The National Hearing Conservation Association has published a defense of the proposed changes, rebutting some of the arguments that are being put forward by business groups. The NHCA points out the shortcomings in the current policy:
This policy – established over 25 years ago in the absence of rulemaking or public input – does not require employers to implement feasible engineering and administrative noise controls until workers’ eight-hour average exposures reach 100 dBA or greater, which is ten times more intense than the current Permissible Exposure Limit of 90 dBA. The current policy has made noise the only regulated health hazard in which OSHA has failed to acknowledge the primacy of engineering controls, and has resulted in a substantial increase in risk of hearing loss for some American workers. The alternative exposure reduction method currently allowed by OSHA for eight hour average exposures between 90 and 100 dBA is the use of earplugs or earmuffs, which have been demonstrated to provide insufficient protection for many workers, if they are used at all.
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