When employers document how and when they implemented each of the elements of a Hearing Loss Prevention Program (HLPP) they may be better prepared to demonstrate compliance with applicable regulations.
In addition, good records may provide evidence to help an employer accurately track employees' hearing over time and, if necessary, record cases of work-related noise-induced hearing loss on the OSHA log of illness and injury, and/or respond to worker compensation claims.
Many companies adopt a philosophy of, “document everything”, while others keep records of only what is required. Despite the extra effort required to document all the actions that have been taken to reduce employee exposure to hazardous noise, doing so may help to strengthen the employer's ability to demonstrate the effectiveness of its hearing conservation program in the event of an inspection, audit, or program evaluation.
Consider whether hearing conservation program records will be maintained electronically or on paper or both and whether records will be held in a central database or at each location. A well-defined process that is consistently followed helps to reduce the likelihood of missing records and may increase the usefulness of the data.
For each type of information that is included in HCP records, the employer needs to decide who is responsible for capturing the data and who will be able to view the records once they are saved. Limiting access to records to those who need to review data for program management purposes helps reduce the possibility that records are compromised in some way, or that data is inadvertently modified or deleted.
Since hearing conservation program records may include confidential health information, it is recommended that these records be protected to help protect the privacy of individual workers and assure that only those who have the proper credentials have access to sensitive data. In addition, there may be applicable data or health privacy regulations governing the storage, access to, or transmission of information, so make sure to contact your legal advisor and ensure full compliance with any such rules and regulations.
For general industry, OSHA requires employers to keep an accurate record of noise exposure measurements for 2 years and audiometric test records for the duration of employment of the employees who are in the hearing conservation program.
The types of hearing test records to be retained include:
Access to all records must be provided to employees, former employees, representatives of employees and OSHA inspectors. When ownership of the company changes or employees are transferred to a new employer, the noise exposure and hearing test records described above must be transferred to the successor employer who must maintain them for time periods described above.
Employers must record cases of work-related hearing loss on a specific form, the OSHA 300 log, each time an employee's hearing test (audiogram) reveals that the employee has experienced a work-related Standard Threshold Shift (STS) in hearing in one or both ears, and the employee's total hearing level is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS. When the hearing loss of the employee meets these criteria, it is known as a Recordable STS. Employers must enter each case of Recordable STS within 7 calendar days after receiving information that a work-related event has occurred. There is an option to retest a worker within 30 days of the annual hearing test. If the retest confirms the STS, then it must be recorded within 7 days after the audiometric retest. If the employer later decides that the hearing loss is not work-related or if the employee’s hearing subsequently improves, the employer can line-out the entry on the OSHA 300 log. According to OSHA, if an event or exposure in the work environment either caused or contributed to the hearing loss, or significantly aggravated a pre-existing hearing loss, you must consider the case to be work related.
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3M Job Health Highlights (2003) (PDF, 176 KB)
The benefits obtained when employers carefully record what they are doing to prevent hearing loss are, in large part, proportional to the accuracy, completeness and accessibility of the documents.
Most decisions made by the people who manage HLPPs are dependent on the quality of the data kept by the employer. When the data contain errors or there is excessive variability, it can lead decision-makers to doubt the accuracy of the records and make it difficult to confidently manage their program. To help prevent that from happening, establish a robust process for keeping records and verify that the key people in the program are following that process. Each person who has access to HLPP records should be trained to look for indications that records are not accurate or do not reflect what has been done to implement the program. In addition, make sure to consult with your legal advisor to ensure that all applicable government rules and regulations are followed with respect to storage, access to, and transmission of personal and health information.
Records are most useful when they are complete and have been kept consistent over time. This is especially critical when it comes to audiometric test data. If the audiometric records indicate that an employee has experienced a Standard Threshold Shift (STS), the employer must conduct follow-up actions. If the STS is potentially recordable, key information is needed to determine if the hearing shift is due, at least in part, to workplace noise exposure. Missing records, inaccurate information, or gaps in the data make it very difficult for the audiologist or physician who reviews the records to make that decision, and the employer may have no other option but to assume that the hearing loss is work-related.
Although the security of records must be maintained, employers must make key records available to employees, their representatives, members of the hearing loss prevention team, and inspectors or representatives of regulatory agencies. To help maintain control of documents, establish a system in which a limited number of people who have direct access to the records can share copies of documents with others who need to view them.
NIOSH recommends that records of noise exposure measurements and hearing test records be retained for the duration of employment plus 30 years.
Consider keeping other records for the same period of time, including those related to:
In the US, the Health Insurance Portability and Accountability Act (HIPAA) specifies how health information must be protected and how employers and health care providers may share confidential health information. The privacy rules in HIPAA apply when employers share personally identifiable health information, such as audiometric test results, with other entities such as health care providers and health plans.
For an overview of obligations concerning U.S. privacy rules related to employers and employee health information, click here.
In addition, make sure to consult with your legal advisor to ensure that all applicable government rules and regulations are followed with respect to storage, access to, and transmission of personal and health information.
IMPORTANT NOTE: This information is based on selected current national requirements. Other country or local requirements may be different. Always consult User Instructions and follow local laws and regulations. This website contains an overview of general information and should not be relied upon to make specific decisions. Reading this information does not certify proficiency in safety and health. Information is current as of the date of publication, and requirements can change in the future. This information should not be relied upon in isolation, as the content is often accompanied by additional and/or clarifying information. All applicable laws and regulations must be followed.