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Guidelines for a Legally Acceptable CAOHC Industrial Hearing Conservation Program

Hearing & noise guidelines for CAOHC legally acceptable industrial hearing conservation program.
By: Robert M. Traynor, Ed.D., MBA, FNAP and Garry G. Gordon, MS, Contributors

Originally published in Workplace Material Handling & Safety

The Council for Accreditation in Occupational Hearing conservation (CAOHC) is a non-membership organization created in 1973 to collaborate with nine professional organizations that have a common interest in all aspects of occupationally related noise-induced hearing loss (NIHL). Through the mission to advance best practices in occupational hearing conservation worldwide through credentialing, education and advocacy, the organization has had a significant impact in the reduction of occupational hearing loss, which has decreased by 59% since 2004.1


Hearing damage is a serious occupational hazard in professions that expose workers to loud impulses or continuous noise. More than thirty million employees work in hazardous noise levels and are found nationwide in all segments of industry. Of course, most occupational hearing loss occurs gradually, over the course of years, making the impairment difficult to perceive until it is too late. However, with appropriate hearing conservation measures, workplace hearing loss is completely preventable. Providing noise anal- ysis, noise control, audiometric monitoring and hearing protection makes a huge difference for workers involved in noisy occupations. Often totally overlooked, recreational noise may have a significant impact on the amount of hearing loss seen in industrial programs. Whatever the cause, NIHL is irreversible and creates multiple issues over time, such as high frequency hearing loss, ringing in the ears (tinnitus), difficulty understanding others (especially in noisy situations), as well as social withdrawal and communicative frustration that often leads to major effects on family life.



Who should be Enrolled in the Program?

OSHA and the other agencies mandate that workers exposed to noise levels over a specific time-weighted average (TWA) throughout their shift should be enrolled in a hearing conservation program. TWA2 is the combina- tion of all the sound intensities that the worker is exposed throughout the work shift. These exposures are limited to 85 dB (A) over an 8-hour shift. Exposures at or above that level require the implementation of a hearing conservation program. When the worker reaches a Permissible Exposure Level (PEL) of 90 dB (A) they are required to use hearing protection devices. The specifics of these programs are out- lined by OSHA, Mine Safety and Health Administration (MSHA) and Federal Railroad Administration (FRA) regulations. Best practices are offered by the National Institute for Occupational Safety and Health (NIOSH).

Elements of a Hearing Conservation Program


To be effective, a hearing conservation program must have the company’s management team on board. Secondly, efforts must be made to enlist worker support for the program. (It’s a good idea to have worker representation in the planning stage.) A third, often overlooked, element is a baseline hearing test for new worker, as well as annual assessments for workers exposed to a TWA of 85 dB (A) OSHA Presumptive Rule (OSHA, CFR 1904.5)3 states that it is presumed all injuries and illnesses result from events or exposures occurring in the work environment and the company must prove that the injury or illness is caused by an outside source.


Without a baseline hearing assessment, the company assumes all responsibility for any hearing loss the worker possesses at the beginning of their employment unless they can prove that the impairment existed prior to employment. Without annual assessments, the company assumes all responsibility for any hearing loss after the first baseline assessment. With no hearing conservation program, the company is liable for any hearing loss incurred by the worker prior to initial employment and subsequently during the life of his or her employment.

The major components of the program include the following:

  1.  Noise Measurement. The noise’s locations, types and intensity must be assessed, along with sources, such as specific machines or operations.
  2. Noise Control. Noise is controlled by altering the source, the path or the receiver. Reducing noise at the source involves engineering controls. Reducing the path of the noise involves administrative controls by rotating workers through different tasks to limit their exposure to the noise. Finally, if engineering and administrative controls are unsuccessful, then noise at the receiver must be reduced through the use of hearing protection devices (HPDs).
  3. Hearing Protection. HPDs must be chosen to provide the correct amount of hearing protection without interfering with essential communication. HPDs must fit properly and be used correctly – so workers should receive instructions on its use.
  4. Audiometric Monitoring. This allows for the assessment of the workers to determine if they have suffered hearing loss from their work environment. 
  5. Worker Training and Motivation. Workers must be trained about NIHL, audiometric monitoring and the use of hearing protection devices. 
  6. Recordkeeping. The occupational conservationist, under the director of the supervisor, maintains the records of the hearing conservation program and makes them available for inspection upon request by inspectors from OSHA, MSHA and FRA. 
  7. Program Evaluation. The program should be regularly evaluated in each of the seven areas to determine efficiency and validity.

Hearing conservation programs do a great job of reduc- ing NIHL. CAOHC offers Occupational Hearing Conservationist (OHC) training by Certified Course Directors in the daily operations of hearing conservation programs. These courses are available from and others. WMHS

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Robert M. Traynor, Ed.D., MBA, FNAP practiced audiology and interoperative monitoring for 46 years, has lectured on audiology topics in more than 40 countries and was a Senior International Audiology Consultant to a major hearing aid manufacturer. He is currently an Adjunct Professor of Audiology at the University of Arkansas for Medical Sciences and Salus University and is a Fellow of the National Academies of Practice. His text, Strategic Practice Management, 3rd Edition, co-authored with Dr. Robert Glaser, is used in most audiology training programs. Through Robert Traynor Audiology, LLC, ( he consults, does forensic audiology, and is CAOHC Course Director and Professional Supervisor in Fort Collins, Colorado.

Garry Gordon, MS. is the CEO/Owner and Audiologist/ Instructor at EAR Inc in Boulder, Colorado. Gordon has served well over 4,000 major medical, audiological and indus- trial accounts and trained a network of 500+ recreational and industrial providers who market high-quality hearing protection. Gordon has also written about hearing loss for publications and presentation, including Outdoor Life, Field and Stream, Trap and Field, Sporting Clays, ENT/Audiology Japan and the International Symposium of Sports Medicine held in Moscow, Russia (

¹ U.S. Bureau of Labor Statistics Moriz, C. (2014).]

² Noise Control and Measurement. In Hutchinson, T., & Shultz (Eds), Hearing