It is the policy of the University of Pennsylvania in coordination with the Office of the Environmental Health and Radiation Safety to provide employees with a safe and healthful working environment. This is accomplished by utilizing facilities and equipment that have all feasible safeguards incorporated into their design. When effective engineering controls are not feasible, or when they are being initiated, administrative controls will be used, followed by the use of personal protective equipment (PPE). 

The primary goal of the University of Pennsylvania Hearing Conservation Program is to reduce, or eliminate hearing loss due to workplace noise exposures. The program includes the following elements:

  • Work environments will be surveyed to identify potentially hazardous noise levels and personnel at risk.
  • Environments containing equipment that produces potentially hazardous noise should, wherever it is technologically and economically feasible, be modified to reduce the noise level to acceptable levels.
  • Where engineering controls are not feasible, administrative controls and/or the use of hearing protective devices will be employed.
  • Annual hearing testing will be conducted to monitor the effectiveness of the hearing conservation program. Early detection of temporary threshold shifts will allow further protective action to be taken before permanent hearing loss occurs.
  • Education is vital to the overall success of a hearing conservation program. Annual training is required and is part of the employees' and supervisors' responsibilities under the program.

When the sound levels listed below are exceeded, reasonable administrative or engineering controls will be instituted. If the controls fail to reduce the noise exposure to within those listed below, hearing protection will be provided and used to reduce the sound levels to an acceptable level. In addition, OSHA requirements dictate that whenever employee noise exposures equal or exceed an 8-hour time-weighted average (TWA) of 85 dBA, slow response, a continuing effective hearing conservation program shall be instituted.


The Office of Environmental Health and Radiation Safety (EHRS)

The Office of Environmental Health and Radiation Safety (EHRS) is responsible for developing, implementing, and administering the University of Pennsylvania Hearing Conservation Program (HCP).

Additional responsibilities include:

  • Identification of work areas and equipment within University of Pennsylvania facilities where noise levels equal or exceed 85 dBA;
  • Identification, through personnel monitoring, of University of Pennsylvania employees whose noise exposure level equal or exceed an 8-hour TWA of 85 dBA. Notification to the employee, the employee's supervisor and HUP Occupational Medicine of exposure measurements, and inclusion in the Hearing Conservation Program, including annual audiometric testing;
  • Conducting noise surveys and/or noise dosimetry to determine areas that require warning signs;
  • Training of employees in the following topics:
    • Noise induced hearing loss;
    • Recognizing hazardous noise;
    • Symptoms of overexposure to noise;
    • Hearing protection devices (HPD's)- advantages & limitations;
    • Selection, fitting, use and maintenance of HPD's;
    • Explanation of noise measurement procedures;
    • Hearing conservation program and requirements.
  • Identification of noise control measures (including engineering and administrative controls) and recommendations.

Occupational Medicine

Occupational Medicine (OM) at the Hospital of the University of Pennsylvania is responsible for conducting baseline and annual audiograms for new employees who may be assigned to tasks with potential exposure to elevated levels of noise. OM also schedules and conducts audiograms on an annual basis for employees exposed to sound levels greater than or equal to 85 dBA. OM is responsible for notifying EHRS of all employees who have experienced significant changes in hearing (standard threshold shifts) in order that follow-up investigations may be conducted. The affected employee and his or her supervisor will also be notified. The occupational nurse case manager sets up appointments and performs the audiogram in accordance with OSHA's noise requirements 29 CFR 1910.95. When a hearing test van is used for audiometric testing, OM will review and store all hearing test van audiometric results.  Follow up testing identified by the hearing test van audiologist will occur at OM.


It is the responsibility of Supervisors to ensure that all of their employees exposed to noise levels equal to or greater than 85 dBA have access to appropriate hearing protective devices in the work area and enroll those employee(s) in the HCP if identified as having an 8-hour TWA equal to or exceeding 85 dBA. Supervisors are responsible for enforcing the use of hearing protective devices and engineering and administrative controls in designated noise hazardous areas and dispensing ear muffs when necessary as well as maintaining a supply of disposable ear plugs.

The supervisor must ensure that the following are maintained:

  • Signs posted at the entrance to any work area where noise levels equal or exceed 85 dBA;
  • Supply hearing protection to his/her employee(s) at no cost to the employee(s);
  • Enforcement of the wearing of hearing protection in the designated areas using established disciplinary procedures;
  • Hearing Protection Devices (HPD) are used and maintained as originally intended and in accordance with instructions provided.

The supervisor is responsible for coordinating and scheduling HCP training and annual audiometric testing for all University of Pennsylvania personnel who participate in the HCP with EHRS.


Employees are responsible for wearing and maintaining hearing protective devices as instructed, and must follow any procedures required as  administrative controls. Employees enrolled in the University's Hearing Conservation Program must participate in annual training programs and the medical surveillance program, which includes baseline and annual audiometric testing.

Noise Evaluation and Surveillance Procedures

Identification of Hazardous Noise Areas

The Office of Environmental Health and Radiation Safety (EHRS) will identify work areas within University of Pennsylvania facilities where noise levels equal or exceed 85 dBA. Signs will be posted at the entrance to any work area where noise levels exceed 85 dBA, requiring anyone entering the area to wear proper hearing protection. Personnel who work in these areas shall have hearing protection supplied to them, shall be instructed in its proper use, and will be required to wear this equipment when in these identified areas. It is the responsibility of the supervisor to ensure that these precautions are maintained.

Noise Measurements and Exposure Assessments

All noise monitoring will be conducted by EHRS. The monitoring of employees for noise exposure is made up of two parts, area and personal monitoring. Area measurements are generally obtained first. If noise levels are at or above 80 dBA, personal monitoring using dosimeters is then performed. Sample data sheets will be used to record monitoring data for both area and personal noise monitoring results. EHRS will provide observation of the monitoring to employees who work in the area.

Area Measurements

In an area survey, measurements of environmental noise levels are recorded using a sound level meter to identify work areas where employees' exposures may be above hazardous levels, and where more thorough exposure monitoring may be needed. Area monitoring is conducted using a calibrated sound level meter set to the A scale, slow response. Within the area of interest, several different locations will be measured. Typical measurement locations would include:

  • In the hearing zone at the employee's normal work location.
  • Next to the noise source(s).
  • At the entrance(s) to the work area.
  • At other locations within the area where the employee might work.

A rough sketch of the area will be included with the results showing the locations where the noise readings were obtained.

If the noise levels are below 80 dBA on a time-weighted average basis in the area, no further routine monitoring will be required for that area. Should any of the noise measurements equal or exceed 80 dBA, records shall be maintained as to the noise levels recorded, where they were taken, and the source(s) of the noise. If any of the measurements equal or exceed a noise level of 80 dBA, employees who work in or near the high noise area or equipment shall have their noise exposure determined through personnel monitoring using dosimeters.

Personal Monitoring

Determination of the noise exposure level will be accomplished using calibrated noise dosimeters. Each employee to be monitored will have a dosimeter placed on him/her at the beginning of his/her normal work shift with the microphone placed in the "hearing zone". The dosimeter will be worn for the full duration of the work shift while the employee performs his/her normal work routine. At the end of the work shift, the dosimeter will be removed and information printed out as soon as possible. Background information will be collected from each employee detailing job description, unusual job activities, personal protective equipment etc., for the time period sampled. Those employees whose noise exposure equal or exceeds 85 dBA on an 8-hour TWA will be referred to the University of Pennsylvania Medical Center's Occupational Medicine Service for inclusion in the Hearing Conservation Program.

Re-monitoring of Hazardous Noise Area

Whenever an employee exhibits a standard threshold shift, as determined by Occupational Medicine, the employee's work place shall be remonitored to identify and rectify the cause.

Re-monitoring Due to Changes

Any area with noise levels that equal or exceed 80 dBA shall also be remonitored whenever a change in production process, equipment, or controls increase the noise exposure such that additional employees are exposed to noise levels at or above 80 dBA on a time-weighted average basis. Areas where the noise levels have dropped below 80 dBA due to alterations in equipment, controls or process changes may be eliminated from the monitoring program after a period of two months.

Noise Control

 Engineering and Administrative Controls

The primary means of reducing or eliminating personnel exposure to hazardous noise is through the application of engineering controls. Engineering controls are defined as any modification or replacement of equipment, or related physical change at the noise source or along the transmission path that reduces the noise level at the employee's ear. Engineering controls such as mufflers on heavy equipment exhausts or on air release valves are required where possible.

Administrative controls are defined as changes in the work schedule or operations which reduce noise exposure. If engineering solutions cannot reduce the noise, administrative controls such as increasing the distance between the noise source and the worker or rotation of jobs between workers in the high noise area should be used if possible.

The use of engineering and administrative controls should reduce noise exposure to the point where the hazard to hearing is eliminated or at least more manageable.

Personal Protective Equipment

Hearing protective devices (ear plugs, muffs, etc.) shall be the permanent solution only when engineering or administrative controls are considered to be infeasible or cost prohibitive. Hearing protective devices are defined as any device that can be worn to reduce the level of sound entering the ear. Hearing protective devices shall be worn by all personnel when they must enter or work in an area where the operations generate noise levels of:

  • Greater than 85 dBA sound levels as an 8 hour time-weighted average and/or;
  • 120 dB peak sound pressure level or greater.

Types of Hearing Protective Devices

Available hearing protective devices include the following:

  • Insert Type Earplugs: A device designed to provide an air-tight seal with the ear canal. There are three types of insert earplugs - premolded, formable, and custom earplugs.
    • Premolded Earplugs: Premolded earplugs are pliable devices of fixed proportions. Two standard styles, single flange and triple flange, come in various sizes, and will fit most people. Personnel responsible for fitting and dispensing earplugs will train users on proper insertion, wear, and care. While premolded earplugs are reusable, they may deteriorate and should be replaced periodically.
    • Formable: Formable earplugs come in different sizes. Some are made of material which, after being compressed and inserted, expands to form a seal in the ear canal. When properly inserted, they provide noise attenuation values that are similar to those from correctly fitted premolded earplugs. Individual units may procure approved formable earplugs. Supervisors must instruct users in the proper use of these earplugs as part of the annual education program. Formable plugs can be corded. 
    • Custom Molded Earplugs: A small percentage of the population cannot be fitted with standard premolded or formable earplugs. Custom earplugs can be made to fit the exact size and shape of the individual's ear canal. Individuals needing custom earplugs will be referred to an audiologist.
    • Canal Caps: Canal caps are ear plugs that are attached to a plastic or metal band.  The advantage of the canal cap is that it can be easily removed in a quiet environment and can then be inserted when it becomes loud.  The canal caps do not always seal as well as a formable or premolded earplug and may be uncomfortable if the pressure from the band is too strong.  In general, we suggest other earplugs are used if possible.
  • Earmuffs: Earmuffs are devices worn around the ear to reduce the level of noise that reaches the ear. Their effectiveness depends on an air tight seal between the cushion and the head.

Selection of Hearing Protective Devices

Employees will be given the opportunity to select hearing protective devices from a variety of suitable ones recommended by the Office of Environmental Health and Radiation Safety. The chosen hearing protectors shall have a Noise Reduction Ratio (NRR) high enough to reduce the noise at the ear drum to 85 dBA or lower.  If single hearing protection is not sufficient, double hearing protection will be required.

Issuance of Hearing Protective Devices

The issuance of hearing protective devices is handled through both EHRS and the Supervisor. EHRS will determine the correct noise reduction rating and issue and fit the initial hearing protective devices (foam inserts, disposables). Instruction on the proper use and care of earplugs and earmuffs will be provided whenever HPDs are dispensed. Personnel requiring earmuffs in addition to earplugs will be informed of this requirement and educated on the importance of using proper hearing protection. The Supervisor will dispense ear muffs when necessary and will maintain a supply of disposable earplugs.

Use of Hearing Protective Devices

  • Always use and maintain HPDs as originally intended and in accordance with instructions provided.
  • Earmuff performance may be degraded by anything that compromises the cushion-to-circumaural flesh seal. This includes other pieces of personal protective equipment such as eyewear, masks, faceshields, and helmets.

Maintenance of Hearing Protective Devices

  • Reusable earplugs, such as the triple flange or formable devices should be washed in lukewarm water using hand soap, rinsed in clean water, and dried thoroughly before re-use. Wet or damp earplugs should not be placed in their containers. Cleaning should be done after each use and prior to another employee wearing the same HPD.
  • Earmuff cushions should be kept clean. The plastic or foam cushions may be cleaned in the same way as earplugs, but the inside of the muff should be disassemled to clean. When not in use, ear muffs should be placed in open air to allow moisture that may have been absorbed into the cups to evaporate.  Replace a cushion if it is cracked or damaged. Replace the earmuff if the band does not hold the cushions securely to the head. 

Hearing Protection Performance Information

The maximum sound attenuation one gets when wearing hearing protection devices is limited by human body and bone conduction mechanisms. Even though a particular device may provide outstanding values of noise attenuation, the actual noise reduction may be less because the noise surrounding the head and body bypasses the hearing protector and is transmitted through tissue and bone pathways to the inner ear.

Note: The term "double hearing protection" is misleading. The attenuation provided from any combination earplug and earmuff is not equal to the sum of their individual attenuation values.

Medical Surveillance


Upon identification of employees whose 8-hour TWA equals or exceeds 85 dBA, EHRS will inform the employee(s), Occupational Medicine and the employees' Supervisor, in writing, of the need to enroll certain employee(s) in the Hearing Conservation Program. Information supplied to Occupational Medicine will include the employee(s) name, supervisor's name, telephone number, and the noise levels recorded in the employee's work area, including dosimetry data. It will be the responsibility of the Supervisor to enroll his/her employee in the Hearing Conservation Program.

In work locations where either through administrative or engineering controls, noise levels are found to have fallen such that the employee's 8-hour TWA is below 80 dBA, EHRS shall notify the employees, Occupational Medicine and the employee's Supervisor, by memo, that the employees working in that area are no longer required to be enrolled in the Hearing Conservation Program. The final decision as to an employee's enrollment status will be left with the Office of Environmental Health and Radiation Safety.

The results of area and personal monitoring shall be forwarded to Occupational Medicine upon completion of the noise surveys.

Any personnel experiencing difficulty in wearing assigned hearing protection (i.e., irritation of the canals, pain) will be advised to immediately report this to their supervisor and make arrangements to go to Occupational Medicine for evaluation as soon as possible.

Audiometric Testing

The object of the audiometric testing program is to identify workers who are beginning to lose their hearing and to intervene before the hearing loss becomes worse. Audiometric testing will be provided to all employees whenever employee noise exposures equal or exceed an 8-hr. time-weighted average (TWA) of 85 dBA following the requirements of 1910.95(g). Annual re-testing will be offered to all personnel enrolled in the Hearing Conservation Medical Surveillance Program.  Audiometric testing will be offered at The University of Pennsylvania Medical Center's Occupational Medicine Service or through a mobile audiometric test van.

Audiometric test vans may be used for audiometric baseline and annual testing.  Test results will be reviewed by an audiologist and the University of Pennsylvania Occupational Medicine, and any re-tests will be scheduled at Occupational Medicine. 


The training and education program will provide information about the adverse effects of noise and how to prevent noise-induced hearing loss. At a minimum, all training will cover the following topics:

  • Noise-induced hearing loss;
  • Recognizing hazardous noise;
  • Symptoms of overexposure to hazardous noise;
  • Hearing protection devices - advantages and limitations.
  • Selection, fitting, use, and maintenance of HPDs.
  • Explanation of noise measurement procedures.
  • Hearing conservation program requirements.

Employees may be provided with copies of the OSHA noise standard (29 CFR 1910.95) and other handouts describing the University of Pennsylvania Hearing Conservation Program. Information provided in Appendix C of this document may also be used.

University employees shall be encouraged to use hearing protective devices when they are exposed to hazardous noise during activities at home; e.g., from lawn mowers, chain saws, etc.

The Office of Environmental Health and Radiation Safety will provide annual refresher training.

Supervisors must contact EHRS to schedule training for new personnel assigned to work in noisy environments and for retraining of current personnel.


Hearing Conservation Program records will include the following:



Medical Evaluation and Audiograms

HUP Occupational Medicine & Health Service

Training Records


Hearing Conservation Program Manual

EHRS and the EHRS Web Site

Hazard Evaluations


All non-medical records (ex., work area and equipment surveys) will be maintained for a period of five years. Results of hearing tests and medical evaluations performed for hearing conservation purposes as well as noise exposure documentation shall be recorded and shall be a permanent part of an employee's health record.

All personnel who routinely work in designated hazardous noise areas shall be identified and a current roster of such personnel shall be maintained by EHRS and Occupational Medicine, and updated periodically.

Appendix A -Training Information


Supervisors and exposed workers must become aware of and understand about the adverse effects of noise and how to prevent noise-induced hearing loss. People exposed to hazardous noise must take positive action, if progressive permanent hearing loss is to be prevented. Each exposed worker and supervisor should know the following:

  1. Noise exposure may result in permanent damage to the auditory system and there is no medical or surgical treatment for this type of hearing loss. Though the use of a hearing aid may provide some benefit, normal hearing will not be restored. Many people don't realize loud sounds can cause hearing loss. Furthermore, in its initial stages, the person may not notice a problem since noise-induced hearing loss is invisible, painless, and the loss involves the inability to hear high frequencies. It is dangerous to ignore the temporary characteristics of noise-induced hearing loss (such as ringing or buzzing in the ears, excessive fatigue, etc.).
  2. Each person should know how to recognize hazardous noise even if a noise survey has not been conducted an/or warning signs posted. Recognizing and understanding the adverse effects of off-duty noise exposures is also important. The best rule to follow is: "If you have to shout at arms length (approximately three feet) to talk face-to-face, you are probably being exposed to hazardous levels of noise."
  3. Preventing noise-induced hearing loss is accomplished by reducing both the time and intensity of exposure. Reducing exposure time is accomplished by avoiding any unnecessary exposure to loud sound. Reducing intensity is usually accomplished by wearing personal hearing protection. Each person must be able to properly wear and care for the particular type of hearing protection selected. Speech communication is difficult in high intensity noise. However, most people don't realize it's easier to understand speech if hearing protection is worn in a hazardous noise environment. Hearing protection reduces the noise and the level of speech, resulting in a more favorable listening level. Hearing protection reduces the intensity of frequencies above the speech range; thus, reducing the noise and accentuating speech. People who claim wearing hearing protection makes it difficult to hear speech are probably in noise levels less than 85 dBA or have already developed a hearing loss.

Each person must know how to tell if they have been overexposed to loud sound. Overexposure may occur even while wearing hearing protection. Earplugs and/or earmuffs alone may not be enough protection. Each time a temporary threshold shift (TTS) occurs, a certain degree of permanent loss results. The recognizable symptoms of overexposure are described as "dullness in hearing or ringing in the ears."

Appendix B  Training Outline

1. How noise damages our hearing

2. Consequences of hearing loss in everyday life:

poor speech understanding

social isolation from friends and family

interference with work and leisure activities

3. Noise exposures that are hazardous

off-the-job (gun-fire, power tools, etc)

on-the-job (sound survey information)

4. Engineering controls implemented or planned

5. HPD choices for the employees department

how to use them correctly

how to care for and replace them

how to solve common HPD problems or complaints

6. Audiometric evaluations-purpose and procedures

Understand your own audiograms

Hearing changes may mean inadequate protection

Nonoccupational hearing loss may be detected

7. Ways to protect your hearing on and off the job

Wear HPD's correctly and consistently

Avoid unnecessary noise exposures

Use engineering noise controls

8. The University's HCP policies:

Importance of HCP

Participation in HCP a condition of employment

HCP is a benefit to employees

Participation is to the employee's own advantage

9. Questions and Answers

Appendix C-Occupational Safety and Health Administration Standard - 29 CFR 1910.95 - Noise

OSHA Occupational Noise Exposure Standard


Reviewed: 1/25/2019