ROCKVILLE, MD — In a letter dated October 30, the Mechanical Contractors Association of America (MCAA) has urged the Occupational Safety and Health Administration (OSHA) not to change its existing occupational noise exposure standard for construction. MCAA believes that the agency would better achieve its goal of reducing construction hearing loss cases by providing employers with training materials to better educate their workers about hearing loss.

MCAA provided the following comments on OSHA's advance notice of proposed rulemaking (ANPR) regarding the possible change:

The current occupational noise exposure standard for construction is more than adequate to protect construction workers from work-related hearing loss. When noise levels exceed the permissible exposure limit and engineering or administrative controls are implemented or the appropriate personal protective equipment is used, workers' hearing is protected. MCAA believes that hearing loss occurs in construction only when employers and/or employees fail to use established protective measures.

Compliance costs associated with the existing construction standard are not unreasonable and the standard is feasible for construction companies of all sizes. However, implementation of a hearing conservation program in construction, which is equivalent to that of the general industry standard, is not feasible. MCAA believes the transient nature of construction workers would make successful implementation of the standard impossible for construction companies of all sizes.

Construction workers constantly change employers, but often return to work for previous employers many times over the course of their careers. Employers would be compelled to administer initial audiograms to the same workers repeatedly, which would result in unreasonable and unnecessary costs. Further, says MCAA, the results of the initial audiograms would be worthless to employers when tested workers accept employment elsewhere before their annual audiograms are administered.

The purpose of audiometric testing is to evaluate hearing and identify hearing loss where applicable. To achieve this purpose, workers must be subject to regular and consistent testing practices over a sustained period of time. Again, because of the transient nature of construction workers, MCAA believes this method simply will not work.

Additional information is available from MCAA's director of safety and health, Peter G. Chaney, MS, CSP, at pchaney@mcaa.org (e-mail).

Publication date: 11/04/2002