Hearing Conservation Program

The Hearing Conservation Program establishes a systematic framework for identifying, evaluating, and controlling occupational noise exposure across all company operations. The program mandates noise monitoring at or above 85 dBA TWA (8-hour time-weighted average), baseline and annual audiometric testing, provision of appropriate hearing protection devices, employee training, and recordkeeping. The goal is to eliminate preventable hearing loss and ensure full compliance with WorkSafeBC OHS Part 7 (Noise, Vibration, and Personal Protective Equipment) and OSHA 29 CFR 1910.95. This policy applies to all employees, contractors, and visitors who enter designated high-noise areas.

This program applies to all company-operated facilities, shops, yards, and field sites where employees may be exposed to continuous, intermittent, or impulsive noise at or above 85 dBA as an 8-hour TWA. It covers all full-time, part-time, seasonal, and temporary employees, as well as subcontractors while on company premises. Supervisors are responsible for identifying tasks and areas that trigger program requirements, including operation of heavy equipment, pneumatic tools, grinding, sawing, blasting, and any process exceeding the action level. Visitors entering posted high-noise zones must also comply with hearing protection requirements.

• 85 dBAAction Level Trigger: When 8-hour TWA noise exposure reaches 85 dBA, the employer must implement a full hearing conservation program including monitoring, audiometric testing, training, and hearing protection. This aligns with WorkSafeBC OHS 7.22–7.30 and OSHA 1910.95(c).
• 87 dBAProtection Mandate: When exposures reach 87 dBA TWA (CEILING), hearing protection devices must be worn by all personnel in the affected area. Employers must enforce double protection (plugs + muffs) in zones exceeding 105 dBA. Feasible engineering and administrative controls must be prioritized before relying on PPE.
• AUDIOAudiometric Testing Protocol: Baseline audiograms must be obtained within 6 months of first exposure ≥85 dBA. Annual audiograms must be compared to baseline using STS (Standard Threshold Shift) criteria. An STS of ≥10 dB at 2000, 3000, or 4000 Hz in either ear triggers retesting, referral, and potential work restriction review.
• TRAINAnnual Training & Fit Testing: All covered employees must complete annual hearing conservation training covering noise effects, proper HPD use, care and replacement schedules, and fit testing. Quantitative fit testing (e.g., PASS or F-MIRE) is required at initial assignment and every 2 years thereafter.
• RECRecordkeeping & Auditing: Maintain noise monitoring records for 30 years, audiometric test records for the duration of employment plus 30 years, and training records for 5 years. Program audits must be conducted annually by the safety department and every 3 years by a third-party industrial hygienist.

• Health & Safety Director: Owns the hearing conservation program, approves noise monitoring plans, reviews audiometric data, and ensures compliance with all regulatory standards. Reports program metrics to senior leadership quarterly.
• Site Supervisors / Foremen: Enforce hearing protection rules in the field, ensure HPD availability and proper use, report noise hazards, and coordinate training schedules. Conduct weekly visual inspections of HPD condition.
• Industrial Hygiene Team: Perform area and personal noise dosimetry surveys, update noise maps, recommend engineering controls, and maintain monitoring records. Conduct annual program effectiveness evaluations.
• Employees: Wear assigned hearing protection in designated zones, participate in audiometric testing and training, inspect HPDs daily, and report any hearing concerns or HPD defects to their supervisor immediately.
• Human Resources: Maintain training and audiometric records, coordinate baseline testing for new hires in covered roles, and manage STS follow-up procedures including referral documentation.