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 Post subject: Hearing Conservation Program
PostPosted: Thu Feb 23, 2012 5:00 pm 
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I have a dozen facilities and we are currently implementing a new electrical safety program. A question arose regarding a hearing protection "requirement" suggested in the HRC quidelines. Many of our facilities do not require hearing protection, and thus don't require a program due to dB's and TWA's at a level below threshold criteria. Once we make it a "requirement" for electrical workers to wear hearing protection, will that subject us to a OSHA mandatory hearing conservation program for the entire facility? Has anyone had a similiar experience? If so, what was your outcome? Any help would be greatly appreciated.... This could get a little costly and time comsuming in the long run.


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PostPosted: Fri Feb 24, 2012 7:46 am 
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I don’t think mandating ear plugs for electrical workers requires a full hearing conservation program. However, you should provide training on proper care, usage and fit of ear plugs to those associates required to use them; this can be easily included in the arc flash training.

OSHA’s hearing conservation program requires employers to monitor noise exposure levels and identify workers exposed to noise at or above 85dB averaged over 8 working hours or an 8-hour time-weighted average (TWA). This exposure measurement is taken during a typical work situation. Exposure measurement must be repeated whenever changes in production, process or controls increase noise exposure. Annual training and audiometric testing is required for employees exposed to TWAs of 85dB and above.


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PostPosted: Fri Feb 24, 2012 8:16 am 
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I agree, if your facilities do not require a hearing conservation program because the sound level is below the 85dB level you do not have to implement one because of the mandated use of ear plugs for arc flash. You do have to have a program to train those required to use the ear plugs on the proper care and use of them in order to maintain compliance for safety equipment.


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PostPosted: Fri Feb 24, 2012 9:07 am 
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I believe the interpretation is coming from a footnote located below the 1910.95 Table G-16 Permissable Noise Exposures that reads "Exposure to impulsive or impact noise should not exceed 140 dB peak sound pressure. Further, 1910.95 (d)(2)(i) states that "All continuous, intermittent and impulsive sound levels from 80 decibels to 130 decibels shall be integrated into the noise measurements". This is located under the Hearing Conservation Program and Monitoring sections. In the unlikely event of an arc blast, the dB level could peak above this threshold for milliseconds and alter the TWA, thus the interpretation.


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PostPosted: Mon Feb 27, 2012 4:43 am 
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I don’t think this is an issue since arc flash is not part of your typical work environment. I believe the footnote is talking about how to calculate daily exposure that is comprised of different noise levels.

1910.95(d)(2) says, “all continuous, intermittent and impulsive sounds… shall be integrated into the noise measurement. Instruments used to measure exposure must be properly calibrated.”

As I interpret this, it means that the employer must actually measure associate exposure accurately; meaning that you can’t wait until it’s quiet to do the monitoring nor do you want to only measure the loudest noise. Requirements for establishing hearing conservation programs are based on measured, not potential, exposure.


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PostPosted: Mon Feb 27, 2012 10:01 am 
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Whats the difference between ARCPLUG (EAR) vs other earplugs? Does it really works?


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PostPosted: Mon Feb 27, 2012 10:31 am 
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Location: Great Bend, KS
Victor Quijano wrote:
Whats the difference between ARCPLUG (EAR) vs other earplugs? Does it really works?


From the published information, the Arc plugs offer an instantanous supression of sound in the event of an arc flash explosion and then reverts back to its normal "hear through" setting. Ear plugs are a constant supression & offer a steady state supression.

I have seen these models used in hunting applications but havent personaly heard any feedback on the electrical side. Just from online reviews, it seems that they are a good option for crews that need to communicate and hear eachother more freely.


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PostPosted: Thu Mar 01, 2012 8:06 pm 
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Victor Quijano wrote:
Whats the difference between ARCPLUG (EAR) vs other earplugs? Does it really works?


Victor, EAR is owned by 3M now. I'm not sure even 3M has data on how protective this device is when exposed to >140 dB. My personal thought is that electrical workers should be required to wear DUAL hearing protection (muffs and plugs). Even DUAL hearing protection is inadequate without another barrier such as an arc-rated arc flash suit hood (bee keeper style) to further reduce the noise energy. Check out Oberon's White Paper on Noise Level Hazard published in 2005.

Excerpt;
..... this testing indicates that with the sound projected directly into the ear through the hood fabric an ARC100 hood would reduce the sound level by approximately 75%. If the sound is projected directly at the hood shield window, i.e. at 90[font=Arial]º[/font][font=Arial]to the ear canal, the sound reduction would be[/font]approximately 90%.

FYI, the noise hazard level is not directly related to the predicted thermal energy (incident energy) of an arc flash. The short circuit fault current is more to blame for noise induced hearing losses attributed to an arc flash event.


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