Has the Occupational Safety and Health Administration record-keeping rule changed hearing loss prevention programs?

Abstract

The Occupational Safety and Health Administration (OSHA) record-keeping rule 29 CFR part 1904.10, changed the definition of recordable hearing loss and created a separate column on the OSHA 300 form to record noise-induced hearing loss (NIHL). In an effort to identify possible effects of the record-keeping rule change, an informal written survey was distributed at the National Hearing Conservation Association (NHCA) annual conference in February, 2006. NHCA conference attendees, because they specialize in hearing loss prevention, are likely to be familiar with hearing conservation issues so their perceptions are of particular interest. A total of 36 attendees, including audiologists, audiometric technicians (OHC), industrial hygienists (IH), mobile test company owners, occupational medicine physicians (OMP), and occupational health nurses (OHN) completed the ten-question survey. In summary, there appears to be a consensus that the everyday practice of hearing loss prevention has been affected by the record-keeping rule change, with both positive and negative influences. Employers seem to be paying more attention to HLPPs, which is, by itself, a positive outcome. Somewhat alarming however, is the finding suggesting that recordable STSs may be being ‘‘lined-out’’ or ‘‘denied’’ inappropriately in order to keep recordable rates artificially low.