According to the U.S. Occupational Safety and Health Administration's (OSHA) record keeping regulation (29 CFR 1904.10), companies are required to report documented hearing loss in the form of qualifying Standard Threshold Shifts (STS), on the OSHA 300 Log. There is evidence that occupational hearing losses are routinely under-reported. Professional supervisors (audiologists and physicians) have at times reported difficulties in making a determination of recordability and work-relatedness. Some have also reported pressure from clients to alter their professional assessment in a manner which benefits the client.
"These guidelines for recording hearing loss cases are the result of over two years of intensive review by a task force of hearing healthcare professionals chaired by Dr. Alice Suter," said NHCA President Timothy L. Rink, Ph.D. "Physician and audiologist reviewers who are responsible for making the determination to record an OSHA STS on the 300 Log will now have consistent and uniform guiding principles to assist them in making that decision."
Under these guidelines, NHCA advises professional reviewers to take into consideration the following when determining occupational hearing loss for documentation on the OSHA 300 Log:
- OSHA's policies as well as legal determinations that if it is more likely than not that any part of a qualifying hearing loss is work related, it must be recorded.
- Noise measurements - including work area and personal dosimetry measurements to determine the worker's time-weighted average exposure level.
- Audiometric configuration - describing configurations consistent with non-work-related causes.
- Non-occupational exposures and medical history.
NHCA's guidelines also provide advice to professional service providers as to how to deal with pressure to under-document occupational hearing loss, and emphasize the need for consistent, diligent follow-up for STS occurrences, whether or not the STS meets the qualifications for recordability, in order to prevent further loss.
These guidelines can be found on NHCA's Web site at www.hearingconservation.org/associations/10915/files/Guidelinesforworkrelatednessdraft8.pdf
About the National Hearing Conservation Association (NHCA)
The mission of the National Hearing Conservation Association is to prevent hearing loss due to noise and other environmental factors in all sectors of society. NHCA provides networking, resources and professional development opportunities to improve skills, practices, and services for its members. NHCA's membership includes audiologists, researchers, students, industrial hygienists, educators, professional service organizations, safety professionals, medical professionals, engineers, audio professionals and others who have dedicated their work to the advancement of hearing loss prevention. For more information about the National Hearing Conservation Association, visit us online at www.hearingconservation.org.
