OSHAs Revised RecordKeeping Rule

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OSHAs Revised Record-Keeping Rule

• by
• Paul L. Osley, PE, BCEE, CIH, CSP
• Principal Environmental Occupational Health
  Services

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The following presentation is a synopsis of the
information provided in the April 2006 Synergist
ArticleCounting Ears OSHAs Revised
Record-Keeping Rule for Hearing Loss Yields
Insightby Lee D. Hager
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Objectives

• Identify the limitations of historical
• (pre-2004) OSHA hearing loss record
  keeping/data
• Identify new rule (29 CFR 1904.10) record-keeping
  criteria

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Objectives

• Identify the power of post-2004 data and ability
  to begin to see true prevalence and incidence of
  noise-induced hearing loss in the American work
  force
• Virtual tour/demonstration of the new hearing
  loss data (since 2004) available at various
  Bureau of Labor Statistics (BLS) websites
• www.bls.gov/iif/oshsum.htm
• http//data.bls.gov/IIRC/
• http//data.bls.gov/GQT/servlet/InitialPage
• www.osha.gov/oshstats/

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Prevalence and Incidence What do those terms
mean again?
Im Glad You Asked !
How about a crash course in Biostatistics and
Epidemiology!
6
Crash Biostatistics/Epidemiology - Refresher
Course
7
Just Kidding ! ! !
8
Crash Biostatistics/Epidemiology - Refresher
Course

• Prevalence - total number of cases present
  during a specified time
• Incidence number of new cases developing in a
  population over some period of time

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HL Data Limitations (Pre-2004)

• Historically the IH Community has shared hearing
  conversation programs by benchmarking and
  comparison
• (see The Synergist, October 2002, pp. 32-33)
• However, it has been difficult to compare the net
  effect of programs and identify the real
  prevalence of work-related, noise-induced hearing
  loss in the work place.
• Why?

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HL Data Limitations (Pre-2004)

• Why?
• Because until 2004, the OSHA hearing loss
  record-keeping requirements in 29 CFR 1904.10 was
  a guideline rather than a regulation and
  hearing loss fell into a catch-all all other
  illnesses section of OSHAs record keeping rules

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Revisions to 29 CFR 1904.10

• Starting in 2004, established a clear and
  unambiguous criteria for clearly identifying what
  hearing loss configuration qualified as a OSHA
  recordable injury on the Form 300
• Established a unique location on the OSHA Form
  300 for recording hearing loss injuires

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Revisions to 29 CFR 1904.10

• In 2004, anecdotally, many programs reported
  significant increases in the number of hearing
  loss cases being reported under the new protocol
• While one years data will not reveal trends, it
  is likely that the change in 29 CFR 1904.10 has
  resulted in a three- to fivefold increase in the
  number of hearing losses recorded as compared
  with the previous rule

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Revisions to 29 CFR 1904.10

• Changes were implemented in two stages
• Stage 1 - Revisions to the recordable criteria
  were put into effect in 2003
• A recordable event was defined as
• A standard threshold shift as defined in 29 CFR
  1910.95 (OSHAs Hearing Conservation Amendment)
  of an average 10 dB change in hearing at 2,000,
  3,000 and 4,000 hz test frequencies but only if
  the standard threshold shift resulted in hearing
  threshold levels (absolute hearing ability) of an
  average of 25dB or worse at standard threshold
  frequencies

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Revisions to 29 CFR 1904.10

• Stage 1 (contd)
• By combining a shift criteria (standard threshold
  shift) with an impairment fence (25 dB hearing
  threshold levels), OSHA tried to ensure that the
  hearing losses reported on Form 300 were
  significant
• However, hearing losses meeting the new criteria
  and detected in 2003 were recorded on Form 300 in
  the all other illnesses category, making it
  impossible to assess the effect of the new
  criteria for that year

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Revisions to 29 CFR 1904.10

• Stage 2 Effective January 2004, a new location
  (Column M5) was added to Form 300 specifically
  for cases of recordable hearing loss
• Maintaining unique records for hearing loss will
  enable OSHA and IHs to track hearing losses
  detected in hearing conservation programs across
  industries
• The OSHA imposed new definition of recordable
  hearing loss on all jurisdictions (even those
  stat-plans that may have more stringent
  requirements), will over time should enable
  apples-to-apples comparison of rates of hearing
  loss across states and across industries

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OSHA Form 300
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Power of 2004 HL Data

• Compiled data for 2004 is now available, giving
  the IH world some insight as to both what the
  changes in the record-keeping rule may bring and
  the true prevalence and incidence of
  noise-induced hearing loss in the American work
  force
• Note data is available from 1994 forward, but due
  to the ambiguous classification criteria prior to
  2004 (i.e. all other illness) hearing loss is
  impossible to parse out

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Virtual Tour to the BLS Website
Hold on to Your Seats ! (One moment please)

• www.bls.gov/iif/oshsum.htm

Industry Injury and Illness Data
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Table 6 2004 OSHA Data
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Two New Web-based Tools for Analyzing
Occupational Injury and Illness Rate (IIR) Data

• Compute your companys own IIR for safety
  management purposes and compare to the industry
  rate at
• http//data.bls.gov/IIRC/
• Access IIR data by industry, demographic and case
  characteristics at
• http//data.bls.gov/GQT/servlet/InitialPage
• OSHA Inspection Data, select Frequently Cited
  OSHA Standards and look for noise
• www.osha.gov/oshstats

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Summary Conclusions

• Making hearing loss data publicly and widely
  available allows employers to view the net
  results of their hearing conservation program
  efforts in a new way. It enables benchmarking of
  hearing conservation program performance by
  comparing individual hearing impairment and
  recordability rates across and within industries.

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Summary Conclusions

• These data also provide the first truly useful
  information about the net effect of hearing
  conservation programs on a national basis. While
  arguments may conitue about the appropriateness
  of OSHAs new recordable hearing loss criteria,
  the ability to readily view hearing impairment
  should enable employers, industrial hygienists,
  hearing conservationists and OSHA to better focus
  their energies where the problem is clearly
  demonstrated to be greatest.

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Thank You !
Questions ?