HEARING CONSERVATION POLICY

I. STATEMENT OF POLICY

It is PIVOT-GIS’s policy to provide a safe and healthful workplace for our

employees. We are committed to the reduction of hazardous noise where
feasible, the strict enforcement of hearing protection usage where required,
the provision for employee education, and the maintenance of a complete and
comprehensive hearing conservation program. It is PIVOT-GIS’s policy to
comply with all pertinent federal, state and local noise regulations. Each
member of the hearing conservation team must do his or her utmost to protect
the hearing of our workers.

II. PURPOSE AND OBJECTIVES

A. To protect the hearing of our employees, prevent permanent hearing

impairment, avoid negative psychological effects and fatigue, avoid
speech interference as a cause of accidents, and minimize workers’
compensation claims.
B. To comply with federal OSHA, state and local regulations, and to avoid
citations and/or penalties.
C. To maintain good community relations by minimizing noise from PIVOT-
GIS facilities.

III. HEARING CONSERVATION PROGRAM OUTLINE

All employees exposed to noise levels of 85 dB time-weight-average or above

on the job will be included in the hearing conservation program. The program
at PIVOT-GIS will include provisions for:

1. Noise Monitoring
2. Baseline (immediately upon hiring) and Annual Audiometric Testing
3. Appropriate Follow-up to Audiometric Testing
4. An Ongoing Hearing Protection Program
5. Annual Employee Education
6. Feasible Engineering Controls
7. Appropriate Record keeping

IV. RESPONSIBILITIES

A. CORPORATE MANAGEMENT

1. The Chief Executive Officer and the HSE Manager are responsible for the
adoption and implementation of this policy to include the budgeting of
funds required to ensure regulatory compliance with standards. They may
designate responsibilities within the facility to see that all employees are
covered for safety administrative purposes.
B. AUDIOLOGICAL CONSULTANTS

1. Audiological Consultancy firm (an outside professional hearing

conservation consultant) shall be saddled with the responsibility of
counseling PIVOT-GIS on the development of programs and standards
which are necessary for compliance with existing regulations and for
maintenance of an effective hearing conservation program. Their services
shall include:

a) Assistance in the training of, and advice/counsel to, PIVOT-GIS

personnel in the areas of audiometric follow-up, record keeping
systems, appropriate hearing protection options, and employee
education systems.
b) Evaluation of all audiograms performed by in-house personnel. The
Audiological Consultant will issue recommendations for employee
follow-up and any necessary referrals. Individualized employee
notification reports shall be provided.
c) Providing advice and counsel in the event of a worker’s compensation
claim for occupational hearing loss. In the event of litigation concerning
compensation, expert witness testimony shall also be made available if
required.
d) Providing PIVOT-GIS with information on audiometric data trends
relating to hearing conservation program effectiveness in each facility.
e) Providing additional consultation services as requested.

C. ENGINEERING CONTROLS

1. Maintain familiarity with feasible engineering controls as they relate to

federal and local regulations and the facilities hearing conservation
program.
2. Select new equipment and /or design new facilities with consideration of
noise generation and effects on the hearing conservation program.
3. Ensure that adequate funding is available to implement feasible noise
controls when new installations do not meet standards.
4. Provide assistance to facilities on noise control matters. The HS&E
Manager should be consulted on noise control when existing machinery or
processes are radically altered.

D. TRAINING COORDINATOR

1. Review corporate policies/guidelines for agreement with OSHA

regulations, current scientific progress, and feasibility of implementation.
Revise/update as necessary.
2. Advise and counsel facilities and corporate management on hearing
conservation policies, objectives and procedures.
3. With assistance from Audiological Associates, Inc., monitor hearing
conservation program effectiveness at division and local levels.
4. Provide information and assistance to facilities about noise monitoring and
noise control.
5. Noise Monitoring:
 a) Ensures that a complete and up-to-date noise survey is on record.
b) Ensures that noise monitoring is repeated on an annual basis and
whenever a change in production process, equipment, or controls
increases noise exposures enough to affect the hearing conservation
program.
c) Ensures that all areas that exceed 90 dBA** are posted with signs
indicating that hearing protection is required in those areas.
d) Provides a copy of all noise surveys for filing with the audiometric
records.
e) Retains noise survey records indefinitely.
f) Investigates noise control options with engineering as appropriate.
g) With facility management, implements a proper maintenance program
for noise control equipment and /or materials.

* NOTE: Annual or every two- (2) years is recommended.

* NOTE: OSHA requires hearing protection for all employees

when time-weighted-average exposures exceed 90
dBA.

1. Hearing Protection

a) With training coordinator, select an appropriate variety of hearing

protection devices from which employees may choose. Hearing
protection must adequately reduce the work place noise exposure
for each employee.
b) Ensure that a suitable variety of hearing protection is made
available to all employees included in the hearing conservation
program. Employees must have the opportunity to select their
hearing protection from a suitable variety.
c) With management, implement an enforcement program that
ensures
that hearing protection is correctly worn at all times within
designated areas, and for those employees who have shown a
Standard Threshold Shift (STS) in hearing.

2. Employee Training:

a) Ensure that each employee in the hearing conservation program

receives adequate training in hearing conservation on an annual
basis.
b) Post a copy of the Noise Standard and Hearing Conservation
Amendment (1910.95) in the work places, and ensures that the
standard and any related materials are accessible to effected
employees.

E. TRAINING COORDINATOR
1. Audiometric Testing:

a) Ensure on-time performance of audiometric tests,

including pre-employment and annual tests, appropriate retest, and
exit audiograms by a qualified service meeting all OSHA
requirements for audiometer calibration, audiometric test facility,
and tester qualifications. If a local clinic is used for pre-employment
or make-up/retest audiograms, test should be forwarded to
Audiological Associates, Inc. immediately for review.

i. Baseline audiograms should be conducted as a part of the pre-

employment physical exam and must be preceded by14 hours
of quiet (or supervised hearing protection use).

ii. Periodic audiograms must be conducted on an annual basis

thereafter. Since the annual audiogram is used as a monitoring
tool, the audiometric test may be conducted at any convenient
time throughout the work shift.

iii. Any retest must be conducted as soon as possible, per

Audiological Associates, Inc. recommendations.

b) Retain all appropriate audiometric records on file indefinitely.

2. Audiometric Follow-up:

a) Conduct appropriate follow-up as recommended by Audiological

Associates, Inc. Each employee should receive notification of test
results, per detailed instructions provided in the Audiometric
Reports. Notification should be documented by obtaining the
employee’s signature on the Hearing Test Report.

i. Employees with medical referrals should be reviewed by the

local PIVOT-GIS physician, and referred to a specialist at the
physician’s discretion.

ii. Employees showing an OSHA Standard Threshold Shift (a

significant change in hearing) must be notified within 21 days of
receipt of the Audio Logical Associates, Inc. report. Hearing
protection use is mandatory for these individuals, and fit/care
use of hearing protection must be checked by the Supervisor.
The employee must be refit and /or retrained in hearing
protection as necessary. A retest of employees showing STS
should be conducted (within 30 days of receipt of report), in
order to gain more information and determine whether the shift
is temporary or persistent in nature.
 iii. Employees in the “normal” category may be notified by sending
the Audiological report to the employee’s home or through inter-
office mail.

b) Notify supervisors and/or department heads regarding

recommendations, which may affect the employee’s type, size or use
of hearing protection. The supervisor is responsible for enforcing the
proper hearing protection procedures for that employee.

c) Retain appropriate documentation of all employee counseling and

follow-up.

3. Hearing Protection:

a. Ensure initial hearing protection fitting for each employee.

Monitoring of hearing protection fit and use should be conducted
periodically. A good time may be at the time of annual audiometric
testing.
b. Ensure initial training for each employee in the proper care and use
of his or her chosen hearing protection device.
c. Retain appropriate documentation regarding type and size of
hearing protection device (HPD) for each employee.

F. SUPERVISOR

1. Be familiar with existing noise levels in his or her particular work area and
with hearing protection policies.
2. Enforce rules on wearing hearing protection and taking periodic hearing
tests when required. Obviously, the supervisor must wear proper
protection and not allow visitors/management into a posted area without
insisting on the same hearing protection procedures that apply to others.

G. EMPLOYEE

1. Follow work rules dealing with hearing protection and periodic testing as
required.