Who's who on NRR Updates
By Elliott Berger,
11/25/2008
Changing the NRR regulations is no simple task. A variety of agencies with various expertise and responsibilities are involved in the process. Here's a brief rundown of who is involved, and their role in the update.
Hearing Protector Labeling Regulation
Workplace Applications
Best Practices
Standards
Hearing Protector Labeling Regulation
EPA (Environmental Protection Agency) – Congress empowered the US EPA in the Noise Control Act of 1972 to label all noise-producing and noise-reducing devices. The EPA began this process, but its Office of Noise Abatement and Control (ONAC) lost funding and associated staffing in the early 1980s.
The only regulation that was promulgated on labeling noise-reducing devices was for hearing protection, and though portions of that regulation were rescinded, overall the requirement for an NRR label was retained and a portion of a staff person devoted to overseeing that requirement ever since.
The EPA hearing protector regulation simply requires labeling of passive hearing protection devices with a number that describes their noise-reduction capabilities. There are no minimum performance requirements specified, nor any physical characteristics that a device must meet to be sold as a hearing protection device.
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Workplace Applications
OSHA (Occupational Safety and Health Administration) – OSHA was established under the Occupational Safety and Health Act of 1970 as the main federal agency charged with enacting and enforcing workplace safety and health legislation. It promulgated the Occupational Noise Standard in 1971 and the Hearing Conservation Amendment in 1983. These are the principal occupational rules defining noise exposure practices in occupational settings. Although OSHA specifies the use of hearing protection in the rule as well as methods of computing hearing protection adequacy on the job, OSHA is not responsible for labeling, testing, or approving hearing protectors.
For a summary of the OSHA hearing conservation regulations, visit: http://www.e-a-r.com/pdf/hearingcons/HCRegComparison0407081.xls
MSHA (Mining Safety and Health Administration) – MSHA is the federal enforcement agency responsible for the health and safety of the nation’s miners. They promulgated an updated health standard for occupational noise exposure in 1999. This included requiring use of hearing protection devices, however, all noise exposures are computed without credit for the hearing protection and the use of the NRR is not required. MSHA has taken this position in recognition of the disparities between labeled and real-world performance. As with OSHA, MSHA does not regulate or stipulate any requirements for hearing protectors.
For a summary of the MSHA hearing conservation regulations, visit:
http://www.e-a-r.com/pdf/hearingcons/HCRegComparison0407081.xls
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Best Practices
NIOSH (National Institute for Occupational Safety and Health) – As part of the Centers for Disease Control (CDC), NIOSH is responsible for conducting research and making recommendations to prevent work-related illnesses and injuries. As such, it does not set regulatory policy (that is under the aegis of OSHA), but makes recommendations and policy statements. NIOSH has been heavily involved in noise research activities since the early 1970s in its Cincinnati and Pittsburgh offices. NIOSH’s most recent criteria document on occupational noise exposure was issued in 1998 and outlines a more rigorous program than was enacted by OSHA. Many consider the NIOSH program one of best practice, whereas the OSHA program is one of compliance.
Though NIOSH is involved in research, has conducted field studies on hearing protector performance, works on the relevant ANSI working groups, and has its own hearing protector test facilities, it does not set policy and does not test and rate hearing protectors for labeling purposes. For a summary of the NIOSH best practices, visit:
http://www.e-a-r.com/pdf/hearingcons/HCRegComparison0407081.xls
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Standards
ANSI (American National Standards Institute) – ANSI is the principal non-government voluntary standards organization in the U.S. ANSI standards do not have the power of law; they are not regulations. Rather, they are consensus documents that have been created by numerous standards-developing bodies that write and maintain standards in many fields. Participants in that process are all of us – product users and producers, researchers and consultants, and military and government agency representatives. ANSI sets the operational procedures and methods required to develop and approve such documents.
ASA (Acoustical Society of America) – With a membership of over 7000 acousticians and interested parties, ASA is a not-for-profit professional organization that provides a Standards secretariat to support and coordinate the activities of four ANSI-Accredited Standards Committees. The Secretariat works with ANSI to produce, publish, and market standards after they are approved by both the appropriate Accredited Standards Committee and by ANSI. Each committee consists of a number of Working Groups (WGs) that have specific assignments. Each Standards Committee typically consists of 15 to 20 organizational members and a number of technical experts.
The principal hearing protector standards committee is WG11, Hearing Protector Attenuation and Performance. WG11 is part of Standards Committee 12 (Noise), and is responsible for the following ANSI standards, two of which (see below) are likely to be adopted in a revised EPA hearing protector labeling regulation.
S12.6-2008 – Methods for measuring the real-ear attenuation of hearing protectors
S12.42-1995 (R2004) – Microphone-in-real-ear and acoustic test fixture methods for the measurement of insertion loss of circumaural hearing protection devices (under revision)
S12.68-2007 – Methods of estimating effective A-weighted sound pressure levels when hearing protectors are worn
S12.71-200X – Performance Criteria and Uncertainty Determination for Individual Hearing Protector Field Attenuation Measurement Devices (under development)
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