Safety Tidbit 2.30 - Recording Hearing Loss on the OSHA 300 Form

Safety Tidbit 2.30 - Recording Hearing Loss on the OSHA 300 Form

Reference:       OSHA Recordkeeping Standard

                        OSHA Letter of Interpretation dated April 29, 2016

I figured another Safety Tidbit on Recordkeeping would not be bad as it is that time of year.  OSHA’s Recordkeeping standard in 1904.10(a) requires: “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." Initially, you must ask, is the injury work-related? As defined by OSHA Recordkeeping Standards, an injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness.

We usually presume work-relatedness for injuries and illnesses resulting from events or exposures occurring in the work environment [1904.5(a)]. If you are exposing the worker to noise levels more than 85 dBA for eight hours (or the adjusted amounts if you work shifts longer than eight hours), then you potentially caused or contributed to the hearing loss injury. Furthermore, an employer must determine their implementation of their hearing conservation program. In additional to assessing the level of protection of the worker's hearing protector, work related determination should also consider whether the given worker actually used the protection and the effectiveness of the employee training in wearing the protection.

A question arose this week whether to include the injury on the OSHA 300 log or not when the worker’s hearing level was already above 25 decibels. Remember what I put in above, the injury is work-related if work caused or contributed to the condition or significantly aggravated a pre-existing injury.  Since the worker was already impaired, as their hearing is above 25 dBA then a significant threshold shift is a further exacerbation of the condition or work conditions “significantly aggravated a pre-existing injury.”

Remember, the purpose of a hearing conservation program is to conserve hearing. If the worker continues to lose her/his hearing, then the program is not working properly.  Also, the purpose of the 300 log is to track and trend injuries so that you can make changes to reduce risk and therefore reduce injuries.  Lastly, as part of the hearing conservation program, once a worker has a loss of their hearing, as shown in the annual audiogram, certain specific follow-up is necessary (1910.95(g)(7)(iii)].

Hope this was helpful and thanks for reading my Safety Tidbits ~ Bryan