Listen Up! New Noise Standards Coming To Construction
In its regulatory agenda published in May of this year, OSHA hinted it would pursue more aggressive noise protection standards for the construction industry.
Currently, the permissible exposure limit (PEL) for noise in construction where Federal OSHA laws apply is 90 A-weighted decibels over an 8-hour time-weighted average. It is expected that OSHA will want to make the construction industry’s noise-related standards comparable with general industry’s Hearing Conservation standard of 85 A-weighted decibels over the same 8-hour time-weighted average.
Why is OSHA pursuing this?
OSHA estimates that over 30 million workers in the U.S. are exposed to unwanted sounds (noise) at a hazardous level, which is why OSHA lists noise-related hearing loss as one of the greatest occupational health concerns in the U.S. for more than 25 years.
Presently, the construction industry does not have equivalent Hearing Conservation program requirements as observed by general industry. Besides the 85 A-weighted average over an 8-hour time-weighted average as a threshold into the program, Hearing Conservation in general industry also includes medical surveillance to establish baseline audiograms and annual audiograms for workers, and solutions must demonstrate feasible engineering and administrative controls before personal protective equipment (PPE, i.e., hearing protection devices or “HPD”) can be used.
There is no great surprise that noise is of concern in the construction industry, but it may be worse than generally perceived. In a presentation about hearing conservation in the construction industry in Dallas last year, Donald J. Garvey of the 3M Company revealed some alarming statistics.
Garvey announced, “Depending on the trade, one study of more than 1,300 noise measurements indicated approximately 70 percent of the construction workers had a full-shift time-weighted average exposure at or above the National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit of 85 dBA.”
Compliance could pose difficulties
Getting a time-weighted average of noise in construction is generally more than challenging in the construction industry compared to general industries such as manufacturing. Over the course of their normal workdays, typical construction workers do so many varying tasks with different materials and different tools in different environments. Most construction workers’ work environments constantly change.
Since the construction worker’s workplace is typically in a constant state of flux, it is difficult to get a reliable time-weighted average for noise. Researchers at NIOSH speculate that continuous monitoring of construction workers should be done for 14 days in order to establish accurate exposure readings for workers.
There is no way anyone will continuously monitor their workers for 14 days to establish noise levels and it isn’t likely that OSHA would require construction employers to do so.
What might the requirements look like?
It’s hard to know what OSHA’s methods for compliance with Hearing Conservation standards for construction might look like, but there are some theories for how the agency might establish compliance criteria.
Table method
For example, OSHA could establish a standard that matches noise exposures to specific tasks, and what to do to protect a worker based on how long the worker does the task.
T-Beam (formula) method
Another example is the Task-Based Exposure Assessment Model (T-Beam), where specific tasks and their duration are identified with sound levels established for each. After a number of tasks and information are documented, modeling of various combinations of tasks can be represented using the formula:
% Dose = (C1/T1 + C2/T2 +… Cn/Tn) x 100
Where:
- % Dose is the percentage of daily maximum allowable does (example: 85 dBA over an 8-hour TWA = 100%)
- Cn is the duration (expressed in hours) a worker spends adjacent to a specific sound level, and
- Tn is the allowable duration (expressed in hours) for the specified noise level.
Ceiling limit method
Ceiling limits might be a method to establish noise levels that cannot be exceeded at any time –not even instantaneous noise. For example, any noise detected over 85 dBA might be considered to be a noise overexposure and require engineering and administrative controls to be implemented before PPE.
If the Ceiling Limit method is used to gauge compliance, then OSHA should just go ahead and say all construction workers must be in a hearing conservation program because one hammer-strike against a nail would surely exceed the limit.
When might the new standard be established?
OSHA’s “Noise in Construction” is currently in the Pre-Rule stage, but there is pressure to get it to the Proposed Rule or Final Rule stage by the end of this year.
With a new Assistant Secretary of Labor for Occupational Safety & Health to be appointed by the new presidential administration next year, it may be midway through 2017 before any new rules by the agency are implemented by then. Therefore, OSHA is expected to put resources towards finalizing a new rule sometime in December.
Safety First Consulting helps businesses identify OSHA compliance issues in their workplaces, manage their safety programs, and we become accountable for the results. In addition to offering custom written safety programs for companies, Safety First Consulting provides required safety training, industrial hygiene sampling, noise sampling, and workplace inspections.
