A new article was posted on October 19, 2010 on the Occupational Health & Safety website explaining the new “proposed interpretation” document released in the Federal Register. The document outlines the revised interpretation of sections 29 CFR 1910.95(b)(1) and 1926.52(b) of the Occupational Safety and Health Act. Previously, employers could use Personal Protective Equipment (PPE) and hearing conservation programs to reduce the effects of sound levels that exceeded the standards listed in the Act. However, the Act actually states that “feasible administrative or engineering controls shall be utilized” to reduce sound levels to below standards. Only if these controls failed could PPE be used. The document published in the Federal Register states that OSHA will now interpret and enforce the Act as it is written, in accordance with the stated hierarchy. This means that, when feasible, administrative or engineering controls must be the first line of protection for high sound levels.
With a bachelor’s degree in Acoustical Engineering and subsequent work in the noise control field, I am well versed on the practical implications of the noise standards in the Act. Administrative and engineering controls are much more effective in reducing noise than PPE. The problems that sometimes occur with PPE stem from a lack of training and knowledge on how to correctly use the PPE and also from lax enforcement of the use of PPE. Additionally, these types of protection simply do not offer the same amount of noise reduction as administrative and engineering controls.
Administrative controls involve reducing the amount of time a worker is exposed to a high-noise environment. This is practical and attainable in most situations. Engineering controls consist of modifications to the plant, equipment, materials or processes that reduce the sound level at the source. This can be done by substituting existing equipment for quieter options, modifying equipment or materials with noise control devices, or creating noise control barriers between the worker and the noise source. These options can become expensive, which is the main problem for most employers. Employers would much rather use PPE, the cheaper option, however, PPE is typically inferior to administrative and engineering controls for reducing sound levels. With OSHA now enforcing a stricter interpretation of their regulations, they will provide increased protection of workers against high sound levels but will also force many employers to implement more costly solutions.
The article discussed in this blog can be found at:
A link to the “proposed interpretation” document published in the Federal Register can be found at:
Based on this new interpretation, you may need to beef up your noise control program. Contact Allison Stalker at 215-881-9401 or email@example.com for a review of your situation.