Environmental Health & Safety
Hearing Protection Program
Revised 4/30/2017
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The Occupational Safety Unit (OSU) of Environmental Health and Safety
EH&S OSU is responsible for:
- Maintaining the University's written plan;
- Identifying high noise areas;
- Maintaining a list of high noise areas;
- Performing environmental sound pressure level measurements in areas of potentially excessive noise exposure, or whenever there is a change in process, equipment, or production that may affect an individual's exposure to noise;
- Evaluating noise measurements and identifying exposures at or above the Permissible Exposure Limit (PEL) of 90 dBA (TWA8);
- Monitoring employee exposures by dosimetry in areas where noise levels may exceed the 85 dBA (TWA8) action level, or in cases where an employee has developed a standard threshold shift that may be work-related;
- Recommending feasible engineering controls;
- Performing noise exposure computations (29 CFR 1910.95 Appendix A);
- Estimating adequacy of hearing protectors (29 CFR 1910.95 Appendix B);
- Reporting findings to employees, appropriate department supervisors and UHS;
- Providing program oversight and making recommendations; and,
- Maintaining necessary records.
University Health Service (UHS)
UHS provides audiometric testing for University employees who work in high noise areas and are required to have their hearing tested to obtain a baseline audiogram before beginning work, and annually thereafter, until they leave the University. Anyone exhibiting an STS suspected to be a work-related hearing loss will be referred for a follow-up with an audiologist. UHS will notify EH&S of any work-related Standard Threshold Shifts (STS) identified during their examinations.
UHS trains employees and fits them with hearing protection devices at the time of their initial and annual hearing tests. UHS will work with employees to determine what device offers the best protection.
The training includes the explanation of reasons for using hearing protection, the proper use of hearing protectors, how to care for hearing protectors, requirements of the University's Hearing Conservation Program, and an introduction to audiometric testing.
UHS also:
- Verifies employees have completed Annual Hearing Conservation training.
- Administers a continuing and effective hearing conservation program that includes audiometric testing for all employees whose exposure equals or exceeds the 85 dBA (TWA8) action level;
- Conducts baseline and annual audiograms, evaluates the audiograms for Standard Threshold Shifts, conducts retesting when necessary and provides evaluations to the employee;
- Notifies University Human Resources of Standard Threshold Shifts for recording on the OSHA 300 Log.
- Refers employees who have been identified as exhibiting an STS to an audiologist for follow-up evaluation. The audiologist notifies UHS and EH&S of the results.
- Notifying EH&S of employees exhibiting an STS for follow-up;
- Provides medical follow-up of exposure testing results when an STS has occurred and makes provisions for retesting and revising baseline audiograms where necessary;
- Provides general training and fit testing in the use of hearing protectors;
- Retrains employees in the use of hearing protection and refits them for hearing protection devices if an STS has occurred;
- Maintains an audiometric testing system that complies with the noise standard, meets with the calibration requirements of the National Standard Specification Audiometers S3.6-1969, and with the requirements described in Appendices C, D and E of the standard; and,
- Maintains necessary records.
University Human Resources/Business Partners
- Business Partners are responsible for determining the training needs for employees, and ensuring that the required training is made available to those employees.
- University HR is responsible for maintaining the OSHA 300 Log of occupational injuries/illnesses.
University Administration, Directors, and Principal Investigators
Provide administrative and financial support and direction for the University's Hearing Protection Program throughout the University and within individual departments (U of R Faculty Handbook, III.M.).
Individual departments must provide personal protective equipment (PPE), in the form of hearing protectors, to any employees who work in a confirmed or suspected high noise area or who use equipment or perform tasks that may generate hazardous noise levels. U of R Faculty Handbook, III.M. and U of R Personnel Policy 158).
Supervisors and managers are responsible for:
- Making themselves familiar with the University's Hearing Conservation Program, and ensuring that employees comply with the requirements of this plan;
- Notifying EH&S of any high-noise areas, equipment, or activities that might expose their employees to excessive noise;
- Ensuring that all of their facilities have been surveyed and that all high noise areas, equipment, or work activities have been identified;
- Helping to identify employees who have the potential for exposure to sound levels that exceed the OSHA Permissible Exposure Limit (PEL);
- Ensuring that employees go to UHS for the initial and annual hearing tests, and keep any follow-up appointments;
- Enrolling eligible employees in the hearing surveillance program with University Health Service (UHS);
- Ensuring that employees identified as exhibiting an STS follow up with the audiologist within 30 days of the initial determination.
- Training employees on safe working practices;
- Ensuring, with possible assistance from EH&S, that any feasible noise attenuation measures (engineering controls) are implemented;
- Ensuring that noise exposure is reduced by means of administrative measures;
- Ensuring their employees complete Annual Hearing Conservation training.
- Ensuring that employees are trained and properly fitted for the use of hearing protectors;
- Ensuring that hearing protectors are properly used by the employees whenever required;
- Providing a clean area where hearing protectors can be stored; and,
- Maintaining necessary records.
In accordance with University Personnel Policy 158, employees who are covered under this Program are responsible for:
- Complying with the University of Rochester's Statement of Safety Policy (Appendix 1) and with the Hearing Protection Program;
- Completing Annual Hearing Conservation Training;
- Carrying out their duties in a manner so as to promote safe work practices;
- Consistently and correctly using the provided hearing protectors in accordance with training and Standard Operating Procedures (SOPs) whenever entering high-noise areas or performing work that could expose them to excessive noise;
- Ensuring that their hearing protectors are in good condition;
- Informing their supervisors when they need replacement hearing protectors;
- Communicating with their supervisor(s) with regard to any problems in the work process or new hazards that may compromise the effectiveness of the hearing conservation practices;
- Keeping all medical surveillance and audiogram appointments at UHS; and
- Making and attending follow-up appointment(s) with the audiologist within 30 days when an STS has been identified during the annual audiogram at UHS.
Audiometry and Threshold Shift Assessment Process
- Employee's supervisor/department shall notify UHS of any employee who is potentially exposed to high noise levels so that the employee(s) can be enrolled in the University's Hearing Conservation Program and baseline and annual audiograms can be obtained.
- The employee completes annual Hearing Conservation Program training on MyPath as part of the annual health update process; this shall be done prior to his/her UHS appointment.
- UHS conducts annual audiograms for employee in Hearing Conservation Program as part
of annual health update. When going to the UHS appointment, the employee must
take along documentation that he/she has completed the required training.
If employee has not completed HCP training, the audiogram will still be conducted and the employee's supervisor is notified. - If a possible STS is detected, UHS notifies the employee, EH&S, HR, and Audiologist. UHS generates a referral letter, which is sent to the employee, the employee's supervisor, the Audiologist, EHS, and HR. EHS is notified by real-time email so investigation can begin immediately.
- HR records the STS on the OSHA log
- EHS sends an e-mail to the employee's supervisor requesting the supervisor ensure that:
- the employee makes and keeps the Audiology appointment within 30 days of initial STS determination;
- the employee is provided with hearing protection equipment and training for its use if he/she will be working under high-noise conditions;
- that the employee be monitored to ensure he/she is consistently and properly using hearing protection;
- that feasible measures to reduce noise exposure are implemented.
- The Audiologist conducts a follow-up examination of the employee to determine whether he/she has a standard threshold shift caused by noise exposure and whether it is work-related. As part of the follow-up appointment, the Audiologist also assesses the employee's ability to properly insert/don hearing protection equipment, and provides instruction to correct any deficiencies.
- The Audiologist notifies EHS and HR of the results.
- If the STS is work-related, EHS notifies the employee's supervisor that the incident is work-related, and that an Incident Report must be filed. EHS conducts additional investigation, which may include noise dosimetry.
- If the STS is not work-related, HR removes the incident from the OSHA log.
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This page last updated 4/17/2018. Disclaimer.
