Safety Tidbit 3.41 - Why 100 Decibels for Noise Abatement

Safety Tidbit 3.41 – Why 100 Decibels for Noise Abatement

Reference:       OSHA Occupational Noise Exposure Standard

                        OSHA Field Operations Manual

As some of you may remember back in 2011 or so, OSHA pushed to start enforcing engineering controls for noise exceeding 90 decibels. Which may have seemed strange as the OSHA Noise Standard, 1910.95(b)(1) states: “When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized.” Which, by the way, the original noise standard was from the first set of OSHA standards in 1971. Therefore, OSHA has never really written an Occupational Noise Standard. However, in the early 1980’s, the Hearing Conservation Amendment was added to the original standard.

An outcome from a 1982 court case and found in OSHA’s Field Operations Manual (FOM):

“Current enforcement policy regarding §1910.95(b)(1) allows employers to rely on personal protective equipment and a hearing conservation program, rather than engineering and/or administrative controls, when hearing protectors will effectively attenuate the noise to which employees are exposed to acceptable levels. (See Tables G-16 or G-16a of the standard).”

This decision and policy came about primarily because, at the time, NIOSH asserted that a comprehensive hearing conservation program was as effective at preventing hearing loss as engineering and administrative controls.

Furthermore, in the OSHA FOM:

“1. Citations for violations of §1910.95(b)(1) shall be issued when technologically and economically feasible engineering and/or administrative controls have not been implemented; and

a. Employee exposure levels are so elevated that hearing protectors alone may not reliably reduce noise levels received to levels specified in Tables G-16 or G-16a of the standard. (e.g., Hearing protectors which offer the greatest attenuation may reliably be used to protect employees when their exposure levels border on 100 dba). See CPL 02-02-035, 29 CFR 1910.95 (b)(1), Guidelines for Noise Enforcement; Appendix A, dated December 19, 1983; or

b. The costs of engineering and/or administrative controls are less than the cost of an effective hearing conservation program.”

So, as you can see OSHA inspectors have been forced to wait until the noise levels are above 100 decibels before engineering controls will be enforced. Meanwhile, hearing loss is one of the greatest occupational injuries plaguing our workforce and degrading worker quality of life. As consultants, we need to look for those feasible engineering and administrative controls and advise our clients so prudent practices can be implemented and the workers protected from occupational noise.

Hope this was helpful and thank you for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan
P.S. If you have an interesting safety or health question please let me know.