# Presentation: 355303

## NOISE WORKSHOPHistory and Use of EPA’s Hearing Protector Labeling Regulation

**Alice H. Suter, Ph.D.****March 27, 2003**

## Who Uses What:

- Europe
- SNR (Single Number Rating)
- HML (High, Middle, Low)
- Canada and Australia
- Class System
- United States
- NRR

## How the NRR’s Use Causes Problems

- Bigger is Better Mentality
- NRR is Gospel
- Failure to Match the NRR to TWA
- NRR Overestimates Attenuation
- Discourages Tailoring to Individual Needs

## Modifications to the NRR

**OSHA’s Compliance Policy**
- Derating by 50 % when assessing the relative effectiveness of hearing protectors and engineering controls
- OSHA Technical Manual mentions NRR(SF)for informational purposes
**NIOSH Criteria Document Recommendation**
- Earmuffs		NRR minus 25%
- Foam Earplugs	NRR minus 50%
- All Other Earplugs	NRR minus 70%
**Some Employers**

## Noise Control Act of 1972

- Congressional Declaration of U.S. Policy
- “to promote an environment for all Americans *free from noise* that jeopardizes their health or welfare.  To that end, it is the purpose of the Act to establish a means for effective coordination of Federal research and activities in noise control, to *authorize the establishment* of Federal noise emission standards for products distributed in commerce, and to provide information to the public respecting the *noise emission and noise reduction characteristics* of such products.”

## Noise Control Act - Section 8

- Gives EPA the Responsibility to Regulate the Labeling of:
- Products Emitting Noise
- Products Reducing Noise

## Noise Control Act - Section 8

- (a)  The EPA Administrator must designate any product or class of products which:
- 1. Emits noise capable of adversely affecting the public health or welfare, or
- 2. Is sold wholly or in part on the basis of its effectiveness in reducing noise.

## Noise Control Act - Section 8

- (b)  For each product or class of products EPA shall require that notice be given to the prospective user of the level of noise the product emits, or of its effectiveness in reducing noise.  The regulation must specify:
- 	1. Whether such notice shall be affixed to the product or to	 	the outside of its container (or both), at the time of its sale	to the ultimate purchaser, or whether such notice shall be	given to the prospective user in some other manner,
- 	2. The form of the notice,
- 	3. The methods and units of measurement to be used.

## Rationale for Labeling Hearing Protectors

- Section 6 of the Noise Control Act mandates regulations for major sources of noise
- Too many noisy new products would take too long to regulate
- Technical and economic feasibility problems
- Need to protect against noise of in-use products

## Background Leading up to the Regulation

- ANSI Z24.22-1957
- ANSI S3.19-1974
- NIOSH Methods #1, #2, and #3
- Subtracting 2 SDs “should rarely overestimate the degree of protection”

## EPA-1979 Hearing Protector Labeling Requirements - Subpart B

**211.204  Information content of primary label **
**Includes requirements for primary label size, print and color, label location and type, and supporting information.**
**211.205  Special claims and exceptions**
**211.206  Methods for measurement of sound attenuation**
**Real ear method in ANSI S3.19-1974 (as modified in this section)**
**211.207  Computation of the noise reduction rating (NRR)**
**211.208  Export provisions**
**211.209  Maintenance of records and submittal of information**
**211.210  Labeling verification requirements**
**211.211  Compliance with labeling requirements**
**211.212  Compliance audit testing**

## OSHA’s Hearing Conservation Amendment

- Appendix G (1981) now Appendix B (1983)
- Noise Reduction Rating
- NIOSH #1, #2, or #3
- Using the NRR to estimate the A-weighted level under the ear protector:
- C-weighted TWA – NRR
- A-weighted TWA - (NRR-7)

## Slide 13

## Labeled vs. Field Values

**Field**

**Laboratory**

## Predicted vs. Field Values

**Field**

**Laboratory**

**Method B**

## Predicted vs. Field Values

**Predicted vs. Field Values**

**NRR (dB)**

**Method B**

**Field**

**Label Test**

## NHCA Task Force HPD Effectiveness

- AAOHN,	Barbara Panhorst
- AAO-HNS,	Robert Dobie
- ACOEM,	Tom Markham
- AIHA,	Dennis Driscoll
- ASA,	Jim Patterson
- ASHA,	Rena Glaser
- CAOHC,	Rena Glaser
- ISEA,	Jeff Birkner
- NHCA,	Larry Royster
- NSC,	Jill Niland

- EPA,	Ken Feith
- MAA,	Doug Ohlin
- MSHA,	Leonard Marraccini
- NIOSH, 	John Franks
- OSHA, 	Deborah Gabry
- WG10,	Charles Nixon
- WG11,	Elliott Berger
- WG12,	Julia Royster
- WG35,	Ed Toothman

## HPD Task Force’s Mission

- Guidelines for labeling hearing protection devices
- Recommendations for educational materials that should be provided
- General guidelines for hearing protector selection and use

## Administrative Issues

- Use Method B from ANSI 12.6-1997
- Test facilities meet NVLAP requirements
- Retesting at least every 10 years but not more often than every 5 years

## Proposed Primary Label 

## Secondary Label Format Instructions for use

- This section may contain unlimited text and pictures at the discretion of the manufacturer.

## Secondary Label Format Selecting Hearing Protectors

- 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.

## Secondary Label Format Additional Issues

- Hearing protector’s noise reduction
- Wearer’s daily equivalent noise exposure
- Variations in noise level
- User preference
- Communication needs
- Hearing ability
- Compatibility with other safety equipment
- Wearer’s physical limitations
- Climate and other working conditions
- Replacement, care and use requirements

## Secondary Label Format Attenuation Values

| Test
Frequency
(Hz) | 125 | 250 | 500 | 1000 | 2000 | 4000 | 8000 | H | M | L | NRR(SF) |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Mean
Attenuation
(dB) | 17.9 | 19.0 | 21.0 | 24.7 | 29.9 | 35.6 | 34.6 | 25 | 18 | 14 | 16 |
| Standard
Deviation
(dB) | 7.3 | 6.3 | 7.3 | 6.4 | 5.3 | 5.0 | 5.4 |  |  |  |  |

## Secondary Label FormatHow to Use NRR(SF)

- The NRR(SF) may be subtracted from an A-weighted sound level or TWA
- 1. 	For example, the noise level is 92 dBA.
- 2. 	The NRR(SF) is 16 dB.
-   Most users (84%) should be protected to a		level of 76 dBA.
- Tip:	A better estimate of the protected level can 	be obtained by adding 5 dB to the NRR(SF)	and subtracting it from a measurement made	using C- instead of A-weighting.

## Secondary Label FormatApplicability

**FAILURE TO FIT THIS HEARING PROTECTOR ACCORDING TO INSTRUCTIONS WILL REDUCE ITS EFFECTIVENESS.  When used as directed, this hearing protector is expected to provide between 16 and 30 dB of noise reduction for about 66% of the users.  Of those remaining, 17% will be likely to obtain less than 16 dB of protection, and the other 17% will be likely to obtain more than 30 dB.**
**Differences between hearing protector ratings of less than 3 dB are **_**not**_** important.**

## Secondary Label Format Estimating Noise Reduction for Individual Users

**The labeled values of noise reduction are based on laboratory tests.  It is **_**not possible**_** to use these data to reliably predict levels of protection achieved by a given individual in a particular environment.  To ensure protection, those wearing hearing protectors for occupational exposures must be enrolled in a hearing conservation program.  Non-occupational users should have hearing evaluations by an audiologist, qualified physician, or other qualified professional, on a regular basis.**

## Secondary Label FormatImpulse Noise

- Although hearing protectors are useful for protection from impulsive noise, the noise reduction measurements are based on tests in *continuous* noise and may not be an accurate indicator of the device’s performance for *impulsive* sounds, such as gunfire.

## Secondary Label FormatAdditional Information

- For additional information, call NIOSH at 800-35-NIOSH to obtain document 9X-XXX (_www.cdc.gov/niosh_), or contact the EPA at phone/address (_www.epa.gov_).

## Summary

- Current NRR is not useful to purchasers and users of hearing protectors
- Modifications to NRR vary and are less than ideal
- EPA developed its hearing protector regulation with the idea that the NRR would be beneficial information for hearing protector users
- NIOSH believed that the two standard deviation adjustment would prevent overestimates
- OSHA cast the NRR in concrete
- Field studies provided a wake-up call
- NHCA Task Force responded, made recommendations
- Something needs to change.....