Fairfield (CT) Fire Department Standard Operating Procedure No. SFT 15 S.O.P. TITLE: Hearing Conservation Program ISSUE DATE: March 19, 2005 REVISED DATE: none Page 1 of 5 Authorized by: __________________________ Introduction An effective hearing conservation program can prevent hearing loss, improve employee morale and a general feeling of well-being, and reduce the incidence of stress-related disease. OSHA standard 1910.95 Occupational Noise Standard requires that the employers provide a hearing conservation program for employees who are exposed to dangerous occupational noise levels. NFPA 1500 also requires fire departments to develop hearing conservation programs. Both OSHA and NFPA recognize that hearing protection may not properly integrate with structural firefighter protective clothing or “where the use of such protective equipment would create an additional hazard to the user.” (NFPA 1500, 1999 edition) It is the intent of the Fairfield Fire Department Hearing Conservation Program (FFDHCP) to minimize exposure to dangerous noise levels during emergency response, equipment inspections and maintenance, and station activities. The FFDHCP will use the following industry standard model to manage and abate occupational noise hazards in the workplace: 1. Engineering Controls – eliminate known problems through design 2. Administrative Controls – SOP’s 3. Personal Protective Equipment and Monitoring – provide PPE for uncontrollable situations Noise Monitoring Program On October 20, 2004, an occupational hygienist from CONN-OSHA conducted an onsite evaluation of employee exposure to occupational noise. Five members of the department were equipped with noise dosimeters and were instructed to complete their normal daily activities. Due to the longer shift schedule for firefighters, the Permissible Exposure Limit for noise for firefighters was established at 83.4 decibels over a 10 hour period. An evaluation of the results found that one employee exceeded this permissible exposure limit for noise and three others exceeded the action level for noise as established by CONN-OSHA standard 1910.95. As a result of the evaluation, the Fairfield Fire Department will administer a continuing, effective hearing conservation program for all at risk employees. The firefighters that were tested performed similar duties to all firefighters in the department regardless of unit and station assignment. Noise monitoring has identified the following at risk employee groups and activities: Exposed Employee Group At Risk Noise Producing Activity 1. Fire Suppression Personnel Emergency Response Gas powered equipment operation Operation of pumps and vehicles Checking of apparatus (brakes, pumps) Radio Usage 2. Fire Maintenance Personnel Emergency Response Equipment maintenance activities Apparatus maintenance activities Radio Usage 3. Fire Prevention Personnel Emergency Response Radio Usage Alarm system testing Machinery/fire pump inspections 4. Fire Training Personnel Emergency Response Radio Usage Training activities involving gas powered tools, apparatus and other equipment 5. Administrative personnel Emergency Response Radio Usage Noise monitoring has identified the following hazardous activities: 1. 2. 3. 4. 5. 6. Emergency response with lights and sirens Inspection and operation of power equipment (gasoline engine type) Operating apparatus and pumps Training Activities involving the above Apparatus Maintenance activities with excessive noise generation Emergency Scene activities, power tools, high pressure gas leaks, alarms and radios Due to the known noise hazards identified by CONN-OSHA and many uncontrollable factors, the Fairfield Fire Department considers all suppression, training, prevention and administrative employees at risk. Repeated monitoring will be performed when changes in the work environment increase the levels of noise to which employees may be exposed. This may result from the arrival of new apparatus, tools or systems or the desire to reduce the level of protection required. In the event of repeated monitoring, all affected employees or their representatives will have an opportunity to observe noise monitoring procedures. Audiometric Testing of Personnel Audiometric testing will be performed initially upon hire and annually thereafter in accordance with the OSHA standard 1910.95. This program will be provided at no cost to employees. All testing will meet or exceed OSHA requirements and 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, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining and checking calibration and proper functioning of the audiometers being used. 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. The FFDHCP will utilize the "mobile test van exception.," portion of the standard. The exception states that where mobile test vans are used to meet the audiometric testing obligation, the employer shall obtain a valid baseline audiogram within 1 year of an employee's first exposure at or above the action level. Engineering Controls The Fairfield Fire Department recognizes that minimizing noise production is the best way to eliminate hazardous noise exposure. As new equipment and apparatus are purchased, the department will incorporate, where practical, noise reducing technologies. Administrative Controls Supervisors will be required to comply with and support this program. CONN-OSHA considers the noise exposure levels as a serious hazard. Failure to utilize HPD’s when required is considered a serious violation by the department. Personnel that refuse to wear provided protection will face disciplinary action in a progressive manner. Hearing Protection Devices Hearing protection devices (HPDs) are considered the last option to control exposures to noise. HPDs are generally used during the necessary time it takes to implement engineering or administrative controls, or when such controls are not feasible. Basic Requirements All personnel shall wear hearing protection devices in accordance with the following chart when HPD usage is required. All personnel should wear hearing protection devices in accordance with the following chart when HPD usage is not required. At no time should the level of personal protection for firefighting be lowered due to the usage of hearing protection at scene of fires or other emergencies. If personnel can not safety wear hearing protection, they will not be required to wear it at emergency scenes. (i.e. pump operator working at a car fire on a limited access highway due to scene safety concerns) Hearing Protection Requirements for personnel by hazardous activity Activitity 1. Emergency response with lights and sirens 2. Inspection and operation of power equipment (gasoline engine type) or fixed equipment. 3. Operating apparatus, compressors, and pumps 4. Prevention inspections with exposure to audible alarm systems noise (ie. testing alarms) 5. Training activities involving all of the above 6. Apparatus maintenance activities with excessive noise generation 7. Emergency scene activities, power tools, high pressure gas leaks, extrications, and alarms 8. Structural Fire Fighting activities HPD Usage Required Required Required Required Required Required NOT required but Recommended - only use if it does not interfere with other PPE Not Required – only use if it does not interfere with other PPE HPD Selection and Use The Fairfield Fire Department provides a variety of hearing protection to all personnel at no cost. The department will initially offer a choice of the following hearing protectors which meet minimum noise reducing requirements (N.R.R.) of OSHA. Muff Style E.A.R Model 3000 ear muff – all riding positions of apparatus David Clack Headset (integrated radio/muff) – Engine 2 lsn __ Plug Style Moldex Rockets Reusable Ear Plugs – N.R.R. 26 db Fusion Reusable Corded Earplugs N.R.R. 27 db Howard Leight QB2hyg Supra-Aural N.R.R. 25 db E-A-R flex 28 N.R.R.28 db Training, selection and initial fitting of HPD’s will be provided by qualified personnel on an annual basis. Due to advances in technology, the department will continue to purchase newer styles of HPD’s which meet minimum OSHA requirements and offer them to personnel as requested at no cost. HPD Attenuation. Attenuation refers to the damping or decrease of noise levels as a result of wearing HPDs. In the event of changes in equipment and noise levels, the department will provide improved HPD’s to reduce noise exposures to acceptable levels. Training and Education The Fire Department will provide initial and annual training to all personnel as required by the standard. The training will at a minimum include the following topics: The effects of noise on hearing. The purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting, use, and care. The purpose of audiometric testing and an explanation of test procedures. Access to Information and Training Materials As a part of the FFDHCP, the department will: Make copies of the noise standard available to affected employees or their representatives and post a copy in each station. Provide affected employees with any informational materials pertaining to the standard that are supplied to the employer by OSHA. Provide, upon request, all material relating to the employer's training and education program to OSHA. Record Keeping The purpose of OSHA recordkeeping regulations is to assist employers in recognizing and correcting workplace hazards by tracking work-related injuries/illnesses and their causes. Requirements according to the noise standard are: Exposure Measurements Employers must maintain an accurate record of all employee exposure measurements. These records must be retained for two years. Audiometric Test Records The employer must retain all employee audiometric test records. These records must include: o Name and job classification of the employee. o Date of the audiogram. o The examiner's name. o Date of the last acoustic or exhaustive calibration of the audiometer. o Employee's most recent noise exposure assessment. The employer must maintain accurate records of the background sound pressure level measurements in audiometric test rooms. These records must be maintained for the duration of the affected worker's employment. Access to Records All records required by the noise standard must be provided upon request to: o employees, o former employees, o representatives designated by the individual employee, and o OSHA. Transfer of Records Employers who cease to do business must transfer to the successor employer all records required by the noise standard. The successor employer must retain these records for the remainder of the periods described previously.