Workplace HR & Safety Awards - helping professionals manage the total workforce experience

New Labeling Improves Hearing Protector Fit, Training

By Brad K. Witt MA, CCC-A

The Environmental Protection Agency (EPA) recently announced proposed changes to the way it rates and labels the performance of hearing protectors. After thirty years of appearing on every hearing protector package, the noise reduction rating (NRR) is undergoing an extensive overhaul. The proposed new NRR is expected to be more accurate than the previous standard, but also more confusing for many safety professionals.

Shortly after its introduction in the late 1970s, it was obvious that many workers in the “real world” of noise exposures do not achieve the same level of attenuation from hearing protectors as indicated on the NRR label. Assuming there was something inherently wrong with the hearing protectors or their EPA rating, a number of “de-ratings” have been devised and touted as remedies to make the NRR more realistic:

• Subtract 7 dB
• Divide the NRR by 2
• Divide the NRR by 2 and subtract 7
• Subtract anywhere from 25% to 70% of the NRR face value

But all of these de-ratings proved to be just as arbitrary, and in many cases, just as incorrect, as the original NRR rating they were trying to remedy.

Protection Depends on Training
With its new NRR, the EPA proposes publishing a two-number range of expected protection, rather than a single-digit estimate. (See Figure 1.) The high and low numbers on that range reflect the variety of protection levels that users might achieve, depending upon how well they fit the protector:

• The lower number shows how much attenuation is possible for minimally trained users to achieve or exceed.

• The higher number shows how much attenuation a few motivated proficient users can achieve or exceed.

Figure 1. EPA’s proposed new NRR will provide a range of expected protection, based upon fit and training.

How much protection are your workers obtaining from an earplug with a new NRR range of 18-32 dB? That depends upon your actions as a safety manager. The manager who provides hands-on training, and in particular one-on-one training, in the proper fit and use of hearing protection, and monitors compliance, will be helping workers move closer to the high end of that range. An employer who simply passes out earplugs to workers, and then leaves them to fend for themselves, will be inadvertently pushing noise-exposed workers toward the lower end of the NRR protection range. New fit-testing technology is also now available to help employers measure exactly how much protection their workers achieve.

Rule Includes Device Testing Changes
A new NRR range is not the only change in EPA’s proposal, currently working its way through public comment and review. Other changes include the following:

• When tested in the laboratory, hearing protectors will now be fit by the test subjects themselves (after training), rather than fit by the experimenter. This is intended to make the results more representative of actual user fit, rather than idealized laboratory fit.

• Electronic earmuffs will be tested in their active and passive mode. Previously, the NRR did not recognize this technology, and these protectors could only be tested with their electronics turned off.

• Periodic retesting every five years to ensure products in the market retain their protection values.

• New requirements for manufacturers to submit their test results to EPA. Previously, EPA never saw the test results.

Final Rule Expected in 2010
When can we expect to see these changes appear at the workplace? It may be a few years. Knowing that regulatory change for hearing protection moves slowly (the last regulation lasted 30 years), EPA is carefully building a consensus among manufacturers and end-users. The public comment and review period has been extended to early November, meaning a final rule would be published in 2010 at the earliest. Changes to hearing protector packaging would likely appear during a phase-in period lasting 2-5 years.

What Employers Should Do Now
Although the proposed EPA changes will take several years to appear in the workplace, there are definitely some things employers can do now to prepare:

• One-one-one training. Research studies continually show the value of individual or small-group training for fitting hearing protection. In one landmark study, workers who merely had two minutes of individual fit training increased their protection levels by nearly 15 dB.

• Fit-testing of hearing protection. Several fit-testing systems are now available, allowing employers to measure the personal attenuation rating of any earplug worn by any worker. Fit testing provides immediate feedback whether a worker has a correct fit or not.

• Offer a variety of hearing protectors. Field studies show that workers who were poorly protected with one model of earplug often have a dramatic increase in attenuation just by using a different model of earplug. Ear canals come in different shapes and sizes, and an employer who offers a variety of suitable hearing protectors increases the likelihood of a good fit among the noise-exposed workers, rather than just offering one model for all workers.

Conclusion
EPA’s new proposed NRR, if enacted, will focus attention on proper fit and training in ways that the old NRR never addressed. And while that may catch some unprepared safety professionals by surprise, the end result will be better protection for noise-exposed workers, and less noise-induced hearing loss.

Useful link related to this article:
Hear Tomorrow: A Personalized Approach to Hearing Conservation
http://www.congress.nsc.org/nsc2009/public/SessionDetails.aspx?SessionID=265

Brad Witt is the director of Hearing Conservation at Sperian Hearing Protection in San Diego. He has a bachelor’s degree in Communication Disorders from Brigham Young University, and a master’s degree in Audiology from Northwestern University. For 14 years, he managed a hearing conservation practice in California, providing OSHA-standard services at 175 locations. Witt has served as president of the National Hearing Conservation Association, and in his present position, manages the Acoustical Laboratory at Howard Leight. He provides training to professional groups in all aspects of hearing conservation. He has presented more than 150 hearing conservation seminars in 15 countries on behalf of Sperian Hearing Protection.