Audiometric Testing
If a site is non-compliant and has not been doing annual audiometric testing for YEARS, however employees did receive baseline audiometric tests as part of their pre-employments, should an upcoming audiometric test be considered a new baseline, or should an upcoming audiometric test be compared to the original baseline from years ago?
Comments (19)
In general, the annual audiogram must be compared to your original baseline, regardless of how many years you've "skipped". It may be hard to determine if any hearing loss discovered is work-related and/or when it occurred, but there is an exception to this, as far as the only time a baseline can be revised, which is shown below:
1910.95(g)(9)
Revised baseline. An annual audiogram may be substituted for the baseline audiogram when, in the judgment of the audiologist, otolaryngologist, or physician who is evaluating the audiogram:
1910.95(g)(9)(i)
The standard threshold shift revealed by the audiogram is persistent; or
1910.95(g)(9)(ii)
The hearing threshold shown in the annual audiogram indicates significant improvement over the baseline audiogram.
I could not explain it better than Drew did!
A slight curve to the above. Through noise abatement, hearing protection was no longer required, and for 4 years, there were no hearing tests due to not being required. Now new equipment has been added and it is likely hearing protection will be required (testing underway now). Will (g)(9) still apply?
I agree with all the Drew said. Original baseline is what their baseline was originally. Annual audiometric testing looks for shifts in the original baseline.
First of all pre-employment audiometric testing is very valuable for establishing if the employee needs special accommodation in noisy areas and whether they started the job with hearing loss. This helps mitigate workers comp claims of hearing loss while working at you company if they had the loss before starting work. Also, it is the baseline throughout worker employment with a particular company.
Also, remember that OSHA compliance gets you a D on your liability report card. The ACGIH TLV, which OSHA references as what should be used in their Annotated PELs document, is much more stringent (85 dBA TLV compared to 90 dBA OSHA PEL and 3 dB exchange rate as opposed to 5 dB for OSHA). There have been many times in my noise dosimetry jobs where the OSHA limits are not exceeded while the TLV is.