Applaud Proposed EPA NRR Rule Changes for Acknowledging “Real World” Experience, Placing More Responsibility on Safety Managers, Expert Says
The Environmental Protection Agency’s proposed changes governing Noise Reduction Ratings will help to “refocus hearing conservation programs to prevent employee hearing loss, and reflect real-world realities in the workplace,” according to Brad Witt, director of hearing conservation for Sperian Hearing Protection, LLC.
“If enacted, the changes will place greater responsibility on the shoulders of safety managers for determining how much protection a noise-exposed worker is obtaining from earplugs and earmuffs, and this can result in better hearing protection for workers,” he said.
One part of the proposed rule (published in August in the Federal Register http://www.regulations.gov/search/Regs/contentStreamer?
objectId=0900006480a01551&disposition=attachment&contentType=pdf
involves revising the labelling of hearing protection devices (HPD) from a single-number estimate of protection to a two-number range, showing high/low values of estimated protection. A second change redefines the test methods by which HPDs are tested, and rated in the laboratory by manufacturers. A third involves including a class of hearing protection that has been excluded in the past – namely electronic hearing protectors which provide active noise reduction or impulse noise suppression. A fourth requires manufacturers to retest their products every five years.
Witt said he applauds the proposed changes for defining protection levels based on the user’s training and proper fit. “With its proposed new rating methods, EPA is confirming that protection is very dependent upon how well the user fits the products, that lab conditions are not field conditions, and that there’s new technology out here that can contribute greatly to a hearing conservation program,” he said.
“The current single number rating system can mislead purchasers to believe the same earplug will provide everyone the same level of protection. But in real-life, protection levels vary widely among individuals, due to their training, fit, and usage, and some will suffer hearing loss. This is not acceptable, and we applaud EPA for recognizing this in their proposed labelling.
“Implementing the proposed two-number range gives safety managers a more realistic estimate of how much protection their workers are really capable of achieving. Individual training will determine whether their workers receive protection toward the low side of that range or, with proper training, toward the higher side of that range.
“The proactive employers will train their employees well in hearing conservation practices. Employers can even fit-test the protection of earplugs and earmuffs now. A manager who simply passes out earplugs to his employees – and then leaves them to fend for themselves – will be inadvertently pushing his workers toward the lower end of the protection range,” Witt said.
Witt said he views the proposed rule changes as a “renewal of the true focus of HCP to stop hearing loss.” For that reason he urged employers, safety managers, risk managers, insurers, and workers themselves to actively support the new regulations.
"Witt and other experts and interested parties formally commented on the proposed NRR rule changes during a public hearing at the EPA in Washington, DC, on October 7, 2009.
