# Presentation: 242717

## Brian Myers
National Hearing Conservation Association Board
Former Vice-Chair of International Safety Equipment Association’s Hearing Protector Group
Marketing under 
Leading brands of hearing protection in the U.S. and the world  

- National Hearing Conservation Association Board
- Former Vice-Chair of International Safety Equipment Association’s Hearing Protector Group
- Marketing under
- Leading brands of hearing protection in the U.S. and the world

- Aearo CompanyHearing Protector Manufacturer

## We believe that providing consumers, users and other key decision makers with better information regarding realistic hearing protector performance is beneficial to ALL stakeholders in the long run.

- Belief

## Committed to improving hearing conservation efforts
Chair of ANSI Working Group
EARCALSM Lab Participation in Interlab Studies
Ongoing Education and Training Efforts

- Chair of ANSI Working Group
- EARCALSM Lab Participation in Interlab Studies
- Ongoing Education and Training Efforts

- Commitment

## The Only Manufacturer to Recommend Hearing Protector Derating on Every Package
For more than fifteen years
Utilization of NVLAP Accredited Lab
Investment in Capital and R&D  

- For more than fifteen years
- Utilization of NVLAP Accredited Lab
- Investment in Capital and R&D

- Commitment

## Support ANSI S12.6 - 1997, Method B protocol 
With one essential modification 

- With one essential modification

- Recommended Test Method

## Conducted our own extensive lab to lab comparison
Found one product where the product performed as expected across all subjects but one.
In this case, the subject had amplification at key frequencies leading to poor mean attenuation and large standard deviation 

- Found one product where the product performed as expected across all subjects but one.
- In this case, the subject had amplification at key frequencies leading to poor mean attenuation and large standard deviation

- Test Method Research

## Manufacturers will invest significant, time, money and resources in the development of a product
Unfair to allow a bad test to dictate the failure of a good idea in the marketplace

- Unfair to allow a bad test to dictate the failure of a good idea in the marketplace

- Outcomes of a “Bad” Test

## More subjects?
Appropriate number may approach one-hundred
Too costly and time-consuming

- Appropriate number may approach one-hundred
- Too costly and time-consuming

- Solutions for a “Bad” Test

## Full Disclosure Option
Allow manufacturers to perform multiple tests
Required to submit all test and reasoning behind rating selection to EPA (or other suitable group)
Decision reviewed within a fixed period of time

- Allow manufacturers to perform multiple tests
- Required to submit all test and reasoning behind rating selection to EPA (or other suitable group)
- Decision reviewed within a fixed period of time

- A New Proposal

## Method B provides more meaningful information to consumers leading to better programs
Will increase product innovation
Renewed investment in hearing conservation and training materials
Will improve product and program performance for hp users

- Will increase product innovation
- Renewed investment in hearing conservation and training materials
- Will improve product and program performance for hp users

- Moving Forward

## Labeling
De-emphasize the “Number” 
Range of numbers to express performance
No number on the individual package
Sunset Clause
Costly and time consuming
7 to 10 years

- De-emphasize the “Number”
- Range of numbers to express performance
- No number on the individual package
- Sunset Clause
- Costly and time consuming
- 7 to 10 years

- Other Issues

## Education and Training
Lab Qualification
National Voluntary Lab Accreditation Program (NVLAP)
Funding 
Office of Noise Abatement and Control
Compliance Audit Testing

- Lab Qualification
- National Voluntary Lab Accreditation Program (NVLAP)
- Funding
- Office of Noise Abatement and Control
- Compliance Audit Testing

- Other Issues

## 3 to 4 years from adoption to consumers
Windows by product style
Earmuffs, foam earplugs, premolded earplugs ...
Separated at three month intervals

- Windows by product style
- Earmuffs, foam earplugs, premolded earplugs ...
- Separated at three month intervals

- Timing

## Support Method B testing
With provision for “bad” test 
Support ISEA consensus
Education, training and funding

- With provision for “bad” test
- Support ISEA consensus
- Education, training and funding

- A Change for the Better