"Good neighbors keep their noise to themselves."
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Alice H. Suter
Alice Suter and Associates
575 Dogwood Way
Ashland, 0R 97520
The fact that U.S. construction workers are exposed to hazardous levels of noise and sustain significant hearing impairments is not news. That these impairments are at least as great as would be expected from an industrial population became evident during the l960s and l970s. Estimated numbers of construction workers exposed to potentially hazardous levels of noise range from about 1/2 million to 750,000.
In the U.S. there are separate noise regulations for construction and general industry. The permissible exposure limits (PEL) and requirements for noise control are essentially the same, an 8-hour time-weighted average exposure level of go dBA with a 5-dB exchange rate between allowable duration and noise level. Engineering or administrative controls are required to be implemented above this level, and hearing protection devices (HPDs) must be issued and worn when exposures exceed the PEL. Both regulations require hearing conservation programs (HCPs) for overexposed workers, but there are two essential differences: (I) the noise regulation for general industry requires the initiation of HCPs at an action level of 85 dBA while the construction regulation does not use an action level, and (2) the general industry regulation gives detailed requirements for noise exposure monitoring, audiometric testing, HPDs, worker training and education, and record keeping, while the construction regulation has only a general requirement for "continuing effective hearing conservation programs" above the PEL. The construction regulation l926.101 merely mandates the use of hearing protection above the PEL and requires insert devices to be fitted or determined individually by "competent persons."
Current enforcement of these noise regulations is not rigorous, particularly in construction. Part of the problem has been a perceived lack of information about the noise exposures of construction workers, although several studies have been conducted over recent decades in the U.S. and Canada. A more salient reason for the lack of activity in this area is the impracticality of the usual approaches to hearing conservation programs in the construction arena. Mobility among construction workers, short periods of employment, and the consequent difficulty in record keeping and follow-up present daunting obstacles.
Data from the Worker Compensation Board of British Columbia, however, show hearing threshold levels that are better than would be predicted from workers' noise exposures, as well as improvements in population hearing levels over a period of nine Years. These findings are attributable to the success of the British Columbia hearing conservation program, one of the most important factors appears to be the centralization of records, as well as technician training and certification. In addition, workers carry with them a record of their hearing test data.
The use of hearing protection devices in U.S. construction workers has been very poor, although it has improved slightly in recent years. The percentage of workers using HPDs varies by trade. For example, operating engineers, whose exposures are relatively continuous, show considerably higher usage of HPDs than carpenters, whose exposures tend to be intermittent. By contrast, the majority of British Columbia construction workers report regular use of HPDs, which is related not only to a vigorous HCP, but to a positive safety culture which has been existence there for more than 20 Years.
The success of the British Columbia hearing conservation program provides incentive to conduct a program for construction workers in the U.S. Such a program has been initiated in the State of Washington.
There are approximately 25,000 employers and 172,000 construction workers in the State of Washington. Host of the employers hire less than ID workers at a given time, but the largest 200 employ 21% of the workforce. Almost all of the small employers are non-union, and of the total number of workers, only 31% are unionized. Because of the temporary nature of employment among union as well as non-union workers, hearing conservation programs, like other programs that require annual testing and coordinated record-keeping, have been difficult to implement. For this reason, all the major employee benefit programs in the industry, including certification and training programs, are organized as multi-employer programs, with each employer contributing funding according to how long a certain worker is employed. This hearing conservation program is being fit into the multi-employer model.
The program has been developed by the Washington State Building and Construction Trades Council under the supervision of the Building Trades Labor Management Organization. Personnel from the Center to Protect Workers' Rights and the University of Washington are also involved. It is a 5-Year project funded by the National Institute for occupational Safety and Health and the Center to Protect Workers' Rights.
There is a well-established history of labor-management cooperation in the Seattle area. For example, the Puget Sound Area Construction Safety Summit, a coalition of unions, employers, and owners in the construction industry totaling 420 individuals, meets regularly to promote safety and health in the industry.
The objectives of this program are to work with leaders in labor and management to develop a "common sense" hearing conservation program based on the British Columbia model. The resulting program is expected to serve all Washington State construction workers and employers, and it should be generalizable to all areas of the U.S. The basic elements include:
The program will be implemented and evaluated on a pilot basis in the Seattle area. Although it will concentrate on construction workers and employers with collective bargaining agreements, non- union employers and workers will be able to participate, and the program experience should relate to non-union as well as union construction. In the process of conducting the program, policies, procedures and funding mechanisms will be developed to institutionalize it so that it will be able to continue after the 5-year funding period.
Worker and supervisor training. This aspect of the program is based on a "train-the-trainer" model which will be carried out at existing training centers operated by the building trades, at vocational schools, or community colleges. Training will be provided to union-employer trainers, who will, in turn, train construction workers. The initial 8-hour training session will include a video, specially developed written materials, and hands- on training in the basics of noise measurement, simple noise control techniques, and the selection, fitting and use of hearing protection devices. The initial training sessions will be carried out by an audiologist and an industrial hygienist. The program will emphasize problems and solutions typical of the construction industry. Solutions may include repositioning noise sources, turning off equipment that is not in use, and attention to equipment maintenance. Each training center will have access to a Type II general purpose sound level meter and calibrator. Workers who have been trained will be issued a wallet-sized certification card.
Selection and fitting of hearing protectors. During the training program workers will be provided with a selection of several types of ear plugs, at least two ear muffs, and a sample communication system. Special emphasis will be placed on the use of hearing protectors that will be as conducive as possible to communication and the perception of warning signals. Construction sites are known for a multiplicity of warning signals, especially back-up alarms, and failure to hear these signals has undoubtedly contributed to the high rate of accidents and fatalities. This is one of the primary reasons why construction workers have resisted wearing hearing protectors, and yet, hearing loss also contributes to the failure to hear necessary signals. Every attempt will be made to provide trainers and workers with protectors whose attenuation is as uniform as possible across the frequency spectrum.
Audiometric testing. Construction workers will receive baseline and annual audiograms through hearing conservation contractors and the testing will be conducted by audiologists or CAOHC certified personnel. Tests will be administered on work sites via mobile testing, at the training centers, or at audiology clinics, and audiograms will be reviewed by an audiologist or physician. Workers who have been tested will receive a wallet- sized card. In addition, results of the test will be entered into a centralized data bank which will be kept by a contractor. Individual records in the centralized repository will be accessible by code.
Counseling. In addition to the training program, workers will receive counseling at the time of audiometric testing. Also, a contractor will maintain an Boo number which workers will be encouraged to use for any questions about noise effects, audiometric testing, and the use of hearing protection devices. In addition, there will be a "Family Reinforcement" program in which the labor-management health and welfare funds will send out information about hearing conservation to construction workers and their families and encourage them to use the 800 number for counseling.
Feedback and evaluation. Randomly selected individual workers will be queried after receiving audiometric testing to assess their understanding of their test results and the use of hearing protection devices. The use of hearing protection will be assessed by visits to the worksites. The relatively short follow-up interval will preclude any comprehensive audiometric data base analysis during the 5-year project. However, preliminary analyses will be conducted to identify STS rates and a foundation will be laid for more comprehensive data base analysis in future years.
The Building Trades Hearing Conservation Program in Washington State represents a major step forward in providing hearing conservation to a population that has been identified as "underserved" by NIDSH and professional groups for many years. The training program is scheduled to begin in December of 2000.
The author gratefully acknowledges the work of Dr. Knut Ringen in preparing the comprehensive proposal for this project, much of which is included in this paper, as well as the WSBCTC, other members of the steering committee, and the funding agencies: NIOSH and the Center to Protect Workers' Rights.