Hearing Conservation Program Template
1.0 Purpose
The primary purpose of the hearing conservation program is to prevent occupational noiseinduced hearing loss for employees. A secondary purpose of the program is to provide
guidance to comply with state and federal standards. When completed, this program
template will serve as the written hearing conservation program for the employing unit. Upon
completion of this template, a copy of the completed plan shall be forwarded to the
Add the title of the document to this text box. The document title will include the name of the document and the
Environmental & Occupational Health Program, 333 East Campus Mall.
type of document.
2.0 Scope
The Occupational Safety and Health Administration (OSHA) Occupational Noise Exposure
Standard 1910.95 has established an action level of 85 decibels, A-scale (dBA) for an 8-hour
time-weighted average (TWA) occupational noise exposure. The action level is equivalent as
a "dose" of exposure level of 50 percent of the permissible exposure limit of 90 dBA as an 8hour TWA.
The Standard requires an effective hearing conservation program when noise levels exceed
85 dBA. At a minimum, the program shall include the following elements:




Noise monitoring
Audiometric testing
Hearing protection
Education and training
The hearing conservation program applies to employees exposed to an 8-hour time-weighted
average noise level greater than 85 dBA.
3.0 Related Documents
 Occupational Safety and Health Administration Standard 1910.95, “Occupational
Noise Exposure”
 Wisconsin Department of Safety and Professional Services, Chapter 332, “Public
Employee Safety and Health”
4.0 Definitions
 Action Level
Employee exposure to noise levels, without regard to any attenuation provided by the
use of personal protective equipment, which exceeds 85 dBA or 50 percent of the
permissible exposure limit.
 Decibel (dB/dBA)
Unit of sound measurement. dBA is a measurement using the A-weighted scale
which approximates how humans hear sound.
Page 1 of 24





Hertz (Hz)
Measurement of frequency also expressed as number of cycles per second.
Occupational Safety and Health Administration (OSHA)
Federal enforcement agency within the Department of Labor charged with protecting
employees’ occupational health and safety.
Permissible Exposure Limit (PEL)
A legal limit for an employee exposure to a chemical or physical agent, such as noise.
Standard Threshold Shift (STS)
A change in hearing threshold of an average of 10 dB or more at 2,000, 3,000 or
4,000 Hz in either ear measured against the baseline audiogram.
Time-weighted Average (TWA)
The average exposure to a chemical or physical agent to which employees may be
exposed without adverse effect over a period, such as an 8-hour day or 40-hour
week.
5.0 Roles and Responsibilities
5.1 Administration
The administration of the program is the responsibility of each employing unit with
assistance from the EOH Department.
Administrative responsibilities include the following:







Coordinating and supervising noise exposure monitoring.
Coordinating and supervising the audiometric testing program.
Assisting with hearing protector selection.
Developing policies relating to the use of hearing protection.
Coordinating and supervising required recordkeeping.
Evaluating the overall program periodically.
Coordinating required changes and improvements in the program.
5.2 Supervisors
Supervisor responsibilities include the following:





Identifying areas, work tasks and employees to be included in the hearing
conservation program.
Providing the resources for the program to be implemented, including availability for
audiometric testing and hearing protection.
Coordinating and assisting with employee training programs.
Maintaining documentation of noise exposures, training, audiometric testing and
hearing protection use.
Evaluating program implementation on an annual basis.
6.0 Policy
6.1 Noise Measurements and Monitoring
The University has implemented a monitoring program to determine whether an
employee's exposure may equal or exceed the action level of 85 dBA as an 8-hour timeweighted average.
The EOH Department can assist with identifying employees for inclusion in the hearing
conservation program by monitoring and consultation. Measurements can be used to
Page 2 of 24
enable the proper selection of hearing protection and to determine feasible engineering or
administrative exposure control measures.
Monitoring may be repeated whenever a change in production, process, equipment or
controls increases noise exposures to the extent that additional employees may be
exposed at or above the action level or the attenuation provided by hearing protection
being used by employees is not adequate to meet requirements.
The employee’s Supervisor will notify an employee exposed at or above an 8-hour TWA
exposure of 85 dBA of the monitoring results.
The EOH Department will provide affected employees, or their representatives, with an
opportunity to observe any noise measurements conducted.
Monitoring will be coordinated by a campus industrial hygienist with assistance from EOH
staff and the affected department or office.
The results of the noise exposure measurements will be reported to affected employees,
safety coordinator/supervisor and other identified department representatives.
6.2 Audiometric Testing
The University will make audiometric testing available to employees whose exposure
equals or exceeds an 8-hour time-weighted average of 85 dBA at no cost to the
employee.
Audiometric tests shall be performed by a licensed or certified audiologist,
otolaryngologist, or other physician, or by a technician who is certified by the Council of
Accreditation in Occupational Hearing Conservation. A technician who operates
microprocessor audiometers does not need to be certified. A technician who performs
audiometric tests must be responsible to an audiologist, otolaryngologist or physician.
Audiometric tests will be performed by the Department of Communicative Disorders at
Good Night Hall. Appointments are coordinate through University Health Services
Occupational Medicine at 265-5610. Other audiology vendors may be used, however,
shall provide audiometric testing report to UHS Occupational Medicine. In all cases,
audiology vendors must follow test requirements specified in the OSHA standard.
Audiometric testing will be preceded by at least 14 hours without exposure to workplace
noise. Hearing protectors may be used as a substitute for the requirement that baseline
audiograms be preceded by 14 hours without exposure to workplace noise.
The Supervisor will notify employees of the need to avoid high levels of non-occupational
noise exposure during the 14-hour period immediately preceding the audiometric
examination
6.3 Baseline audiogram
Within 6 months of an employee's first exposure at or above the action level, the
University will establish a valid baseline audiogram to compare against subsequent
audiograms.
6.4 Annual audiogram
Page 3 of 24
Audiograms will be completed at least annually after obtaining the baseline audiogram for
employees exposed at, or above, an 8-hour time-weighted average of 85 dBA.
The EOH Department, Occupational Health Officer will maintain a record of employee
audiometric test records. This record will include the following:





Name and job classification of the employee.
Date of the audiogram.
The examiner's name.
Date of the last acoustic or exhaustive calibration of the audiometer.
Employee's most recent noise exposure assessment.
6.5 Audiometric Evaluation
Each employee's annual audiogram will be compared to their baseline audiogram by a
qualified evaluator to determine if a Standard Threshold Shift (STS) has occurred.
In determining if a STS has occurred, an allowance can be made for the contribution of
aging (presbycusis).
The audiologist, otolaryngologist, or physician will review audiograms and determine
whether there is a need for further evaluation. The University will provide the following
information to the person performing this evaluation:



A copy of the requirements for hearing conservation as set forth in the standard.
The baseline audiogram and most recent audiogram of the employee to be
evaluated.
Any noise exposure measurements pertaining to the employee’s work tasks.
The person conducting the audiograms may be required to provide the following
documentation to the University:


Measurements of background sound pressure levels in the audiometric test room.
Records of audiometer calibrations.
If the annual audiogram shows that an employee has suffered a STS, the University may
obtain a retest within 30 days and consider the results of the retest as the annual
audiogram.
Unless a physician determines that the STS is not work-related or aggravated by
occupational noise exposure, the University will follow these steps when a standard
threshold shift occurs:


Page 4 of 24
Employees not using hearing protection will be trained, fitted, and required to use
hearing protection if they are exposed to an 8-hour TWA of 85 dBA or greater.
Employees already using hearing protection will be retrained, refitted, and required
to use hearing protectors and provided with hearing protectors offering greater
attenuation if necessary.


The audiology clinic will inform the employee in writing within 21 days of this
determination of the existence of a permanent STS (Form 2, Appendix A). A copy
of the STS letter will also be sent to the employee's Supervisor.
The audiology clinic will counsel the employee on the importance of using hearing
protection and refer the employee for further clinical evaluation if necessary.
Persistent significant threshold shifts must be entered on the OSHA 300 Log if determined
to be work-related.
6.6 Protective Equipment
The Supervisor will ensure that hearing protection is worn by the following employees:



those subjected to sound levels equal to, or exceeding, an 8-hour TWA of 90 dB;
those who have experienced a persistent STS and are exposed to an 8-hour TWA
of 85 dBA or greater;
Any employee who has not had an initial baseline audiogram and who is exposed
to an 8-hour TWA of 85 dBA or greater.
Hearing protection will be available for any employees exposed to noise levels greater
than 85 dBA.
Various types of appropriate protectors are available for use. Employees will be given the
opportunity to select their hearing protection from a variety of suitable hearing protectors
at no cost to them.
The Supervisor will provide or assure the employee receives training in the use and care
of hearing protection and will ensure proper initial fitting and supervise the correct use of
hearing protection.
Employees will be held accountable for not properly using and maintaining the equipment
furnished.
The EOH department will evaluate the attenuation characteristics of the hearing protectors
to ensure that a given protector will reduce the individual's exposure to levels within the
PEL.



If the 8-hour TWA is over 90 dBA, the protector must attenuate the exposure to at
least an 8-hour TWA of 90 dBA or below.
If the protector is being worn because the employee experienced a STS, then the
protector must attenuate the exposure to an 8-hour TWA of 85 dBA or below.
If employee noise exposures increase to the extent that the hearing protectors
provided may no longer provide adequate attenuation, the employee will be
provided more effective hearing protectors.
6.7 Employee Training
An annual training program for each employee included in the hearing conservation
program will be conducted by the Supervisor or EOH Department and will include
information on the following:
Page 5 of 24





The effects of noise on hearing.
The purpose and use of hearing protectors.
The advantages, disadvantages, and attenuation of various types of protection.
Instruction in the selection, fitting, use and care of protectors.
The purpose of audiometric testing and an explanation of the test procedures.
Training dates and the employees in attendance will be documented on Form 4, Appendix
A.
Information provided in the training program will be updated to be consistent with changes
in protective equipment and work processes.
6.8 Recordkeeping
Employee data relating to noise exposure measurements, audiometric testing and
personal protective equipment used must be kept for the duration of the affected
employees employment plus 30 years. The records must be kept in a confidential, secure
manner.
The following information should be forwarded to the Occupational Health Program:




Noise exposure monitoring results.
Audiometric test information, not including private, confidential medical
information.
Training information.
Hearing protection information.
Records required by this section will be provided upon request to employees, former
employees, and representatives designated by the individual employee.
Hearing Conservation
Program Element
Noise Measurements
and Exposure
Monitoring
Audiometric Testing
Page 6 of 24
Element
Includes:
Critical Record Keeping
Information
Record Retention
Period
Sound survey position, task or
personal noise
exposure level
measurements
The date of survey, instruments
used, areas surveyed, noise
hazards identified, employees
affected, employees with
exposure levels exceeding 85
decibels over an eight-hour
period - Form 1.
30 years after the
employee’s
Baseline and
annual
audiograms
Name and job classification of
each affected employee,
30 years after the
employee’s
employee test results, tester’s
termination date
Education and
Hearing
conservation
name, test date, audiometer
calibration date, test room
background sound pressure level
termination date
Names of employees trained,
date, presenter - sign-in, Form 4.
3 years
3 years
Training
concepts
Program Evaluations
– Supervisor and
Environment, Health
& Safety Department
Annual evaluation
of program
implementation,
and the overall
program
Supervisor’s Evaluation - Form 5
and
Engineering or
Administrative
Controls
Technical or
equipment
information,
Results of feasibility surveys,
controls used, start date, noise
reduction achieved. Written
memos, e-mails, documents
No minimum period
Date of initial hearing protector
fitting for each employee, size
and brand of hearing protector
selected, name of person who
assisted with fitting – Form 3.
Length of
employment
EOH Department Program
Evaluation - Form 6.
feasibility survey
Hearing Protection
Selection and
fitting
6.9 Program Evaluation
At least annually, the hearing conservation program will be evaluated by the Supervisor using an
evaluation checklist (Form 5, Appendix A). The overall program will be evaluated periodically by
the EOH Department (Form 6, Appendix B) After evaluation, program changes or revisions
deemed necessary will be made as soon as possible.
This written program may be adapted to fit the particular needs of the facility.
7.0 Document Revision: Each time this document is revised, the revisions will be listed in the
table below.
Revision History
Revision
Number
Page 7 of 24
Revision
Date
Description of Revision
1
4/27/2012
Minor edits and changes in audiology service providers
2
3/26/2013
Eliminated PPE declination
3
11/06/2014 Updated to reflect UHS
Page 8 of 24
Appendix A
Implementation Plan
Noise Exposure Evaluation Record – Form 1
Sample Standard Threshold Shift (STS) Letter – Form 2
Hearing Protection Equipment Summary – Form 3
Hearing Conservation Training Sign-in Record – Form 4
Supervisor Hearing Conservation Program Evaluation – Form 5
Page 9 of 24
Form # 1
Noise Exposure Evaluation Record
Department: ______________________________________________
Date
Page 10 of 24
Location
Process/Operation
Noise Exposure
Levels in Decibels
Form # 2
Sample Standard Threshold Shift (STS) Letter
Date:
Dear __________,
Your most recent audiometric test result was compared to your baseline audiogram. This
comparison indicates that your hearing has deteriorated to the point where your hearing
impairment constitutes a “standard threshold shift.” This is defined by the Occupational Safety
and Health Administration (OSHA) as a relative hearing loss of an average of 10 decibels in
either ear at the frequencies of 2,000, 3,000, and 4,000Hz.
An audiogram cannot define why you have a hearing loss, and there are many possible reasons
for diminished hearing. Please feel free to ask the audiologist any questions you may have.
By taking necessary actions now, your hearing loss can be minimized. Consequently, you must
wear hearing protectors when working in noisy environments to prevent further hearing loss.
Whenever you are in a work environment that would result in noise exposure that equals or
exceeds an 8-hour Time Weighted Average (TWA) of 85 decibels, hearing protection must be
used.
Please call _____________ to arrange an appointment with ____________ for follow-up and
evaluation.
Hearing loss will affect your life. Preserve your hearing.
The Environmental Health and Safety Department will attempt to answer any additional
questions you may have.
Sincerely,
(Clinic or audiometric tester)
cc. Employee’s Supervisor
EOH, Occupational Health Officer
Page 11 of 24
Form # 3
Hearing Protection Equipment Summary
Department: ______________________________________________
Type
Name
(muff/cap/plug)
(Brand and Model)
cc. EOH Department
Page 12 of 24
Noise Reduction
Rating
Form # 4
Hearing Conservation Training Sign-in Record
Department: __________________________________________
Name of Employee
Job Classification
Department
Trainer: _______________________________ Date: ________________
EOH Department
Page 13 of 24
Form 5
Supervisor’s Hearing Conservation Program Evaluation
1.
Noise exposure level monitoring has been completed in all areas and rechecked
as necessary after any alterations which may have resulted in a change in noise
levels.
Yes ___
No ___
If no, what action will be taken to complete the monitoring?
2.
Baseline audiograms (if required) have been completed on all employees hired
this year.
Yes ___
No ___
If no, what arrangements will be made to complete the audiograms?
3.
Annual audiograms (if required) have been completed on all employees who are
included in the hearing conservation program.
Yes ___
No ___
If no, what arrangements will be made to complete the audiograms?
Page 14 of 24
4.
All employees included in the hearing conservation program have been provided
with hearing protection.
Yes ___
No ___
If no, what action will be taken to provide this protection?
5.
All employees who are required to wear hearing protection are wearing them
correctly.
Yes____
No ____
If no, what action(s) will be taken to enforce this requirement?
6.
All employees included in the Hearing Conservation Program have received initial
and annual training in the use of hearing protection, the effects of noise on
hearing and the purpose of audiometric testing, if applicable.
Yes____
No ____
If no, what will be done to complete this training?
7.
Potential Standard Threshold Shifts (STS) have been evaluated.
Yes____
No ____
If no, what action will be taken to complete evaluations?
Page 15 of 24
8.
Employees with STS’s have been notified in writing and fitted with the proper
hearing protectors.
Yes____
No ____
If no, what action will be taken to notify these employees?
Review Completed by: _____________________________ Date: ______________
Page 16 of 24
Appendix B
EOH Hearing Conservation Program Evaluation Checklist – Form 6
(For use by EOH)
Page 17 of 24
Form 7
EOH Hearing Conservation Program Evaluation Checklist
Training and Education
Failures or deficiencies in hearing conservation programs may be traced to inadequacies in the
training and education for noise-exposed employees and those who conduct elements of the
program.
Yes No
Has training been conducted at least once in the year?
Was the training provided by a qualified instructor?
Was the success of each training program evaluated?
Is the content revised periodically?
Are managers and supervisors directly involved?
Are posters, regulations, handouts, and employee newsletters used as
supplements?
Are personal counseling sessions conducted for employees having problems with
hearing protection devices or experiencing standard threshold shifts?
Supervisor Involvement
Data indicate that employees who refuse to wear hearing protectors or who fail to show up for
hearing tests may work for supervisors who may not be committed to the hearing loss
prevention programs.
Yes
Have supervisors been provided with the knowledge required to supervise the use
and care of hearing protectors by employees in their department?
Do supervisors wear hearing protectors in appropriate areas?
Have supervisors been counseled when employees resist wearing protectors or fail
to show up for hearing tests?
Are disciplinary actions enforced when employees repeatedly refuse to wear hearing
protectors?
Page 18 of 24
No
Noise Measurement
For noise measurements to be useful, they should be related to noise exposure risks or the
prioritization of noise control efforts. In addition, the results need to be communicated to the
appropriate personnel, especially when follow-up actions are required.
Yes
No
Were the essential/critical noise studies performed?
Was the purpose of each noise study clearly stated? Have noise-exposed
employees been notified of their exposures and informed of hearing loss risks?
Are the results routinely transmitted to supervisors and other key individuals?
Are results entered into health/medical records of noise exposed employees?
Are noise measurement results considered when contemplating procurement of new
equipment? Modifying the facility? Relocating employees?
Have there been changes in areas, equipment, or processes that have altered noise
exposure? Have follow-up noise measurements been conducted?
Are appropriate steps taken to include (or exclude) employees in the hearing loss
prevention programs when exposures change significantly?
Engineering and Administrative Controls
Controlling noise by engineering and administrative methods is often the most effective means
of reducing or eliminating the hazard. In some cases engineering controls will remove
requirements for other components of the program, such as audiometric testing and the use of
hearing protectors.
Yes
Have noise control needs been prioritized?
Has the cost-effectiveness of various options been addressed?
Are employees and supervisors informed of plans for noise control measures? Are
they consulted on various approaches?
Will in-house resources or outside consultants perform the work?
Page 19 of 24
No
Have employees and supervisors been counseled on the operation and
maintenance of noise control devices?
Are noise control projects monitored to ensure timely completion?
Has the full potential for administrative controls been evaluated?
Are noisy processes conducted during shifts with fewer employees?
Do employees have quiet lunch or break areas?
Monitoring, Audiometry and Record Keeping
The skills of audiometric technicians, the status of the audiometer, and the quality of
audiometric test records are crucial to hearing loss prevention program success. Useful
information may be determined from the audiometric records as well as from those who actually
administer the tests.
Yes
Has the audiometric technician been adequately trained, certified, and recertified as
necessary?
Do on-the-job observations of the technicians indicate that they perform a thorough
and valid audiometric test, instruct and consult the employee effectively, and keep
appropriate records?
Are records complete?
Are follow-up actions documented?
Are hearing threshold levels reasonably consistent from test to test? If not, are the
reasons for inconsistencies investigated promptly?
Are the annual test results compared to baseline to identify the presence of a
standard threshold shift?
Is the annual incidence of standard threshold shift greater than a few percent? If so,
are problem areas pinpointed and remedial steps taken?
Are audiometric trends (deteriorations) being identified, both in individuals and in
groups of employees?
Page 20 of 24
No
Do records show that appropriate audiometer calibration procedures have been
followed?
Is there documentation showing that the background sound levels in the audiometer
room were low enough to permit valid testing?
Are the results of audiometric tests being communicated to supervisors as well as to
employees?
Has corrective action been taken if the rate of no-shows for audiometric test
appointments is more than about 5%?
Are employees incurring STS notified in writing within at least 21 days?
Referrals
Referrals to outside sources for consultation or treatment are sometimes in order, but they can
be an expensive element of the hearing loss prevention program, and should not be undertaken
unnecessarily.
Yes No
Are referral procedures clearly specified?
Have letters of agreement between the company and consulting physicians or
audiologists been executed?
Have mechanisms been established to ensure that employees needing evaluation or
treatment actually receive the service (i.e., transportation, scheduling, and
reminders)?
Are records properly transmitted to the physician or audiologist, and the
Occupational Health Officer?
If medical treatment is recommended, does the employee understand the condition
requiring treatment, the recommendation, and methods of obtaining such treatment?
Are employees being referred unnecessarily?
Hearing Protection Devices
When noise control measures are infeasible, or until such time as they are installed, hearing
protection devices are the only way to prevent hazardous levels of noise from damaging
Page 21 of 24
hearing. Making sure that hearing protection is worn effectively requires continuous attention on
the part of supervisors and program implementers as well as noise-exposed employees.
Yes
Have hearing protectors been made available to all employees whose daily average
noise exposures are 85 dBA or above?
Are employees given the opportunity to select from a variety of appropriate
protectors?
Are employees fitted carefully with special attention to comfort?
Are employees thoroughly trained, not only initially but at least once a year?
Are the protectors checked regularly for wear or defects, and replaced immediately if
necessary?
If employees use disposable hearing protectors, are replacements readily available?
Do employees understand the appropriate hygiene requirements?
Have any employees developed ear infections or irritations associated with the use
of hearing protectors?
Are there any employees who are unable to wear these devices because of medical
conditions?
Have these conditions been treated promptly and successfully?
Have alternative types of hearing protectors been considered when problems with
current devices are experienced?
Do employees who incur noise-induced hearing loss receive intensive counseling?
Are those who fit and supervise the wearing of hearing protectors competent to deal
with problems that can occur?
Do workers complain that protectors interfere with their ability to do their jobs?
Does the hearing protection interfere with spoken instructions or warning signals?
Are these complaints followed promptly with counseling, noise control, or other
measures?
Are employees encouraged to take their hearing protectors home if they engage in
noisy non-occupational activities?
Are new types of potentially more effective protectors considered as they become
Page 22 of 24
No
available?
Is the effectiveness of the hearing protector program evaluated regularly?
Is each hearing protector user required to demonstrate that he or she understands
how to use and care for the protector?
Are the results documented?
Administrative
Keeping organized and current on administrative matters will help the program run smoothly.
Yes
Have there been any changes in federal or state regulations?
Have hearing loss prevention program policies been modified to reflect these
changes
Are copies of UW policies and guidelines regarding the hearing loss prevention
program available in the offices that support the various program elements?
Are those who implement the program elements aware of these policies?
Do they comply?
Are necessary materials and supplies being ordered with a minimum of delay?
Are procurement officers overriding the hearing loss prevention program
implementer’s requests for specific hearing protectors or other hearing loss
prevention equipment?
If so, have corrective steps been taken?
Is the performance of key personnel evaluated periodically?
If such performance is found to be less than acceptable, are steps taken to correct
the situation?
Has the failure to hear warning shouts or alarms been tied to any accidents or
injuries?
If so, have remedial steps been taken?
Page 23 of 24
No
Page 24 of 24