Understanding and applying Occupational Safety and Health Administration (OSHA) standards is at the heart of any safety and health program. That’s the thinking behind this Compliance Report, a review of two widely applied and frequently cited standards, Occupational Noise Exposure (29 CFR 1910.95) and permit-required confined space (29 CFR 1910.146).

The article aims to provide a helpful overview of the requirements, as well as some compliance tips to give your programs a boost, or to help you get one off the ground. 

Hearing conservation (29 CFR 1910.95)
More than 10 percent of the U.S. population suffers some degree of hearing impairment. Jackhammers, electric razors, crowded freeways, noisy offices, manufacturing equipment, and stereo headsets are among the many culprits.

The hearing conservation section of OSHA’s noise exposure standard requires that employers establish “a continuing effective hearing conservation program” if their facility generates high noise levels, that is, levels exceeding 85 decibels (dB) on an eight-hour time-weighted average (TWA). 

The noise volume in a typical office is about 70-75 dB. A sander emits about 85 dB; factory noise is 80-90 dB; and the sound of a pneumatic drill is about 100 dB. By way of comparison, a whisper is about 10 dB, and a car horn is 120.

It’s estimated that more than 9 million people are exposed to job-related noise levels above 85 dB, most of whom work in manufacturing and utilities.

High noise levels are quite common in workplaces where metal-on-metal impacts occur, such as metal fabrication plants. But food processing, textiles, lumber and wood, and many other industries are also big noisemakers.

When assessing the risk of noise-induced hearing loss, it’s essential to consider the exposure duration. Noise levels even as high as 130-140 dB can be harmless if the duration is extremely short and if there are no or few repetitions.

It’s the law!
OSHA says that if employees are regularly exposed to noise levels above 85dB, they must be required to wear hearing protection devices in areas of high noise. Also, they must be trained in the potential hazards of noise exposure, and must be offered a choice of hearing protection devices.

The training program must include:
(1) information on the effects of noise on hearing;
(2) the purposes of hearing protectors, including their advantages and disadvantages, the attenuation provided by various types, and the instructions on their selection, fitting, use and care;
(3) the purpose of audiometric testing and an explanation of testing procedures. 

Protection measures can include the following:
• reorganizing equipment, facilities, and/or tasks to reduce noise levels;
• monitoring individual and work-area noise levels and reporting high levels to employees;
• testing employee hearing with annual follow-ups;
• providing hearing protectors where needed. 

Noise reduction strategies
Noise can be reduced in a work area through a variety of strategies. 

Among them:
• separating noisy machinery or operations;
• keeping equipment well-maintained and lubricated so it doesn’t rattle or squeak;
• replacing worn or loose machine parts;
• using substances like wood or plastic instead of metal when possible;
• using sound-absorbing acoustical tiles on the floor, ceiling or walls;
• considering noise levels during the new equipment purchasing process;
• trying to perform noisy maintenance tasks after hours. 

The standard requires that hearing protectors reduce the noise to no higher than 90 decibels.

There are three categories of protectors. Earmuffs usually provide the greatest amount of protection to the ears. They consist of a headband, ear cups and ear cushions. Earplugs seal the ear canal and keep noise from getting through to the ear’s delicate parts. There are quite a variety on the market. Some come in standard sizes, while others are custom-fitted to the ear. Canal caps are soft pads on the ends of a headband, similar to headphones. The caps, which must fit snugly, seal the entrance to the ear canal rather than entering it, as earplugs do.

Some particularly noisy environments may call for wearing more than one kind of protector. Beyond compliance, it just makes sense that a successful program must include the support and involvement of supervisors and top management. They should be especially aware of the reasons for the program, why hearing is so important to preserve, and what happens to the noise-exposed ear when it is unprotected. 

They should also wear hearing protection themselves in posted areas -- not just to set a good example, but to protect their own precious hearing. 

Invisible and insidious
Noise, like other occupational health hazards, is insidious. Those with noise-induced hearing loss may not even become aware of the problem until it has reached serious levels, and by that time the loss can be permanent.

Noise is also an invisible risk. Unlike a solvent or a sharp object, the risk cannot be seen, which leads some employers and employees to underestimate its importance. In most cases, noise-related hearing loss occurs gradually, starting with a temporary loss that over time can become permanent.

An overly noisy environment can have serious effects on a worker’s ability to communicate. Experts say that communicating in noise levels above 85 dB is not satisfactory for the speaker or for the listener.

Noise can also mask acoustic warning signals and the sounds of properly functioning equipment. And it can negatively affect job performance. While routine tasks are not usually affected, complex tasks are, especially as the noise gets louder.

Intermittent, unpredictable noise is especially detrimental to optimal functioning. Some studies have shown that even fairly moderate levels of noise can raise anxiety and increase the risk of antisocial behavior.

Although the research is somewhat controversial, there is some evidence of a link between noise exposure and stress diseases such as cardiovascular disorders and ulcers. There’s also plenty of anecdotal evidence that workers are less fatigued, less irritable and sleep better when they’re part of a hearing conservation program. As well, they appear to have fewer accidents and absences.

Train and motivate!
It’s important that hearing conservation training – whether it’s group or individual – instruct but also motivate employees to wear their protection when necessary.

Some trainers like to use the metaphor of grass to represent the tiny sensory cells of the inner ear. Usually, blades of grass will straighten up after they’ve been bent by being walked on. However, if one continues to tread on the same patch day after day, the grass will eventually die, leaving a bare spot.

That’s similar to what happens to the ear’s hair cells when assaulted by high-decibel sound. Employees should be told about the symptoms of noise-induced hearing loss, including persistent tinnitus or ringing in the ears, a sensation of muffled hearing after a work shift, difficulty understanding conversation in groups or noisy surroundings, and the sense that people are mumbling.

Training should extend beyond the formal sessions; supervisors should routinely make sure ear plugs are inserted correctly; check ear muffs, head bands and cushions; and ask employees about their use and comfort.

A simple yet valuable technique for motivating employees is to explain their audiometric test results to them, perhaps comparing a current audiogram to a previous test, and comparing it with a normal result. If threshold levels are deteriorating, it’s time to remind the worker about fitting and wearing hearing protection.

Supervisors should be sensitive to unusual situations. For example, some workers may be fearful that wearing the protector could make them unable to hear a malfunctioning machine, or could compromise their ability to communicate. There are, however, special types of hearing protectors that are especially designed to facilitate communication and thus might be an appropriate solution. Some employers have found that workers comply better with hearing protection rules when their families are involved. Businesses may choose to provide audiometric tests for spouses and children. This gets people talking about hearing protection on and off the job. 

Permit-required confined spaces (29CFR 1910.146)
There’s nothing new about confined spaces or their hazards. In Roman times, the Emperor Trajan sentenced criminals to clean sewers, an occupation known to be particularly dangerous.

OSHA defines a confined space as one whose size and shape allows an employee to enter and perform assigned work but is not designed to be occupied continuously and has limited or restricted means for getting in and out. Examples include tanks, storage bins, vessels, silos, hoppers, vaults and pits.

Confined spaces can be awkward and uncomfortable to work in. What’s more, hazards are generally even more severe when they exist in confined spaces. That’s why OSHA requires special precautions and even permits for a great many confined-space tasks.

OSHA defines a permit-required confined space as one that has one or more of the following.

1. A hazardous atmosphere that could cause a person to become ill, incapacitated, unable to escape without aid or even to die. The atmosphere may be hazardous due to:
• flammable gas, vapor, or mist levels more than 10 percent above the substance’s lower flammable limit;
• airborne combustible dust at or above that limit (OSHA notes that “this concentration may be approximated as a condition that obscures vision at a distance of 5 feet);
• an oxygen concentration below 19.5 percent or above 23.5 percent;
• a concentration of any substance for which a dose or a permissible exposure limit (PEL) in Subpart G or Z of Part 1910 and that could result in employee exposure in excess of such dose or PEL; or,
• any other atmospheric condition immediately dangerous to life or health. 

2. An engulfment potential that could lead to a worker being immersed and buried or smothered by a liquid or a flowing solid, like sand or grain.

3. A potentially entrapping design such as walls that converge inward or a floor that slopes and tapers down. 

4. Any other recognized serious health or safety hazard – such as falls or excessive heat or noise. 

Employer requirements
OSHA’s permit-required confined space regulation requires employers to develop and follow a written confined space entry program, which “shall be available for inspection by employees and their authorized representatives.”

The program provides for determining and stating the conditions that will allow safe space entry and verifying that those conditions will be maintained while anyone works in the space. Such work will thus be allowed only when the space meets listed criteria and after obtaining a permit that lists specific information about the space and entry.

It is also the employer’s responsibility to:
• train employees to safely perform confined space tasks;
• develop safety procedures, including rescue plans and personnel;
• identify and test the atmosphere in a confined space that is to be entered;
• retest the atmosphere in the space before workers enter it -- with the authorized entrant and an authorized representative allowed to observe
• flush, ventilate, or otherwise eliminate or control atmospheric hazards before allowing workers in the space;
• keep unauthorized employees out of such spaces by the posting of signs or other warnings, the use of barricades or other appropriate means. 

Roles and responsibilities
To help assure worker safety in permit-required confined spaces, OSHA also described several key employee roles. Authorized entrants may enter only after the air is tested and found safe. Once in the space, these workers must be vigilant for any change in conditions. They must be familiar with the potential hazards listed on the permit and the signs and symptoms of lack of oxygen and other risks.

Authorized entrants must know what equipment to use and how to use it. That includes personal protective gear, tools needed for the task, equipment for communicating with the attendant, and some kind of personal retrieval system.

According to OSHA, each authorized entrant has to use a chest or full body harness attached to a retrieval line. A wristlet system may be used only if the employer can demonstrate that other systems are impractical or dangerous. 

Also, despite the protections in place, work inside the space should be completed as efficiently and quickly as possible. Workers should be instructed to leave the space immediately if they suspect trouble, or if the attendant gives an order or sounds an alarm.

Attendants must remain on duty outside an occupied permit-required confined space. They must study the permit to understand the potential hazards of the space and the signs and symptoms of trouble. 

An attendant must:
• monitor and count who’s in and who’s outside the space;
• stay in touch with authorized entrant(s) working inside;
• keep unauthorized people away from an occupied space
• order immediate evacuation if the entrant shows signs of hazardous exposure, if the attendant can’t perform duties safely, or if a situation outside the space could endanger workers within;
• summon rescue and emergency services when needed to evacuate workers.

Entry supervisors oversee the operation. They make sure testing and other permit requirements are met and sign the permit so workers can enter. The entry supervisor also must be familiar with the hazards in the space, assure the availability of rescue and emergency services, and stop work in the space and cancel the permit when the task is completed or when conditions develop that make the work unsafe.

Rescue and emergency service personnel may work for the employer, or for an outside service. But it’s always the job of the employer with the permit-required confined space to be sure rescuers are ready, willing, and able to handle their duties. 

Reminders for employees
Doing your part as an employer is just one component in a program to keep workers safe during confined space work. It’s equally important that employees do their part, including participating in training and applying what they’ve learned.

Encourage your workers to understand and observe these basic safety precautions that can help keep them safe. 

Employees should:
• plan tasks and assemble equipment so work in the confined space can be performed quickly;
• be sure any steam, water, heat or power lines going into the space are cut off and locked and tagged;
• not enter the space if they feel unwell or have been using alcohol or any drugs
• pay close attention to how they feel while in the space;
• leave immediately if they have trouble breathing, feel tired, dizzy, nauseated, etc.;
• avoid taking food, drinks or cigarettes into the space;
• make sure the space is adequately ventilated. 

Vigilance and vigor
Hearing conservation and permit-required confined space programs don’t have a great deal in common in terms of the hazards they address. But compliance with each of these bedrock OSHA standards requires a great deal of vigilance and vigor -- by employers and employees.

Although hearing loss is not a “life and death” matter like asphyxiation in a confined space, adherence with both sets of OSHA requirements can have a dramatic impact on the life and health of your greatest business asset: your workforce.

TrainingOnline is a full-service learning content provider that specializes in Web-based training courses for the environmental, health, safety and human resources markets. Read more about safety training at www.trainingonline.com.

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