leads most companies to seek engineering solutions to their noise problems.
"Our business is not driven by OSHA," declares Kris Kollevoll, president of BRD Noise and Vibration Control, a company that abates noise for manufacturers and offers training for OSHA compliance officers. "OSHA checks you out for noise very rarely. They just don't have the manpower."
Instead, says Kollevoll, concerns about general liability issues are the most important factors that lead employers to see the value of engineered solutions.
"Compliance 