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Deadline is Approaching
Three Comparisons
The Reasons Behind The Changes
Deadline is
Approaching
On July 1, 2002 OSHA published the Final Rule on Recording Hearing Loss. This is a revision of the hearing loss
provisions of the Occupational Injury and Illness Recording and Reporting Requirements published January 19, 2001.
OSHA’s new rule is scheduled to take effect on January 1, 2003.
If your clinic performs audiometric testing for corporate clients that are subject to federal OSHA regulations, you will
need to identify OSHA-reportable test results using the new methodology.
Here is the change: Before January 1, 2003, companies must report to OSHA those workers who experience a hearing loss
that averages 25 decibels (dB) at 2000, 3000, and 4000 hertz (Hz), regardless of the present level of the
employee’s hearing. Starting January 1, 2003, companies will need to report to OSHA those workers who experience an
average hearing loss of 10 dB at 2000, 3000, and 4000 hertz and whose hearing level after the change averages 25 dB or
more at 2000, 3000, and 4000 hertz.
Three
Comparisons
To see how the new rules compare to the old, let’s look at three case studies:
CASE 1
|
Frequency
|
Baseline
|
New
|
Audiogram Difference
|
|
(Hz)
|
(dB)
|
(dB)
|
(dB)
|
|
2000
|
10
|
35
|
25
|
|
3000
|
10
|
35
|
25
|
|
4000
|
10
|
35
|
25
|
|
Average
|
10
|
35
|
25
|
In Case 1 the difference between the audiograms averages 25 dB and the new audiogram averages 35 dB. This hearing loss
would be reportable to OSHA under both the old and new rules.
In Case 2 the difference between the audiograms averages 10 dB and the new audiogram averages 20 dB. This audiogram
would not be reportable to OSHA under either the old or new rules.
CASE 2
|
Frequency
|
Baseline
|
New
|
Audiogram Difference
|
|
(Hz)
|
(dB)
|
(dB)
|
(dB)
|
|
2000
|
10
|
15
|
5
|
|
3000
|
10
|
25
|
15
|
|
4000
|
10
|
20
|
10
|
|
Average
|
10
|
20
|
10
|
In the final example (Case 3), the difference between the audiograms averages 10 dB and the new audiogram averages 30
dB. This audiogram would not be reportable to OSHA under the old rules, but is reportable under the new rules because it
meets the new standard of average change of 10 dB or greater and average hearing level after the change is 25 dB or
more.
CASE 3
|
Frequency
|
Baseline
|
New
|
Audiogram Difference
|
|
(Hz)
|
(dB)
|
(dB)
|
(dB)
|
|
2000
|
20
|
30
|
10
|
|
3000
|
15
|
35
|
20
|
|
4000
|
25
|
25
|
0
|
|
Average
|
20
|
30
|
10
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The Reasons Behind the
Changes
Why did OSHA make the change? Several reasons-here are two:
To understand the first, we need to review some basic audiology. When we discuss hearing, we use the measure of decibels,
named after the great scientist Alexander Graham Bell. A decibel is generally the level of just noticeable difference in
hearing in the normal human ear. As a rule, we cannot tell the difference between two sounds less than a decibel
apart.
The decibel scale is logarithmic. Since you may not remember logarithms very well from high school, look at the table on
the next page. In that table, we show how a particular change in decibels relates to the underlying change in sound
intensity.
TABLE 1
|
Change in Decibels
|
Factor Change in Sound Intensity
|
|
10
|
10
|
|
20
|
100
|
|
25
|
316
|
|
30
|
1,000
|
|
40
|
10,000
|
|
50
|
100,000
|
|
60
|
1,000,000
|
Look at the difference between the 10 dB and 25 dB changes in Table 1. A
change of 10 decibels reflects a change in sound intensity of 10 times; a change of 25 dB is a change of 316 times. Big
difference!
OSHA concluded it was too big. So OSHA adopted a narrower range.
A second reason for the change is that the old 25 dB OSHA reporting standard created a mess. OSHA wants the employee
notified when a standard threshold shift (STS) has occurred. An STS is defined as an average change at 2000, 3000, and
4000 hertz of 10 dB or more. Using 25 dB as the OSHA reportable cutoff meant that programs had to keep two sets of
baseline audiograms-one for the 10 dB shift that needed to be reported to the employee and one for the 25 dB shift that
needed to be reported to OSHA. The new requirement simplifies reporting considerably because a single baseline can be
used for both employee and OSHA reporting.
OSHA estimates 105,779 additional cases of occupational hearing loss will be captured by this rule change.
If you are using software to manage audiology reporting, be sure to obtain an updated version of your reports prior to
the January 1, 2003 deadline.
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