OSHA Issues a Regional Emphasis Program Regarding Noise Exposure
As of June 1, 2021, the Occupational Safety and Health Administration (OSHA) implemented a Regional Emphasis Program (REP) for Region V (Minnesota, Wisconsin, Illinois, Indiana, Michigan, and Ohio) for scheduling and conducting inspections of specific manufacturing industries with hearing loss rates that are higher than the national average (OSHA, 2021). While the national average rate for hearing loss was 1.4 per 10,000 full-time workers, the rate for hearing loss among all private manufacturing was 8.6 cases per 10,000 full-time workers (BLS, 2019). According to OSHA’s Regional Instruction directive, OSHA in Region V plans to perform outreach and enforcement activities “to encourage employers to take steps to identify, reduce, and eliminate hazards associated with exposure to high levels of noise” (OSHA, 2021: p. 3).
Industries that are designated under certain North American Industry Classification System (NAICS) codes that are impacted by the REP are listed in the directive. (OSHA, 2021: p. 5-6). According to the REP, employers that have complaints and referrals will undergo inspection, as well as selected employers according to a master list of establishment designated by the NAICS code (OSHA, 2021). As part of the REP, a Compliance Safety and Health Officer (CSHO) will conduct a walk-around inspection and “obtain sound level meter readings to identify noise levels” that exceed the OSHA Action Level (AL) of 85 decibels (OSHA, 2021: p. 9). As stated in OSHA’s Regional Instruction directive, if the CSHO identifies any “potential for noise overexposures” the CSHO will conduct full-shift noise monitoring (OSHA, 2021: p. 9).
Although not specified in the REP, discerning whether continuous or impulse noise is present to representatively capture worker exposure is important. Certain processes generate continuous noise, which OSHA defines as noise with variations in the noise level involving maxima at intervals of one second or less (OSHA, 2008). Examples of continuous noise include an idling diesel engine or an air compressor in constant use. Other processes generate impulse noise, or a near-instantaneous increase in sound pressure level. Examples of impulse noise include a drop forge, stamping, or gunfire. According to Occupational Noise Exposure Standard 1910.95(d), continuous, intermittent, and impulsive sound levels from 80 decibels to 130 decibels must be captured in noise measurements during occupational monitoring for the Action Level measurement, regarding hearing conservation provisions (OSHA, 2008). However, the threshold level of 90 dBA is used for noise measurements to comply with the Permissible Exposure Limit (PEL) (OSHA, 2021). Factors such as worker mobility, sound level variation, or significance of impulse noise must be considered in order to determine the most effective monitoring method (OSHA, 2008). All parties, including compliance officers, contractors, or health and safety staff should assess both impulse and continuous noise during work periods in order to accurately capture representative exposures to sound pressure levels.
The REP dictates that the enforcement actions OSHA Region V plans on implementing include inspecting and reviewing operations and working conditions, injury and illness records, and health and safety programs (OSHA, 2021). While the REP focuses on noise hazards, it can also be used to evaluate overall workplace health and safety, and OSHA will continue to evaluate any other visible hazards. In addition to having a noise exposure and risk management strategy in place, employers in Region V, designated under NAICS codes listed in OSHA’s Regional Instruction Directive, should be aware of OSHA’s REP requirements, and consider proactively preparing for potential inspections.
Cardno ChemRisk is experienced with developing, undertaking, and assisting with exposure and risk assessments for environmental and occupational noise. Additionally, Cardno ChemRisk has experience consulting for occupational and environmental noise assessments for several clients among various industries.