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Disclaimer – This model policy does not constitute legal advice. Fire Departments using this policy as a model should consult with your department’s attorney for applicability in your state and to conform to and not conflict with existing companion policies or existing State or Federal laws. Contributor – Fairfield (CT) Fire Department SUBJECT - Hearing Conservation Program Introduction An effective hearing conservation program can prevent hearing loss, improve employee morale and a general feeling of well-being, and reduce the incidence of stress-related disease. OSHA standard 1910.95 Occupational Noise Standard requires that the employers provide a hearing conservation program for employees who are exposed to dangerous occupational noise levels. NFPA 1500 also requires fire departments to develop hearing conservation programs. Both OSHA and NFPA recognize that hearing protection may not properly integrate with structural firefighter protective clothing or “where the use of such protective equipment would create an additional hazard to the user.” (NFPA 1500, 1999 edition) It is the intent of the Fire Department Hearing Conservation Program to minimize exposure to dangerous noise levels during emergency response, equipment inspections and maintenance, and station activities. The Fire Department will use the following industry standard model to manage and abate occupational noise hazards in the workplace: 1. Engineering Controls – eliminate known problems through design 2. Administrative Controls – SOP’s 3. Personal Protective Equipment and Monitoring – provide PPE for uncontrollable situations Firefighters are exposed to the following noise hazards creating a risk of hearing loss or damage Exposed Employee Group 1. Fire Suppression Personnel • • • • • At Risk Noise Producing Activity Emergency Response Gas powered equipment operation Operation of pumps and vehicles Checking of apparatus (brakes, pumps) Radio Usage 2. Fire Maintenance Personnel • • • • Emergency Response Equipment maintenance activities Apparatus maintenance activities Radio Usage 3. Fire Prevention Personnel • • • • Emergency Response Radio Usage Alarm system testing Machinery/fire pump inspections 4. Fire Training Personnel • • • Emergency Response Radio Usage Training activities involving gas powered tools, apparatus and other equipment 5. Administrative personnel • • Emergency Response Radio Usage These are considered hazardous activities: 1. 2. 3. 4. 5. 6. Emergency response with lights and sirens Inspection and operation of power equipment (gasoline engine type) Operating apparatus and pumps Training Activities involving the above Apparatus Maintenance activities with excessive noise generation Emergency Scene activities, power tools, high pressure gas leaks, alarms and radios Due to the known noise hazards and many uncontrollable factors, the Fire Department considers all suppression, training, prevention and administrative employees at risk. Monitoring Repeated monitoring will be performed when changes in the work environment increase the levels of noise to which employees may be exposed. This may result from the arrival of new apparatus, tools or systems or the desire to reduce the level of protection required. In the event of repeated monitoring, all affected employees or their representatives will have an opportunity to observe noise monitoring procedures. Audiometric Testing of Personnel Audiometric testing will be performed initially upon hire and annually thereafter in accordance with the OSHA standard 1910.95. This program will be provided at no cost to employees. All testing will meet or exceed OSHA requirements and be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council of Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining and checking calibration and proper functioning of the audiometers being used. Engineering Controls The Fire Department recognizes that minimizing noise production is the best way to eliminate hazardous noise exposure. As new equipment and apparatus are purchased, the department will incorporate, where practical, noise reducing technologies. Administrative Controls Supervisors will be required to comply with and support this program. OSHA considers noise exposure levels as a serious hazard. Failure to utilize hearing protection devices when required is considered a serious policy violation by the department. Personnel that refuse to wear provided protection will face disciplinary action in a progressive manner. Basic Requirements All personnel shall wear hearing protection devices in accordance with the following chart when HPD usage is required. At no time should the level of personal protection for firefighting be lowered due to the usage of hearing protection at scene of fires or other emergencies. Hearing Protection Requirements for personnel by hazardous activity 1. 2. 3. 4. 5. 6. 7. Activitity Emergency response with lights and sirens Inspection and operation of power equipment (gasoline engine type) or fixed equipment. Operating apparatus, compressors, and pumps Prevention inspections with exposure to audible alarm systems noise (ie. testing alarms) Training activities involving all of the above Apparatus maintenance activities with excessive noise generation Emergency scene activities, power tools, high pressure gas leaks, extrications, and alarms 8. Structural Fire Fighting activities HPD Usage Required Required Required Required Required Required NOT required but Recommended - only use if it does not interfere with other PPE Not Required – only use if it does not interfere with other PPE If personnel cannot safety wear hearing protection, they will not be required to wear it at emergency scenes. (i.e. pump operator working at a car fire on a limited access highway due to scene safety concerns) HPD Selection and Use The Fire Department provides a variety of hearing protection to all personnel at no cost. The department will initially offer a choice of the following hearing protectors which meet minimum noise reducing requirements (N.R.R.) of OSHA. Muff Style • E.A.R Model 3000 ear muff – all riding positions of apparatus • David Clack Headset (integrated radio/muff) Plug Style • Moldex Rockets Reusable Ear Plugs – N.R.R. 26 db • Fusion Reusable Corded Earplugs N.R.R. 27 db • Howard Leight QB2hyg Supra-Aural N.R.R. 25 db • E-A-R flex 28 N.R.R.28 db Training, selection and initial fitting of HPD’s will be provided by qualified personnel on an annual basis. Due to advances in technology, the department will continue to purchase newer styles of HPD’s which meet minimum OSHA requirements and offer them to personnel as requested at no cost. Training and Education The Fire Department will provide initial and annual training to all personnel as required by the standard. The training will at a minimum include the following topics: • • • The effects of noise on hearing. The purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting, use, and care. The purpose of audiometric testing and an explanation of test procedures. Access to Information and Training Materials As a part of the Hearing Protection Program, the department will: • • • Make copies of the noise standard available to affected employees or their representatives and post a copy in each station. Provide affected employees with any informational materials pertaining to the standard that are supplied to the employer by OSHA. Provide, upon request, all material relating to the employer's training and education program to OSHA. Record Keeping The purpose of OSHA recordkeeping regulations is to assist employers in recognizing and correcting workplace hazards by tracking work-related injuries/illnesses and their causes. Requirements according to the noise standard are: Exposure Measurements Employers must maintain an accurate record of all employee exposure measurements. These records must be retained for two years. Audiometric Test Records The employer must retain all employee audiometric test records. These records must include: o Name and job classification of the employee. o Date of the audiogram. o The examiner's name. o Date of the last acoustic or exhaustive calibration of the audiometer. o Employee's most recent noise exposure assessment. The employer must maintain accurate records of the background sound pressure level measurements in audiometric test rooms. These records must be maintained for the duration of the affected worker's employment. Access to Records All records required by the noise standard must be provided upon request to: o employees, o former employees, o representatives designated by the individual employee, and o OSHA. Transfer of Records Employers who cease to do business must transfer to the successor employer all records required by the noise standard. The successor employer must retain these records for the remainder of the periods described previously. END