# Presentation: 062952

## Recommendations forHearing Protector LabelingEPA Workshop on Hearing Protector DevicesMarch 27, 2003

**Ted K. Madison, M.A., CCC-A**
**3M Occupational Health &****Environmental Safety Division, **
**St Paul,  MN**

## Hearing Protector Labeling

- Users of HPDs need clear, accurate information
- Current EPA-required HPD labeling is inadequate and misleading
- Improved HPD labeling will benefit  HPD users

## HPD User NeedsOccupational Noise

- Key question
- Are these HPDs capable of reducing the noise exposure of wearers to levels below the exposure limit?
- Typical situation
- Known exposure levels
- Hearing conservation training
- Annual hearing tests

## HPD User NeedsNon-Occupational Noise

- Key question
- Are these HPDs capable of protectingmy hearing from hazardous or nuisance level noise?
- Typical situation
- Unknown exposure levels
- No training
- Unknown hearing levels

## Purposes of HPD Labeling

- EPA intent 	(EPA press release- 9/12/79)
- “Consumer will be able to tell at a glance the relative noise characteristics of a specific brand of product by comparing its...Noise Reduction Rating to those of other brands”
- “Primary emphasis on...labels on products used in and around the home”

## Existing HPD LabelsBased on False Premise

- EPA Premise
- “The higher the rating, the more effective the product should be”  (EPA press release- 9/12/79)
- What we have learned
- High NRR is a poor predictor of HPD effectiveness
- NRR only reveals capability of device to attenuate
- HPD effectiveness varies widely in real world

## HPD Effectiveness

- Effective HPDs reduce noise exposure
- Many factors influence effectiveness
- Noise
- Exposure Time
- Level
- Wearer
- Wear time
- Training
- Motivation
- Device
- Attenuation
- Fit

## Existing HPD Labeling is Inadequate

- Not enough information on hearing protector selection
- Too much emphasis on HPD attenuation
- Little information on variability of HPD performance
- Single number rating (NRR) obscures fact that performance varies widely across population

## Misleading HPD LabelCreates Confusion

- EPA statements on label contradict OSHA enforcement directives
- Derating is response to misleading NRR
- EPA-required text contradicts manufacturer’s use recommendations
- User cautions and warnings needed to correct misleading EPA labeling information

## Examples of Contradictory Information

- EPA-required text
- “The level of noise entering a person’s ear... is closely approximated by the difference between the ... noise level and the NRR”
- Manufacturer’s use recommendation
- “Research suggests that the NRR may overestimate the protection provided by hearing protectors during typical use.  3M recommends reducing the NRR by 50% for estimating the amount of noise reduction provided”

## Examples of Contradictory Information

- EPA-required text
- “Higher (NRR) numbers denote greater effectiveness”
- Manufacturer’s use recommendation
- “Differences between hearing protector ratings of less than 3 dB are not important.  Far more important is the amount of time you wear the hearing protectors relative to the amount of time you are exposed to noise”

## RecommendationsREAT Test Method

- Measure real-ear attenuation according to ANSI S.12.6 method B (subject fit)
- Provides user with better information on HPD attenuation in typical use conditions
- Simplifies compliance with noise exposure regulations
- Built-in “safety factor” eliminates need for derating

## RecommendationsNRR

- Noise Reduction *Range*
- Describe noise reduction at 2 different performance levels
- Higher number describes attenuation achievable by small number of persons
- Lower number describes attenuation achievable by most wearers
- Informs users that HPD performance is highly variable in real world

## RecommendationsSecondary Label

- Follow recommendations of NHCA Task Force on Hearing Protector Effectiveness
- De-emphasize attenuation as a selection criterion
- Describe other factors in HPD selection
- Wear time
- Fit
- Comfort
- Communication

## NHCA Task Force on Hearing Protector Effectiveness

- “The most critical consideration in selecting and dispensing a hearing protector is the ability of the wearer to achieve a comfortable noise-blocking seal which can be consistently maintained during all noise exposures.”

## RecommendationsHPD Testing Rules

- Allow 3-year transition period for new labeling
- HPD manufacturers need time to re-test products
- Require manufacturers to re-test HPDs when product changes affect form, fit,or function
- Require manufacturers to test products at independent, third-party laboratories

## RecommendationsTest-Retest Variability

- Create rules for establishing labeled NRR when attenuation data vary over a series of tests
- Manufacturers face market pressure to use test results yielding highest NRR
- Consider history of performance tests rather than a single test to determine if manufacturer is in compliance
- Helps create level playing field for all manufacturers
- Helps prevent NRR from changing due to statistically insignificant variations in test results

## RecommendationsOffice of Noise Abatement & Control

- Seek EPA funding for ONAC
- Assures that HPD labeling regulations stay up to date
- Maintains enforcement of regulations
- Consider memorandum of understanding to allow NIOSH to regulate certain aspects of HPD labeling if the EPA ONAC remains un-funded

## Slide 19