Airing on the Side of Caution

To encourage workers to wear their hearing protection, Atlanta-based Delta Air Lines has found that it’s good to keep things personal.
Belinda Hall, for example, tells Delta workers that her grandfather – a retired autoworker – is hard of hearing. “We tell them, ‘You want to hear your grandbabies,’” Hall says. “We make it personal, because it is personal.”

Hall, who is the program manager, compliance and quality assurance, for Delta’s Airport Customer Service and Ground Support Equipment divisions, says “it’s the exception” that she hears of workers who don’t comply with Delta’s hearing protection requirements. In particular, Hall notes that younger workers – who can witness firsthand the ravages of noise exposure in their older colleagues – are becoming more aware of the importance of wearing their hearing protection.

“A lot of the old-timers have terrible stories and terrible hearing, because whatever they did in their life or in their past jobs – whether they worked here or somewhere else – they didn’t wear hearing protection,” Hall says. “So they’re losing their hearing, and I think the people in later generations are realizing, ‘Wow, it is important.’ So I think word-of-mouth is a part of the education process.”

Education is an important part of a hearing conservation program, but according to OSHA 29 CFR 1910.95, it’s just one component. That’s why in addition to providing annual training on the hazards of noise, Delta also conducts annual audiometric testing, provides hearing protection equipment such as earplugs and earmuffs and uses administrative and engineering controls – where feasible – to limit noise exposures. Together, these elements comprise Delta’s hearing conservation program, which includes any worker whose noise exposure is more than 85 dBA as an 8-hour, time-weighted average.

Although Delta in 2005 filed for bankruptcy, the airline has not compromised on safety. In the case of hearing protection, Industrial Hygiene Manager Steve Tochilin notes that implementation of a hearing conservation program not only is an OSHA requirement but also is included in Delta’s safety manual, and “If it’s in there, we’re going to do it.”

“Delta is totally committed to compliance, whether it’s FAA or OSHA or EPA,” Tochilin says. “It’s not like it’s a nice thing to do. We have to do it, and it’s the way we do business.”

Above and Beyond

T he OSHA noise exposure standard says that employers must require hearing protection to be worn by any worker whose 8-hour noise exposure is more than 90 dBA. It also says that employers must require hearing protection to be worn by any worker whose 8-hour noise exposure is more than 85 dBA and who has experienced a standard threshold shift (essentially a loss of 10 decibels of hearing in the middle frequencies).

Delta – which OCCUPATIONAL HAZARDS in 2005 named one of America’s Safest Companies – goes beyond the OSHA standard by requiring hearing protection to be worn by any worker with an 8-hour noise exposure of 85 dBA or more.
Tochilin says the philosophy behind Delta’s stricter standard is just as much about safety as it is about “consistency and enforceability” for front-line supervisors.

“The people you’re supervising may be all over the airport,” Tochilin says. “You can’t really keep up with 2,000 people when some are supposed to be wearing hearing protection and some aren’t. If everybody’s wearing it, it’s easy to pick out the people who aren’t – especially if they have the bright orange earplugs they’re supposed to be wearing.”

While departments such as those at maintenance facilities are evaluated on a case-by-case basis to determine whether they qualify for the hearing conservation program, Delta errs on the side of caution when it comes to including its “ramp” workers – baggage handlers, line mechanics and anyone else who works near the airplanes.

In terms of noise exposure, these are Delta’s most at-risk workers. Consequently, even if noise dosimetry indicates that a ramp worker has an 8-hour noise exposure of 82 dBA one day, Tochilin says that Delta would keep that worker in the hearing conservation program.
“Because you might come back a month later and find out that whatever airline has the two gates next to us has just changed planes, and now they’re using something that’s considerably louder and our exposures have gone up.”

Delta also considers most baggage room workers to be part of the ramp, even though they might not be working near the planes. Tochilin points out that the din of sorting equipment and vehicle traffic creates noise exposures that are akin to an industrial environment. “It’s not a library, that’s for sure,” Tochilin says.

“Free Harassment Service”

O SHA’s noise exposure standard calls for annual audiometric testing of employees whose 8-hour exposures are equal to or exceed 85 dBA. Heather McMaster, an occupational health specialist with Delta, explains that the airline encourages employees to schedule their annual hearing tests around the time of their hire dates.

McMaster, who is based in Salt Lake City, and two occupational health nurses in Atlanta create spreadsheets to keep track of the test results and dates for the thousands of Delta employees in the program. If an employee fails to schedule his or her annual hearing test, McMaster quips: “We provide a free harassment service until they do.”

At Delta hubs in Atlanta and Salt Lake City, the occupational health nurses administer the hearing tests. The nurses use the tests as an occasion to review the employee’s hearing history, discuss any recent hearing problems and remind them to wear their hearing protection. If the hearing test reveals a standard threshold shift, OSHA requires the employee to be notified, in writing, within 21 days. Other follow-up actions might include refitting and retraining on the proper use of hearing protection.

At some airports, hearing tests are administered by Delta employees who have been certified by the Council for Accreditation in Occupational Hearing Conservation. Even though the employees receive no extra compensation for this, McMaster finds that they often become advocates for hearing conservation.

“When they understand how your ears and your hearing mechanism work and what their role is ,” McMaster says, “ ... it’s like they catch fire about hearing protection.”

Workers Have a Say

To ensure that employees are comfortable with their hearing protection, groups of Delta workers at each airport test various product samples from Delta’s PPE vendor. The employees vote on the ones they like.

An earplug or earmuff’s noise reduction rating (NRR) is important, but Tochilin notes that “the highest NRR isn’t always the best solution.” Sometimes, a product with a high NRR can compromise comfort or even reduce noise to the point where workers are unable to hear their co-workers.

“We focus on what the employees like,” he says. “Because the whole goal here is to have them wear it. Something with a great NRR that they only wear two-thirds of the time – because it’s uncomfortable or difficult to put in your ear – is not going to provide as much protection as one that they wear all the time with a lower NRR.”