NHCA points out that occupational hearing loss cases may be underreported, despite OSHA’s requirement for companies to report documented hearing loss (as standard threshold shifts, or STS) on the 300 log. The new guidelines are designed promote hearing conservation best practices and help audiologists and others determine recordability of hearing loss cases, according to NHCA.
“Stated compliance with OSHA’s hearing conservation amendment does not assure that a shift in hearing level is not work related,” the guidelines state. “Most professionals in hearing conservation know that workers can still incur occupational hearing losses in spite of the employer’s attempt to comply with regulations. Compliance with OSHA’s standards should be considered the minimum and does not reflect best practice for the prevention of hearing loss.”
NHCA added that some audiologists and physicians have reported resistance from clients, along with pressure to alter their assessments. These guidelines may assist professionals in resisting that pressure and making the best decisions surrounding the work-relatedness and recordability of hearing loss.
The new guidelines advise professional reviewers to consider the following when determining occupational hearing loss for documentation on the OSHA 300 log:
- OSHA's policies as well as legal determinations that if qualifying hearing loss is likely work related, it must be recorded.
- Noise measurements – including work area and personal dosimetry measurements to determine the worker's time-weighted average exposure level.
- Audiometric configuration – describing configurations consistent with non-work-related causes.
- Non-occupational exposures and medical history.
“Physician and audiologist reviewers who are responsible for making the determination to record an OSHA STS on the 300 log will now have consistent and uniform guiding principles to assist them in making that decision,” said NHCA President Timothy L. Rink, Ph.D.
These guidelines can be downloaded as a PDF.