More on Hearing Protection Training: A Deeper Dive into Standard 1910.95(a)


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The Occupational Noise Exposure mandate (OSHA’s 29 CFR 1910.95) requires employees exposed to 85dBA TWA be enrolled in the HCP. Employers are required to ensure employees participate in hearing conservation training for the duration of their employment. This should begin with initial orientation training, followed by annual reinforcement. 

Section 1910.95(a) part of the standard initiates and establishes a hearing conservation program to protect personnel from the effects of occupational noise exposure. Here is a short look at the “what,” “who,” “how” and “when” of hearing conservation implementation. 

What Should be Taught

29 CFR 1910.95 includes specific guidance as to what topic areas must be covered annually. The required topics can be broken into three groups of information:

  1. The effects of noise on hearing
  2. The purpose of hearing protectors; the advantages, disadvantages and attenuation of various types; and instructions on selection, fitting, use and care
  3. The purpose of audiometric testing and an explanation of the test procedures

Who Should Be Trained

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According to audiologists Dr. Vickie Tuten and Dr. Kathy Gates, all employees exposed to 85 dBA TWA, for even one day, need to be enrolled in the HCP. 85 dBA TWA is referred to as the action level (AL) under OSHA. The program must have at a minimum, annual testing, annual training and available hearing protection to enrolled employees. When employees reach the Permissible Exposure Limit (PEL) of 90dBA TWA, hearing protection is mandated. Annual education and training remain a constant throughout, once the AL is reached. 

How to Conduct Training

Industrial hygienists are in a perfect position to provide formal training and impromptu education, when conducting area monitoring or dosimetry. Formal training should always be documented and records maintained, in case of an audit. Informal or impromptu education serves as great reinforcement to remind workers of the importance of adopting good hearing conservation practices, noted Drs. Gates and Tuten.

The training element is flexible and allows for creativity to be incorporated into the process. When you break the topics into the three groups of information listed above, the primary focus of the industrial hygienist would be to provide training on the “effects of noise on hearing” and “all things hearing protection.”

The third required topic, “purpose of audiometric testing and explanation of test procedures,” should be provided by the hearing technician at the time of the hearing test. The topic “effects of noise on hearing” can be delivered at any time. This could be covered during a formal training session or shared with workers while visiting individual worksites. Informal education sessions are “excellent opportunities to discuss the noise hazards being heard in participants’ workplaces; how unprotected exposures to this noise hazard may result in a permanent injury/illness; and how properly worn hearing protection can mitigate the risk of a permanent hearing loss,” stated Gates and Tuten. 

When Training Should Occur

HCP training must be completed annually, and employers must ensure employee participation. The education and training element allows flexibility for the employer to provide the training at different times throughout the year, by any HCP team member. “There is not a requirement to discuss all mandated education and training topics in a single event; however, the mandatory topics need to be covered and employee attendance rosters maintained,” stated Drs. Tuten and Gates. 

[Editor’s note: Much of the material used in this article first ran in IHW’s March/April 2021 issue in an article titled “Now Hear This: Right Steps for Hearing Conservation Training.” For the entire article, go to https://industrialhygienepub.com/hearing/now-hear-this-right-steps-for-hearing-conservation-training/ .]

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