SNAPON INCORPORATED STANDARD ON HEARING CONSERVATION Issued By:.DOC Approval: Page 1 of 9
1.0 SCOPE It is Snapon Incorporated's policy to have in place a management system that drives all operating units to continual improvement in environmental quality and protection of employee health and safety through the application of best management practice. Best management practice is the minimization of impacts from operations and production by optimizing all of the following: Inputs Processes, Procedures, Practices Prevention and Beneficial Reuse of Waste Minimization of Air Emissions, Wastewater Discharges and Disposal of Waste From Processes and Packaging Safe and Healthy Work Environs This standard applies to all semiautonomous business units, manufacturing plants, distribution centers and repair or service centers worldwide. 2.0 BACKGROUND (Driven by SEQ Industrial Hygiene Assessments) As a consequence of the manufacturing processes employed in producing hand tools, power tools, sheet metal products and electrical products, Snapon employees may be exposed to noise levels which exceed values experienced in nonindustrial settings. Snapon Incorporated and the Manufacturing and Technology Division recognize that uncontrolled occupational noise can cause hearing loss and increase worker susceptibility to other work place safety problems. Safety and health problems such as temporary and permanent loss of hearing sensitivity, physical and psychological disorders, interference with speed and communication and disruption or reduced job performance have been attributed to excessive noise intensities. Snapon Incorporated is committed to reducing noise exposures in its work places to levels conforming to the requirements of the Occupational Safety and Health Administration (OSHA) Noise Regulation 29 CFR 1910.95. Snapon believes that permanent hearing loss is preventable with continued use of proper hearing protection and, where feasible, reduction of work place noise levels by engineering intervention. The Corporation believes that an aggressive hearing conservation program will benefit our employees throughout their lifetimes as well as further our legal and moral obligation of providing the best work place environment possible. Senior Management of Snapon Incorporated has delegated authority and responsibility for worker safety and health issues to the Plant or Facility Manager. This delegation is based upon the premise that the locus of control is most productively administered at this level at each operating entity. Additionally, the Corporation has provided the Safety, Environment and Quality Group function as a resource to the operating entities in a role of monitor and advisor and as the coordinator of environmental, industrial hygiene and safety programs throughout the Corporation. The 29 CFR 1910.95 regulation defines an Action Level (AL) as a dose of 50% of the Permissible Exposure Limit (PEL). The PEL is 90 dba, and the AL is 85 dba on an eight hour time weighted Page 2 of 9
average basis. Where work place noise levels exceed the 85 dba AL, the plant or facility will initiate and continue a hearing conservation program which meets the requirements of. 3.0 IMPLEMENTATION Program Elements OSHA Reference A. General B. Noise Monitoring 29 CFR 1910.95(d)(e)(f) C. Audiometric Exams 29 CFR 1910.95(g)(h) D. Personal Protective Equipment 29 CFR 1910.95(i)(j) E. Education and Training 29 CFR 1910.95(k)(l) F. Recordkeeping 29 CFR 1910.95(m) A. General All employees exposed above the 85 dba AL (eight hour time weighted average) must have hearing protection provided at no cost to the employee. Additionally, employees exposed above 87 dba (eight hour time weighted average) or those who have been documented to have experienced a standard threshold shift are mandated to wear hearing protection. Snapon's Corporate Policy is to encourage all employees exposed at the AL or above to wear hearing protection. B. Noise Monitoring The Director, Safety, Environment and Quality Group or his designee shall monitor representative noise levels at each facility annually. Noise monitoring shall include personal exposures as well as area exposures. Results of such monitoring will be reported to the Facility Manager as part of the annual industrial hygiene appraisal. Accordingly, Corporate governance on work place exposures are as follows: i. 95 dba and Above Definite overexposure situation citable by OSHA as a serious violation. Where feasible, engineering and administrative controls must be implemented, and hearing protection is mandatory until exposure levels are reduced. Participation in hearing conservation program is required. ii. 90 dba Action level has definitely been exceeded, and hearing conservation program participation is mandatory. iii. 85 dba The action level may or may not have been exceeded, but employees shall be included in hearing conservation program. iv. Below 85 dba No action indicated. Frequently employee noise exposure varies with duty assignments during an eight hour work shift. OSHA has allowed for computation of the eight hour exposure by prorata treatment of the individual exposures using Table G16A. Page 3 of 9
Duration, Hours Per Day dba Slow Response 8 90 6 92 4 95 3 97 2 100 1.5 102 1 105.5 110.25 or Less 115 i. Noise is constant over entire shift: D = 100 (C/T) Where D = % of PEL C = Length of Work Day (Hrs.) T = Exposure Allowed in G16A ii. Noise varies throughout the shift: D = 100 (C 1 /T 1 + C 2 /T 2 + C 3 /T 3... + Cn/Tn) Where D = % of PEL Cn = Total Time of Exposure (Hrs.) at a Given Level Tn = Allowable Exposure in G16A C. Audiometric Exams Audiometric examinations should be performed by certified or licensed individuals. Examinations may be conducted by licensed audiologists or otolaryngologists or technicians certified by the Council of Accreditation in Occupational Hearing Conservation. If technicians administer the exam, they must be responsible to an audiologist, otolaryngologist or physician (29 CFR 1910.95(g)(3). All problem audiograms shall be reviewed by a physician. Recordkeeping of audiograms must include all of the following (29 CFR 1910.95(m)(2)(ii)): i. Name and Job Classification of Employee ii. Date of Audiogram iii. Examiner's Name and Credentials iv. Date of Last Acoustic or Exhaustive Calibration of the Audiometer Page 4 of 9
v. Employee's Most Recent Noise Exposure Measurement vi. Measurements of Background Sound Pressure Levels in Test Room Baseline audiograms are required within six months of an employee's first exposure at or above the action level unless the facility utilizes a mobile test van for testing, in which case the test must be performed within one year of exposure onset. Additionally, baseline audiograms shall be preceded by at least 14 hours without exposure to work place noise, and employees shall be advised to avoid high level nonoccupational noise in the 14 hours preceding an audiogram. All employees exposed to the 85 dba TWA action limit shall be given annual audiograms which are to be evaluated against the baseline as follows: i. Annual audiograms shall be compared to the employee's baseline to determine if a standard threshold shift has occurred per 1910.95(g)(10). If an audiogram shows a shift, then the employee may be retested within 30 days. Problem audiograms are to be reviewed by a licensed audiologist, otolaryngologist or physician. Employees who have experienced a standard threshold shift shall be notified within 21 days of the determination unless a physician has determined that the shift is not work related or aggravated by occupational noise exposure. The following requirements apply when a standard threshold shift has occurred: i. Employees not using hearing protectors shall be fitted with hearing protectors, trained in their use and care and required to use them. ii. Employees already using protectors shall be refitted and retrained in the use of protectors and supplied with protectors offering greater attenuation if necessary. iii. Employees shall be referred for a clinical audiological evaluation or an otological examination, as appropriate, if additional testing is necessary or if it is suspected that a medical pathology of the ear is causing or aggravated by the hearing protectors. iv. The employee is informed of the need for an otological examination if a medical pathology of the ear is unrelated to the use of hearing protectors. v. If subsequent audiograms indicate that the threshold shift was not persistent and the employee is not exposed to 90 dba or higher TWA noise levels, the employee should be notified of his/her new status and the wearing of protectors then become optional. An annual audiogram may be substituted for or become the new baseline audiogram when, in the judgment of a licensed audiologist, otolaryngologist or physician, the standard threshold shift is persistent (permanent) or the standard threshold appears improved over that of the baseline audiogram. A standard threshold shift is a change in hearing threshold relative to the baseline of an average 10 db, after compensating for the contribution of age (presbycusis), at 2,000, 3,000 and 4,000 hertz. D. Personal Protection Equipment Page 5 of 9
Each facility shall have at least a selection of three hearing protectors as part of the hearing conservation program. Hearing protector attenuation as determined by noise reduction rating is governed by Table I. Hearing protectors must attenuate exposure at least to an eight hour TWA of 90 db for employees who have not experienced standard thresholds. Attenuation at least to an eight hour TWA of 85 db is required for employees who have been identified as having a standard threshold shift (1910.95(g)(10)). Hearing protector attenuation requirements are to be reviewed at the time of the annual audiogram review and protectors upgraded to the extent required based upon audiogram results. E. Education and Training Each facility shall provide training for all employees exposed to and above the eight hour TWA AL. The training shall be updated and documented annually. The training shall include all of the following: i. Training in the care and proper use of hearing protectors. ii. Training in proper fit techniques of protectors. Advantages and disadvantages and attenuation ratings of supplied protectors. iii. Effects of noise on hearing. iv. Purpose of audiometric testing and an explanation of the test procedure. v. Each facility shall have available and post a copy of 29 CFR 1910.95 in a conspicuous place where employees and/or their representatives may gain access for informational purposes. F. Recordkeeping Requirements i. All employee exposure records shall be kept for 30 years. ii. All employee audiograms shall be retained for 40 years and include: Name and Job Classification Date of Audiogram Examiner's Name and Credentials Date of Last Instrument Calibration Most Recent Noise Exposure Relevant Background Pressure Levels in the Audiometric Test Room iii. Employees, employee representatives and the Assistant Secretary of Labor may access all records within the restriction limitations of 1910.20(a)(e). Page 6 of 9
TABLE I To ensure that the type of hearing protector used by employees is adequate, it is necessary to estimate the inear noise levels when wearing the protection. Inear eight hour time weighted average levels must be less than 90 dba (85 dba for employees with a standard threshold shift) when wearing the protectors. Methods included in Appendix B of the OSHA Noise Standard use the Noise Reduction Rating (NRR) to estimate inear levels. The packaging of most hearing protectors is labeled with the NRR. Other methods of estimating attenuation are included in the Noise Standard and can be used. However, the EPA method is the most convenient. Higher NRR values indicate greater noise reduction potential provided by the protectors. The actual protection experienced by the employee will depend upon the proper fitting and wearing of the device. The minimum NRR required for the protectors can be determined through use of the simple equation shown below. For example, if the highest measured time weight average level (TWA) was 95 dba, the minimum acceptable NRR for the protectors would be: NRR = (TWA + 7) 90 = (95 + 7) 90 = 12 For an employee who has experienced a standard threshold shift, the minimum acceptable NRR would be: NRR = (TWA + 7) 85 = (95 + 7) 85 = 17 The NRR should be used only as a guide. The actual inear noise level will depend upon how the protector is worn. In real life, the noise reduction is usually significantly less than that implied by the NRR. However, it has been demonstrated that, with proper training and supervision, the effectiveness of the hearing protector can be dramatically improved. the minimum acceptable NRR's for various noise exposures are listed on the following page. They have been calculated by the preceding formulas. Page 7 of 9
TABLE I (CONTINUED) Eight Hour TWA NRR for an 85 dba InEar Level NRR for a 90 dba InEar Level 85 86 87 88 89 7 8 9 10 11 90 91 92 93 94 12 13 14 15 16 7 8 9 10 11 95 96 97 98 99 17 18 19 20 21 12 13 14 15 16 100 101 102 103 104 22 23 24 25 26 17 18 19 20 21 105 106 107 108 109 27 28 29 30 31 22 23 24 25 26 Page 8 of 9
Date REVISION LOG Revision Statement 12/01/95 Initial issue. 02/03/97 Annual review and revisions to expand scope of the EH&S Management System to Non U.S. entities. 12/21/98 Annual review. 12/13/99 Annual review. 03/06/00 Reconciliation with external audit recommendations. 05/15/00 Update after initial audits for certification. 01/15/01 Annual review and revision. Administrative and other minor changes. 12/28/01 Annual review and revision with changes from MTS to SEQ due to Corporate realignment. 07/01/02 Periodic review. 01/01/03 Annual review and revision. 01/01/04 Annual review no changes. 09/01/05 Annual review and revision to reflect organizational and system changes. All pages affected. Page 9 of 9