Last Revised: December 19, 2022
It is the policy of the University of Pennsylvania in coordination with the Office of the Environmental Health and Radiation Safety (EHRS) to provide employees with a safe and healthful working environment. This objective 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 (HCP) is to reduce or eliminate hearing loss due to workplace noise exposures. The program includes the following elements:
- Work environments will be quantitatively and/or qualitatively surveyed to identify potentially hazardous noise levels and personnel at risk.
- Environments containing equipment that produces potentially hazardous noise will, wherever it is technologically and economically feasible, be modified using engineering controls to reduce noise to acceptable levels.
- Where engineering controls are not feasible, administrative controls and/or the use of hearing protective devices (HPDs) will be employed.
- Annual audiometric testing will be conducted for all employees enrolled in the HCP to monitor the effectiveness of the program. Early detection of temporary hearing threshold shifts will allow further protective actions to be taken before permanent hearing loss occurs.
- Education is vital to the overall success of the hearing conservation program at Penn. Annual training is required and is part of each employee’s and each supervisor’s responsibilities under the program.
Noise levels have units of decibels, which are logarithmic units of measurement used to describe the power of noise. Decibels may be A-weighted (dBA), C-weighted (dBC) or unweighted (dB).
When the Penn Action Levels listed below are exceeded, reasonable administrative or engineering controls will be instituted. If the controls fail to reduce the noise exposure to levels below the limits listed below, hearing protection will be provided and used to reduce the sound levels to an acceptable level.
The provisions of the University of Pennsylvania HCP meet or exceed regulatory requirements set forth by OSHA in 29 CFR 1910.95.
The Penn Action Levels for Noise Exposure are as follows:
- 85 dBA as an 8-hour time-weighted average (TWA), as measured using a 3-decibel exchange rate and 80 decibel measurement threshold.
- 140 dBC as a peak sound pressure level. This level shall not be exceeded at any time as a continuous, intermittent or impact noise during a shift.
If either or both of these action levels are met or exceeded during at least one workday per year, employees in affected job categories or work areas shall be enrolled in the Penn HCP.
The Penn Action Levels are consistent with current threshold limit values (TLVs) published by the American Conference of Governmental Industrial Hygienists (ACGIH) and recommended exposure limits (RELs) published by the National Institute for Occupational Safety & Health (NIOSH).
Federal Occupational Safety and Health Administration (OSHA) requirements dictate that whenever employee noise exposures equal or exceed an 8-hour TWA of 85 dBA at slow response with a 5-decibel exchange rate with an 80 dB measurement threshold, a continuing effective hearing conservation program shall be instituted. In addition, OSHA sets a permissible exposure limit (PEL) of 90 dBA at slow response with a 5-decibel exchange rate and a ceiling limit of 140 dBC as a peak sound pressure level. The Penn Action Levels are more protective than the OSHA requirements.
Additionally, personnel who work in job categories, tasks and areas surveyed and determined to have noise levels below 80 dBA on a TWA basis will not continue to be assessed unless changes to the job duties, area or equipment occur. Personnel who work in job categories, tasks or areas known to have noise exposures between 80 and 85 dBA are not required to be enrolled in the HCP but shall be periodically reassessed.
The Office of Environmental Health and Radiation Safety (EHRS)
EHRS is responsible for developing, implementing, and administering the University of Pennsylvania HCP. Additional EHRS responsibilities include:
- Identification and documentation of work areas and equipment within University of Pennsylvania facilities where noise levels may equal or exceed 80 dBA, or where significant peak or impulse exposures may occur.
- Identification, through personal dosimetry, of University of Pennsylvania employees or job categories whose noise exposure level equal or exceed 85 dBA as an 8-h TWA or 140 dBC as a peak measurement,
- Notification to the employee, the employee's supervisor(s) and HUP Occupational Medicine (OM) of exposure measurements, and inclusion in the Hearing Conservation Program, including annual audiometric testing,
- Conducting noise surveys and/or noise dosimetry to determine areas or equipment that require warning signage,
- Training of employees enrolled in the program,
- Identification of noise control measures (including engineering and administrative controls) and recommendations for reduction of noise exposure.
- Evaluation of PPE for use in hearing protection-required areas and job tasks, and recommendations for types of PPE to supervisors upon request.
- Management of audiometric testing performed using mobile audiometric testing laboratories and coordinating records transfer to OM.
Occupational Medicine (OM)
OM at the Hospital of the University of Pennsylvania is responsible for conducting baseline and annual audiometric testing for new employees who may be assigned to job categories, duties or tasks with potential exposure to hazardous 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 including standard threshold shifts (STSs) so 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.
For some exposed employees, a mobile audiometric testing laboratory may be used for baseline and annual examinations. When a mobile audiometric testing laboratory is used for audiometric testing, EHRS will coordinate and manage the testing performed by a qualified technician. EHRS will provide all results to OM. OM will review and maintain records of all mobile laboratory audiometric testing as provided by EHRS. Follow up testing identified by the mobile audiometric testing laboratory audiologist will occur at OM or in another medical or clinical setting with qualified audiologists.
It is the responsibility of Penn Departments to purchase and deploy noise controls and HPDs as required by this program.
It is the responsibility of Penn Supervisors to ensure that all of their employees exposed to noise levels in excess of Penn Action Levels have access to appropriate controls and HPDs in the work area and enroll those employee(s) in the HCP if identified as having an 8-hour TWA equal to or exceeding Penn Action Levels.
It is the supervisor’s responsibility to ensure their employees’ continued compliance with the provisions of the HCP including the proper use of controls, annual audiometric testing, and annual training. The supervisor is responsible for coordinating and scheduling HCP training with EHRS and annual audiometric testing with EHRS and/or OM.
The supervisor shall ensure that the following are maintained:
- Signage posted at the entrance to any work area or on any equipment where noise levels equal or exceed 85 dBA,
- Supply HPDs to employee(s) at no cost to the employee(s),
- Enforcement of the wearing of hearing protection in the designated areas using established disciplinary procedures,
- Ensuring that HPDs are used and maintained as originally intended and in accordance with instructions provided.
Employees are responsible for wearing and maintaining HPDs as instructed and shall follow any procedures required as administrative controls. Employees enrolled in the HCP shall participate in annual training programs and the medical surveillance program, which includes baseline and annual audiometric testing.
Identification of Hazardous Noise Areas
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.
Exposure Assessments and Noise Measurements
All personnel who routinely work in designated hazardous noise areas shall be identified by EHRS. Exposure assessments consisting of noise measurements and qualitative observations will be performed. A similar-exposure group (SEG) approach will be used such that new employees at Penn entering a job capacity with known exposures to hazardous noise will be automatically enrolled in the HCP.
All noise monitoring will be conducted by EHRS. The monitoring of employees for noise exposure is made up of two parts, personal and area monitoring. Area measurements are generally obtained first. Area measurements are spot or time-weighted measurements of noise in work areas or noise emitted close to sources, such as equipment. If noise levels are at or above 80 dBA, personal monitoring using dosimeters is then performed. Personal dosimetry is the preferred method for determination of the need for enrollment of employees in the HCP, but either personal dosimetry, area monitoring, or qualitative observation may be used for enrollment decisions. Sample data sheets will be used to record monitoring data for both personal and area noise monitoring results. EHRS will provide observation of the monitoring to employees who work in the area and their supervisors.
Determination of the personal exposure levels will be accomplished using calibrated noise dosimeters. Each employee to be monitored will have a dosimeter placed on their shoulder at the beginning of their normal work shift with the microphone placed in the "hearing zone" as close as possible to the ear. The dosimeter will be worn for the full duration of the work shift or the specific tasks associated with hazardous noise while the employee performs their normal work routine. At the end of the work shift or tasks, the dosimeter will be removed and the data will be analyzed as soon as possible. During the monitoring, observational information will be collected from each employee detailing their job description, sources of noise in their work, usual and unusual job activities, HPDs worn etc., for the time period sampled. Those employees whose noise exposure equals or exceeds 85 dBA as an 8-hour TWA (using 80 dB threshold and 3 dB exchange rate) will be enrolled in the HCP.
In an area survey, measurements of environmental noise levels are recorded using a sound level meter to identify work areas and specific sources of noise 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 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 TWA basis in the area, no further routine monitoring will be required for that area unless changes to the area or equipment occur. If 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.
Re-monitoring of Enrolled Employees and Potentially Hazardous Noise Areas
Any area with noise levels that may potentially 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 TWA basis. Areas where the noise levels have decreased below 80 dBA due to alterations in equipment, controls or process changes may be eliminated from the monitoring program after confirmatory monitoring and a period of two months.
Additionally, whenever an employee exhibits a work-related standard threshold shift (STS) in hearing as determined by OM or another qualified medical group, the employee's workplace shall be re-surveyed to identify and rectify the cause(s) of the STS.
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 soundproofing enclosures around pumps and compressors, soundproofing panels on walls and ceilings in high noise areas, acoustical silencers on exhausts, installation of impact dampeners on metal-to-metal contact surfaces, mufflers on heavy equipment exhausts and air release valves, etc.) 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 implementation of a buy-quiet program, increasing the distance between the noise source and the worker, rotation of workers in a high noise area, etc.) will 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 (PPE)
HPDs (ear plugs, muffs, etc.) shall be the permanent solution only when engineering or administrative controls are determined to be infeasible or cost prohibitive. HPDs are defined as any device that can be worn to reduce the level of sound entering the ear. Hearing protection shall be worn by all personnel when they must enter or work in an area where the operations generate noise levels of:
- Equal to or greater than 85 dBA sound levels as an 8-hour TWA and/or,
- Multiple, repeated sound maxima occurring at 115 dBA or greater and/or,
- Any noise above 140 dbC for any time duration.
Types of Hearing Protective Devices (HPDs)
Available HPDs 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. Premolded plugs can be corded or uncorded.
- 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 departments may procure approved formable earplugs. Supervisors shall train users in the proper use of these earplugs when first distributed. EHRS also trains workers who use formable earplugs on their proper use as part of the annual education program. Formable plugs can be corded or uncorded.
- 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 quickly 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 based on the lower protection provided by canal caps.
- Earmuffs: Earmuffs are devices worn over and around the ear to reduce the level of noise that reaches the ear. Their effectiveness depends on an airtight seal between the cushion and the head with no gaps or material deformation.
Selection of Hearing Protective Devices (HPDs)
Employees will be given the opportunity to select HPDs from a variety of suitable ones evaluated and recommended by EHRS. Several styles and sizes will be made available because one style does not fit all workers. The chosen HPDs shall have a Noise Reduction Rating (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 (HPDs)
The issuance of hearing protective devices is handled through both EHRS and the Supervisor. Purchasing of HPDs is managed by the department. 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.
Use of Hearing Protective Devices (HPDs)
- Always use and maintain HPDs as originally intended and in accordance with the manufacturer instructions.
- Earplugs do not provide the rated protection if they do not form a tight barrier inside of the ear canal. Earplugs must be used in accordance with manufacturer instructions for insertion.
- Earmuff performance may be degraded by anything that compromises the cushion-to-circumaural flesh seal. This includes other PPE such as eyewear, masks, face shields, and helmets.
Maintenance of Hearing Protective Devices (HPDs)
- Reusable earplugs, such as the triple flange or formable devices shall be washed in lukewarm water using hand soap, rinsed in clean water, and dried thoroughly before re-use according to manufacturer instructions. 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 shall be kept clean according to manufacturer instructions. 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 NRR provided on the label of all regulatory-compliant HPDs is a single-number noise reduction factor determined by an empirically derived technique which considers a number of factors affecting performance variation. NRRs are regulated by the United States Environmental Protection Agency (40 CFR 211). The NRR required for HPDs used by individual departments and employees will be determined by EHRS based on exposure assessments and will vary between exposure groups.
The maximum sound attenuation achieved 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" as used to describe the use of both earplugs and earmuffs at the same time is misleading. The attenuation provided from any combination earplug and earmuff is not equal to the sum of their individual attenuation values.
Upon identification of employees whose 8-hour TWA exposure equals or exceeds 85 dBA or whose peak exposure exceeds 140 dBC, EHRS will inform the employee(s), OM and the employees' Supervisor, in writing, of the need to enroll certain employee(s) in the Hearing Conservation Program. Information supplied to OM will include the employee(s) name, supervisor's name, telephone number, and the noise levels recorded in the employee's work area, including personal dosimetry data. It will be the responsibility of the Supervisor to enroll his/her employee in the Hearing Conservation Program and to ensure continued compliance with the provision of the program.
In work locations where employee 8-hour TWAs have been successfully reduced to below 80 dBA through implementation of engineering or administrative controls, EHRS shall notify the employees, OM and the employee's Supervisor, by written memorandum, 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 in the HCP shall be made by EHRS.
The results of exposure assessments that result in a change in employee enrollment status in the HCP shall be forwarded to OM.
Any personnel experiencing difficulty in wearing assigned hearing protection (i.e., irritation of the canals, pain, interference with safe execution of job duties, etc.) will be advised to immediately report this to their supervisor and make arrangements to report to OM and/or EHRS for evaluation as soon as possible.
The objective 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 their noise exposures equal or exceed Penn Action Levels. Audiometric testing shall be provided at no cost to employees. Audiometric testing shall be performed such that all requirements of 29 CFR 1910.95(g), 29 CFR 1910.95(h) and 29 CFR 1910.95 Appendices D and E are met. Annual re-testing will be offered to all personnel enrolled in the Hearing Conservation Medical Surveillance Program. Audiometric testing will be offered at OM or through a mobile audiometric testing service.
Mobile audiometric testing laboratories may be used for audiometric baseline and annual testing. When tests are performed using a mobile unit, all test results will be reviewed by a qualified audiologist and OM, and any re-tests or medical follow-up appointments will be scheduled at OM or another clinic or medical practice with qualified audiologists.
Each annual audiogram shall be compared to an employee’s baseline audiogram to determine if the audiogram is medically valid and if an STS has occurred. An STS is defined as is a change in hearing threshold relative to the baseline audiogram of an average of 10 dB or more at frequencies of 2000, 3000, and 4000 Hz in either ear or both ears.
If an annual audiometric test shows a potential STS, supervisors will be notified by EHRS and a re-test audiogram with medical evaluation shall be scheduled at OM or in another medical or clinical setting with qualified audiologists within 30 days of the test. The supervisor is responsible for appointment scheduling and should seek the input of the employee when scheduling the appointment. All clinical follow-up results shall be reported to EHRS.
EHRS shall provide annual HCP training to all groups enrolled in the HCP. 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:
- Characteristics of noise
- The effects of noise on hearing
- Noise-induced hearing loss and its health effects
- Recognizing hazardous noise exposures
- Symptoms of overexposure to hazardous noise
- HPD advantages and limitations
- Selection, fitting, use, and maintenance of HPDs
- Explanation of noise measurement procedures
- Penn Hearing conservation program requirements
- The purpose of audiometric testing and the audiometric testing procedures
- The purpose of annual training
Employees shall be provided with a handout of, or direct link to, a copy of the OSHA noise standard (29 CFR 1910.95) and other handouts or links describing the University of Pennsylvania Hearing Conservation Program. Information provided in Appendix B 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.
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
Hearing Conservation Program Manual
EHRS Office and the EHRS Website
All non-medical records (such as work area and equipment surveys) will be maintained for a period of five years. Results of audiometric tests and medical evaluations performed for hearing conservation purposes as well as noise exposure documentation specific to employees shall be recorded and shall be a permanent part of an employee's occupational health record. These records are retained for at least the duration of the affected employee’s employment with Penn.
All records specified in this section shall be provided to employees, former employees, representatives designated by employees, and OSHA upon request.
A current roster of HCP-enrolled personnel and SEGs shall be maintained by EHRS and OM. The roster of HCP-enrolled personnel shall be updated periodically using both quantitative and qualitative hazard and exposure assessment techniques.
Appendix A: Basic Training Information for Employees and Supervisors
Employees and their supervisors must become aware of, and understand, the adverse effects of noise exposure 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 be familiar with the following information:
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 that 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, having to ask coworkers to repeat themselves during normal conversation, etc.).
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-of-thumb to follow is: "If you have to shout at arm’s length (approximately three feet) to talk face-to-face, you are probably being exposed to hazardous levels of noise."
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 sounds. Reducing intensity is usually accomplished by implementation of controls or by wearing personal hearing protection.
Each person must be able to properly wear and care for the particular types of hearing protection used in the workplace. 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 that wearing hearing protection makes it difficult to hear speech are probably in noise levels less than 85 dBA have likely already developed hearing loss.
Each person must know how to tell if they have been overexposed to loud sounds. Overexposure may occur even while wearing hearing protection. Earplugs and/or earmuffs alone may not be enough protection. Each time a temporary threshold shift occurs, a degree of permanent loss can result. The recognizable symptoms of overexposure are described as "dullness in hearing or ringing in the ears."
Appendix B: EHRS Training Outline
- The characteristics of noise
- How noise can damage hearing
- The signs and symptoms of hearing loss
- Consequences of hearing loss in everyday life
- Noise exposures that are hazardous (specific to department or SEG)
- Occupational noise exposures
- Non-occupational noise exposures
- Penn’s HCP policies
- Importance of the HCP
- Participation in the HCP as a condition of employment
- HCP as a benefit to employees
- Measurement of noise
- Personal dosimetry
- Area and equipment sound level measurements
- Engineering controls (implemented or planned) (specific to department or SEG)
- Administrative controls (specific to department or SEG)
- PPE: The types of HPDs (specific to department or SEG)
- How to correctly use HPD
- How to handle, store and replace HPDs
- Solutions for common problems and complaints related to HPD use
- Audiometric testing: purpose, policy and procedures
- The baseline audiogram
- Annual audiograms
- Understanding your baseline and annual audiograms
- Methods for protecting your hearing on and off the job
- Annual training requirement
- Questions and answers
Appendix C: Occupational Safety and Health Administration Standard 29 CFR 1910.95
A direct link to the OSHA Occupational Noise Exposure Standard is provided here for all employees, supervisors and departments.