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An Explanation of Recording Hearing Loss on the OSHA 300 Log

By: George Cook, Au.D., CCC-A

In January 2001, OSHA published rules on recording and reporting occupational injuries and illnesses and made the effective date January 1, 2002. They delayed the recording criteria for cases involving occupational hearing loss and musculoskeletal disorders until January 1, 2003, and asked for comments. On July 1, 2002, OSHA published the finalized criteria for recording hearing loss. As of January 1, 2003, hearing tests meeting the following finalized criteria of change were required to be logged on the OSHA 300 form. All states are required to use identical recording criteria (66 FR 52033).

1904.10 Recording criteria for cases involving occupational hearing loss.

(a) Basic requirement. If an employee’s hearing test (audiogram) reveals that the employee has experienced a work-related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee’s total hearing level is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS, you must record the case on the OSHA 300 Log.

RE: Federal Register/Vol. 67, 126/ Monday, July 1, 2002/Rules and Regulations pg 4407

The following is a step by step approach in considering if an employee meets the recording criteria and when a previous entry may be erased or lined-out.

Step 1

Does the employee have an STS with aging?

A Standard Threshold Shift (STS) occurs when the current audiogram is compared to the baseline or revised baseline and a change of 10 dB average occurs at the frequencies of 2000, 3000 and 4000 Hz, and allowance has been made for aging from the presbycusis charts provided in the appendices of 1910.95 noise standard. Aging may be used in determining if an STS has occurred (76 FR 44043).

For example lets consider the following hearing tests on a male worker exposed at or above the Action Level of 85 dBA TWA.

Age Type Test Date 2000 3000 4000 Hz
30 Baseline 8/20/95 05 05 10
37 Retest 8/10/02 20 20 25
Change 15 + 15 + 15 = 45 –8 (aging) = 37/3= 12.3avg.

The new criteria use the baseline and revised baseline as identified in 1910.95 (76 FR 44044). This worker has an STS as defined in the 1910.95 noise standard. All the STS follow-up required by the standard is to be done. Logging criteria does not have any effect on the STS identification or follow-up required in the Noise Standard 1910.95. The employee is to be notified in writing within 21 days, hearing protection is to be fitted or refitted, recalculated for attenuation, and the wearing is to be enforced.

Step 2

Does the current hearing test exceed normal hearing?

The hearing loss on the current hearing test must exceed the low fence criteria of 25 dB average or when the total of the thresholds at 2000, 3000 and 4000 Hz are greater than 75 (A 75 total change is the same as an average of 25 when dividing by 3). Remember, there is no allowing for age correction when determining if the retest meets the 25 dB average criteria (76 FR 44043).

Age Type Test Date 2000 3000 4000 Hz
37 Retest 8/10/02 20 20 25
Total = 65
65/3 = 21.67 avg

In the above example the STS is not a possible recordable because the worker does not have a 25-dB average loss from audiometric zero. The reason for using the 25-db average is to assure that the total hearing level is beyond the normal hearing range (76 FR 44044).

OSHA feels this is consistent with the recent, January 1, 2002, record keeping rulemaking "final rule no longer requires recording of minor or insignificant health conditions that do not result in one or more of the general recording criteria such as medical treatment, restricted work, or days away form work (76 FR 44038).

Let’s change the thresholds,

Age Type Test Date 2000 3000 4000 Hz
37 Retest 8/10/02 25 25 25
Total = 75
75/3 = 25 avg

Now the worker does have a possible recordable STS because hearing thresholds on the current test total 75 or average 25.

Step 3

Does retesting confirm the STS?

A 30-calendar day retest is allowed if a qualifying STS occurs. Temporary hearing loss is addressed by the use of the 30-day retest. (76 FR 44043) OSHA does not allow a longer than 30-day retest period (76 FR 44043).

The logging does not need to occur until after the 30-day retest. If a possible recordable has occurred, you do not have to record if you are going to perform a retest. If the retest confirms the recordable you have seven (7) calendar days from the test to record. (76 FR 44048) It is assumed that if the retest were planned but missed for some rational reason, the employer would have seven days from the 30-day allowed retest period.

Also, see Step 5. Is the loss persistent?

Step 4

Is the hearing loss work-related?

The guidance of a physician or other licensed health care professional is to be used when determining work-relatedness. If the professional "determines that the hearing loss is not work-related or has not been significantly aggravated by occupational noise exposure, the employer is not required to consider the case work-related and therefore is not required to record it" (76 FR 44045).

Work-relatedness is to be determined on a case-by-case basis. The overall approach is that "a case is work-related if one or more events or exposures in the work environment either causes or contributed to the hearing loss, or significantly aggravated a pre-existing hearing loss" (76 FR 44045).

‘Other licensed health care professional’ is defined in 1904.10 Subpart G – Definitions, as "an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently perform, or be delegated the responsibility to perform, the activities described by this regulation." Occupational Audiologist qualify for determining job relatedness for purposes of recording hearing loss on the OSHA 300 Log.

There is no presumption of work-relatedness for workers exposed to 85 dBA TWA, Action Level (76 FR 44045). Workers above the Action Level may experience a non-work-related loss even though "it is likely that occupational exposure to noise in excess of 85 dBA will be a casual factor in hearing loss in some cases…work-relatedness is not justified in all cases" (76 FR 44045).

Considerations in determining work-relatedness:
—Prior occupational and non-occupational noise exposure.
—Evaluation of calibration records and test environment.
—Investigation of related activities.
—Personal medical conditions.
—Age correction.
—Effectiveness of hearing conservation program,
—Wearing of hearing protection.
—Inadequate attenuating hearing protection.
—Ill-fitting and improper insertion of hearing protection.
—Consistent or inconsistent use of hearing protection.
(76 FR 44045)

Workers below the Action Level may experience a work-related loss (76 FR 44045).

Where it is true that noise exposure below the Action Level of 85 dBA TWA has a small percentage of workers at risk, it is important to note that in my experience the occurrence of work-related hearing loss without noise is rare in most industries. A ruptured eardrum due to trauma or diving, sparks in the ear, etc., would already be recordable as an injury. Exposure to heavy metals and organic solvents as toluene, xylene, styrene, trichlorethylene, etc. may produce hearing loss without noise. However, their occurrence without noise is rare. Hearing testing on some routine basis (3yrs, 5yrs or 7 yrs) of non-noise exposed workers is strongly encouraged. The benefit of a continuing, successful hearing conservation program is to maintain a healthy workforce by detecting and preventing hearing loss in all workers.

Step 5

Is the loss persistent?

If in the course of routine testing required by the Noise Standard, the STS no longer appears, it may be lined out. If the audiometric testing indicates that an STS is not persistent, the entry may be erased or lined-out (76 FR 44043). "If subsequent audiometric testing performed under the testing requirements of the 1910.95 noise standard indicates that an STS is not persistent, you may erase or line-out the recorded entry."

The employer does not have to maintain documentation concerning the removal. OSHA feels the documentation is in the hearing test records the company is already required to keep for the Noise Standard - 1910.95 (76 FR 44044). Accountability is in the audiometric record keeping.

Also, The removal is not at the discretion of the reviewing professional. OSHA considers the program to be reviewed by a reviewing professional and did not want to repeat the requirement (76 FR 44044).

Additional Notes:

In recording hearing loss the requirement to check the hearing loss column on the Log for hearing loss cases has been delayed. OSHA is asking for comments concerning the need for a separate hearing loss column.

Construction, agriculture, oil and gas drilling and servicing, and shipbuilding industries are not covered under 1910.95 and are not required to do hearing testing. If they do testing they would be required to log according to 1904.10 like other industries.

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