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Guidelines for A Legally Acceptable CAOHC Industrial Hearing Conservation Program

By Robert M. Traynor, Ed.D., MBA, FNAP and Garry G. Gordon, MS

The Council for Accreditation in Occupational Hearing conservation (CAOHC) is a non-membership organization created in 1973 to collaborate with nine professional organizations that have a common interest in all aspects of occupationally related noise-induced hearing loss. This is a collaboration of the organizations that are those most involved with hearing conservation including Audiology, Otolaryngology, Occupational Health Nursing, Occupational and Environmental Medicine, Industrial Hygiene, Safety professionals, Noise Control Engineering and Military Audiology.

Through the mission of the advancing of best practice in occupational hearing conservation worldwide, through credentialing, education and advocacy, the organization has had a significant impact in the reduction of occupational hearing loss, by over 59% since 2004. This has been accomplished by the development of guidelines for industrial programs and cautions for those involved in noisy recreational activities. CAHOC trains qualified course directors to train and certify occupational hearing conservationists involved with these programs and professional supervisors to set up, ensure compliance, as well as follow up with those that suffer hearing impairment.

Who Needs These Programs?

Hearing damage is a serious occupational hazard in professions that expose workers to loud impulses or continuous noise. Over thirty million employees work in hazardous noise levels and are found nationwide in all segments of the industry. Routine places where noise is a hazard in industry are (but not limited to):

  • Manufacturing and assembly
  • Distribution centers
  • Military personnel
  • Construction workers
  • Law enforcement
  • Those who work near certain chemicals

Of course, most occupational hearing loss occurs gradually over the course of years, making the impairment difficult to perceive until it is too late. However, with appropriate measures, workplace hearing loss is completely preventable. Providing the services to analyze noise, audiometric monitoring and provide hearing protection products makes a huge difference for workers involved in noisy occupations.

Another area, often totally overlooked, is recreational noise which may have a significant impact on the amount of hearing loss seen in industrial programs. Without an efficient industrial hearing conservation program, companies are legally responsible for any hearing loss seen during a worker’s employment, unless they can prove that the impairment was created by disease or recreational noise exposure. Research has demonstrated over the years that many recreational activities are part of overall noise exposure from various activities. Th following is a partial list of activities dangerous for the auditory system:

  • Snowmobiling
  •  Motorcycling
  • Woodworking
  • Music, concerts, playing in bands
  • Hunting & target shooting
  • Motorboating, personal watercraft

No matter if it is caused by industry or recreation, noise-induced hearing loss creates multiple issues for those that suffer its effects. The damage to the ear is currently irreversible and slowly becomes permanent over time, creating high frequency hearing loss, ringing in the ears (tinnitus), understanding difficulties (especially in noisy situations), as well as social withdrawal and communicative frustration that often leads to major effects on family life.

General Industrial Hearing Conservation

Who should be Enrolled in the Program?

OSHA and other regulations mandate that workers exposed to noise levels of a time weighted average (TWA) throughout their shift should be enrolled in a hearing conservation program. Mortiz (2014) explains that the TWA is the combination of all the sound intensities that the worker is exposed throughout the work shift. These exposures are limited to 85 dB(A) over an 8-hour shift. Exposures at or above an 8-hour TWA of 85 dB(A) require the implementation of a hearing conservation program. When the worker reaches a Permissible Exposure Level (PEL) of 90 dB (A) they will be required to use hearing protection devices. The specifics of these programs are outlined by the various regulations that manages safety within that, such as OSHA, MSHA and FRA. Best practices are offered by the National Institute for Occupational Safety and Health (NIOSH). Tuten & Gates (2021) indicate that even if the worker is exposed for only one day, they are required to be enrolled in a hearing conservation program. When the worker reaches a Permissible Exposure Level (PEL) of 90 dB (A) they are required to use hearing protection devices. The specifics of these programs are outlined by OSHA, Mine Safety and Health Administration (MSHA) and Federal Railroad Administration (FRA) regulations. Best practices are offered by the National Institute for Occupational Safety and Health (NIOSH).

Elements of a Hearing Conservation Program

First Considerations

One of the first necessary components of a hearing conservation program is to have the whole company management team on board with the program. Schaible & Swisher (2014) present that managers and supervisors must understand the rationale for the program, the effects of noise on hearing, the requirements of the appropriate regulations and the need for their participation and support. Secondly, there must be efforts to enlist worker support for the program and it is a good idea to have worker representation in the planning of the program to be offered. A third, often overlooked, concern for management is that if there is no baseline hearing test for a new worker joining the company and annual assessments during their tenure for a worker exposed to a TWA of 85 dB (A), the company is responsible for the resulting hearing loss via the Presumptive Rule (OSHA, CFR 1904.5). This OSHA rule states that it is presumed that injuries and illnesses result from events or exposures occurring in the work environment and the company must prove that the injury or illness is caused by an outside source. Without a baseline hearing assessment, the company assumes all responsibility for any hearing loss the worker possesses at the beginning of their employment unless they can prove that the impairment existed prior to employment. Without annual assessments, the company assumes all responsibility for any hearing loss after the first baseline assessment. With no hearing conservation program, the company is liable for any hearing loss incurred by the worker prior to initial employment and subsequently during the life of his or her employment.

The workers usually know the most about the factors important to the development of the hearing conservation program, such as work schedules, sources of noise in their environments, if improved maintenance could reduce the noise of their manufacturing equipment and possible methods to reduce the noise. The major components of the program include the following:

  1. Noise Measurement. The purpose of noise measurement is first to assess the noise, map the areas where the noise exists and its type and intensity to determine its influence on the work environment. Secondly, these measurements are necessary to determine the amounts of noise presented to the workers from specific machines and or operations. These determinations are usually conducted by professional engineers or industrial hygienists using sound level meters and/or dosimeters.
  2. Noise Control. Noise is controlled by altering the source, the path or the receiver. Reducing noise at the source involves engineering controls. These controls are created by engineering out the noise, making the machines quieter, purchasing newer/quieter equipment, building enclosures around the equipment to reduce the machine or the process noise. Often these controls are prohibitively expensive. Reducing the path of the noise involves administrative controls by rotating workers through different tasks to limit their exposure to the noise. Finally, if engineering and administrative controls are unsuccessful, then reduction of the noise at the receiver is conducted. This procedure involves the use of hearing protection devices.
  3. Hearing Protection. Hearing protection devices (HPDs) must be selected to provide the correct amount of hearing protection without interfering with essential communication. The HPDs need to be fit properly, with good instructions for the worker to ensure that continued use will be afforded the correct amount of protection. If possible, the devices should be “fit checked” with appropriate equipment to determine a Personal Attenuation Rating, ensuring that the HPDs will provide the necessary protection.
  4. Audiometric Monitoring. Audiometric monitoring allows for the assessment of the workers to determine if they have obtained a hearing loss from their work environment. In the CAOHC System, workers typically receive a baseline hearing test upon employment and/or entering the hearing conservation program and annual recheck of their hearing and a review of problem hearing evaluations for possible referral for medical attention.
  5. Worker Training and Motivation. Workers must be trained as to what happens with noise-induced hearing loss, audiometric monitoring and the use of hearing protection devices. Training is part of the motivation to cooperate with the hearing conservation program. The training is usually conducted by an occupational hearing conservationist that is knowledgeable of their jobs.
  6. Recordkeeping. The occupational hearing conservationist, under the director of the professional supervisor, maintains the records of the hearing conservation program, but the company is ultimately responsible for all hearing loss greater than the baseline, unless they can prove that the impairment was created by another cause. If no baseline hearing test is conducted, then the company is assumed to be responsible for all hearing loss. Records must be available for inspection upon request by inspectors from OSHA, MSHA and FRA.
  7. Program Evaluation. Any program to record and benefit workers in industry should be evaluated to determine if it is beneficial. Hearing conservation programs should be evaluated in each of the seven areas to determine efficiency and validity. Any area that does not provide benefit, should be reconsidered and updated.

Hearing conservation programs do a great job of reducing noise-induced hearing loss in this new century. Not only is industrial hearing loss down in the U.S. but also in Europe (Chandra & Ceiza, 2021). CAOHC offers Occupational Hearing Conservationist (OHC) training by Certified Course Directors in the daily operations of hearing conservation programs. These instructors train OHCs to understand the seven areas of hearing conservation and specifically assist them in learning how to administer a routine hearing test. These courses are available from and others throughout the country.


Chandra, S. & Ceiza, A. (2021). World Report on Hearing. World Health Organization, Geneva, Switzerland.

Moriz, C. (2014). Noise Control and Measurement. In Hutchinson, T., & Shultz (Eds), Hearing Conservation Manual, 5th Edition Milwaukee, WI : Council for Accréditations in Hearing   Conservation.

Occupational Safety & Hazard Administration (OSHA) (2001). 1904.5 – Determination of work-   relatedness. US Department of Labor, Retrieved May4, 2021 from:

Tuten, V., & Gates, K., (2021). Now Hearin This : The Rght Steps for Hearing Conservation  Training, Industrial Hygiene in the WorkPlace, March April, pp. 16-17, 46.

US Bureau of Labor Statistics, (2016). Reduction of Noise Induced Hearing Loss. Retrieved April 20, 2021 from:

Robert M. Traynor, Ed.D., MBA, FNAP practiced audiology and interoperative monitoring in Greeley, Colorado, treating patients of all ages for 46 years. He is a frequent lecturer and convention speaker domestically and has lectured internationally on most aspects of audiology in over 40 countries. For 17 years he was Senior International Audiology Consultant to a major hearing aid manufacturer. Traynor is currently an Adjunct Professor of Audiology at the University of Arkansas for Medical Sciences and Salus University. He is a Fellow of the National Academies of Practice, was presented the 2014 Lifetime Achievement Award from the Colorado Academy of Audiology, named a 2018 Distinguished Alumnus of the University of Northern Colorado and in 2019, received the Joel Wernick Award for outstanding educational contribution to the fields of audiology and Hearing Science. His text, Strategic Practice Management, 3rd Edition, co-authored with Dr. Robert Glaser, is used in most audiology training programs. At Robert Traynor Audiology, LLC., he conducts audiology consulting, forensic audiology, and is CAOHC Course Director and Professional Supervisor business in Fort Collins, Colorado.

Garry Gordon, MS. is the CEO/Owner and Audiologist/Instructor at EAR Inc in Boulder, Colorado. While president of E.A.R., Inc. Gordon has served well over 4000 major medical, audiological and industrial accounts and trained a network of 500+ recreational and industrial providers who market hearing protection. He is well recognized by all manufacturing companies and provider networks of hearing healthcare products in the U.S. and Canada. Gordon has also contributed to several major publications and presentations regarding hearing loss. These include Outdoor Life, Field and Stream, Trap and Field, Sporting Clays, ENT/Audiology Japan, International Symposium of Sports Medicine held in Moscow, Russia (

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