U. S. Department of Labor

Occupational Safety and Health Administration

Directorate of Science, Technology & Medicine

Office of Science and Technology Assessment

SHIB 07-22-2005

 Innovative Workplace Safety Accommodations

 for Hearing-Impaired Workers

Safety and Health Information Bulletin

Introduction

Approximately 28 million Americans have some

degree of hearing loss [1,9]. Hearing loss can result

from a variety of factors, including: heredity, disease,

physical trauma, and exposure to loud noises. The

National Institute for Occupational Safety and Health

(NIOSH) estimates that 10 million American workers

have permanent hearing loss resulting from exposure

to excessive noise at work [2]. The number of

American workers with hearing loss from all sources is

expected to increase over time as the workforce ages.

Hearing-impaired workers face challenges responding

to emergencies, working safely around machinery,

communicating with coworkers, and receiving training.

Accommodations necessary to address these

challenges may not be part of an employer’s current

hearing conservation practice. This Safety and Health

Information Bulletin (SHIB) focuses on (1)

Emergency/Evacuation Response Considerations

for Hearing-Impaired Workers; and (2) Workplace

Safety and Health Considerations for HearingImpaired Workers.

Purpose

The purpose of this SHIB is to provide employers,

workers and professional organizations guidance on

accommodating the safety and health needs of

hearing-impaired individuals in the workplace.

Specifically, this SHIB:

1. Raises awareness about the safety and health

challenges faced by hearing-impaired workers.

2. Informs employers of the wide range of

accommodations available for the hearing-impaired

worker and their application in the workplace as they

relate to emergency evacuation, training, responding to

safety hazards and communication.

3. Encourages employers to develop and establish

procedures for hearing-impaired workers that further

safety and health in their workplaces.

4. Encourages worker participation in the

development, planning, and implementation of these

accommodations.

This Safety and Health Information Bulletin is not a

standard or regulation, and it creates no new legal

obligations. The Bulletin is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace.

Pursuant to the Occupational Safety and Health

Act, employers must comply with hazard-specific

safety and health standards promulgated by OSHA or

by a state with an OSHA-approved state plan. In

addition, pursuant to Section 5(a)(1), the General

Duty Clause of the Act, employers must provide their

employees with a workplace free from recognized

hazards likely to cause death or serious physical harm.

Employers can be cited for violating the General Duty

Clause if there is a recognized hazard and they do not

take reasonable steps to prevent or abate the hazard.

However, failure to implement any recommendations

in this Safety and Health Information Bulletin is not, in

itself, a violation of the General Duty Clause. Citations can only be based on standards, regulations, and

the General Duty Clause.
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1

 OSHA’s standard at 29 CFR 1926.52 addresses occupational noise exposure in the construction industry.

Background

The Occupational Safety and Health Administration’s

(OSHA) Occupational noise exposure standard

includes requirements for a hearing conservation

program (29 CFR 1910.95(c)). It covers employers

in general industry with employees exposed to noise at

85 decibels (dBA) or above measured as an 8-hour

time-weighted average sound level (TWA). It

requires these employers to include their noiseexposed employees in a hearing conservation program

that consists of noise exposure assessment,

audiometric testing, hearing protection and training.1

The nature of the workplace has changed since the

standard took effect; many workers in the United

States are aging and have some degree of hearing

loss. There is also greater concern among workers

about readiness to safely react to catastrophic events.

In addition to emergencies caused by natural

disasters, and technological accidents; possibility of

acts of terrorism have become a concern.

Accommodations are available to enable hearingimpaired workers to evacuate safely, and certain

accommodations may benefit workers with no hearing

loss, since some emergencies may adversely impact all

workers’ ability to hear or communicate.

Accommodation measures in the workplace are an

extension of good communication and safe practices

for all workers.

Hearing-impaired workers also face routine

workplace safety and health challenges. In particular,

hearing-impaired workers may have difficulty

understanding audible warning signals and alarms

designed to indicate the approach of motorized

vehicles. For those with severe and profound hearing

losses, a common safety concern is localization. For

example, “I know there are forklifts in the area but I

do not know where they are coming from.” Other

concerns expressed by hearing-impaired workers

include difficulty understanding conversation on the

telephone, at meetings and in training sessions [16].

Fortunately, accommodations and equipment

modifications are available to assist hearing-impaired

workers to perform their jobs safely [4,9].

A. Emergency/Evacuation Response

Considerations for Hearing-Impaired Workers

Customizing Worksite Emergency Preparedness

for Hearing-Impaired Workers

The OSHA Emergency action plans standard (29

CFR 1910.38) requires an employer to develop a

written emergency action plan when such a plan is

required by a specific OSHA standard, such as 29

CFR 1910.120 hazardous waste operations and

emergency response, and 29 CFR 1910.160 fire

extinguishing systems. When the plan is required, it

must describe the actions employees should take to

ensure their safety if a fire or other emergency situation

occurs. At a minimum, the plan must include:

emergency escape procedures; procedures for

employees who remain to operate critical plant

operations before they evacuate; procedures to

account for all employees after emergency evacuation;

and procedures for reporting fires and other

emergencies. The plan must also include the types of

evacuation to be used in emergency circumstances.

The employer must review the plan with each

employee covered by the plan when it is developed,

whenever the plan changes and upon an employee’s

initial assignment. Employers must consider

employees with disabilities in the development of an

emergency action plan when such a plan is required by

a specific OSHA standard.

The plan must be in writing, kept in the workplace,

and available to employees for review. For employers

with 10 or fewer employees, the plan may be

communicated orally and the employer does not have

to maintain a written plan. The Appendix to 1910,

Subpart E, Exit Routes, Emergency Action Plans, and

Fire Prevention Plans is a nonmandatory guideline to

assist employers in complying with the requirements of

the employee emergency plan [3].

The Americans with Disabilities Act (ADA) does

not require employers to have an emergency

evacuation plan, but if an employer decides to have

such a plan, they are required to include people with

disabilities [10,14].
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To help prepare workers for emergencies, the Office

of Disability Employment Policy (ODEP), at the U.S.

Department of Labor, provides recommendations on

emergency preparedness for people with disabilities.

The ODEP report suggests three essential parts to an

emergency evacuation plan: plan development, plan

implementation and plan maintenance [4].

Plan development includes identifying the potential

hazards, the accommodation needs of persons with

disabilities, and key personnel who will be involved in

an emergency. In developing a plan, employers

should ask their employees for their input, and

workers with disabilities should take responsibility for

their safety by offering their ideas and input. The plan

should address after-hours situations, and include a

method to identify visitors with special needs. The

plan also should include details on how information

will be conveyed to hearing-impaired workers when

they are away from their work areas. Finally, the plan

should be easy to read and understandable.

Employers should consult with local fire, police and

emergency departments as well as community-based

organizations in developing the plan. While the plan

should be in writing, it should be viewed as an ongoing

process, periodically revised and updated to reflect

changes in technology, personnel and procedures.

Plan implementation involves distribution of the plan

in an accessible format to all employees and the

integration of the plan into the employer’s standard

operating procedures. Drills, both scheduled and

unscheduled, should be performed regularly. Such

practice drills should encompass the needs of all

individuals, including workers with disabilities, to

ensure familiarity with the procedures and to

determine where improvements are needed.

Plan Maintenance involves developing a system for

identifying new safety concerns and the needs of new

disabled employees, reviewing and modifying plans

after practice drills, and ensuring that emergency

equipment is being properly maintained in good

operating condition [4,5,9,10].

Alerting Device Options

Traditionally, notification of an emergency has been

done through the use of auditory devices which are

effective for most workers. OSHA’s Employee Alarm

Systems standard (29 CFR 1910.165), addresses all

emergency alarms required to be installed by specific

OSHA standards. The standard indicates that an

alarm system must provide warning for necessary

emergency actions and be capable of being perceived

above ambient noise by all employees. Since hearingimpaired employees may not be able to hear auditory

alarms, OSHA considers strobe lights or similar

lighting devices and tactile devices to meet the

requirement of the standard [3].

Hearing-impaired workers may also have difficulty

understanding voice communication over the public

address (PA) system. The alarm may interfere with or

drown out voice announcements, making the

emergency voice communication system ineffective.

Alerting device accommodations are available to

notify hearing-impaired workers of emergencies, and

they cause minimal distraction to other workers.

Visual alarms equipped with flashing strobe lights or

vibrating alerting devices can be hard-wired into the

existing emergency notification system. The

Underwriters Laboratories Standard for Emergency

Signaling Devices for the Hearing-Impaired (UL

1971), establishes criteria for systems used for

emergency notification [5].

Section 4.28 of the ADA Accessibility Guidelines

(ADAAG) 2

 specifically addresses specialized alarms

(www.access-board.gov/adaag/html/adaag/

htm#4.28). To be effective for notification, visual

alarms must be installed where hearing-impaired

persons can see them [6].

Many alerting device options are available for use in

the workplace, depending on the particular needs of

the hearing-impaired worker. However, not all of the

devices listed below are appropriate for every

hearing-impaired worker. Some of the devices are

 ADAAG contains scoping and technical requirements for accessibility to buildings and facilities by individuals with

disabilities under the ADA. These scoping and technical requirements are to be applied during the design, construction, and

alteration of buildings and facilities covered by Titles II and III of the ADA to the extent required by regulations issued by

Federal agencies, including the Department of Justice and the Department of Transportation, under the ADA.

2
4

more appropriate for individuals with a severe-toprofound hearing loss, while others are appropriate for

workers with a mild hearing impairment. The

employer should work together with hearing-impaired

employees, and perhaps with an occupational

audiologist, in determining the device or combination

of devices that work best for their particular situation.

Some alerting device options include:

• Exit signs set to flash when an emergency

alarm sounds. These signs are typically

connected to the emergency power system.

• Strobe lights [7] or vibrating alarm signals

placed in all areas occupied by hearingimpaired workers.

• Visual or vibrating alarm signals at the

worker’s workstation.

• Vibrating pagers worn by hearing-impaired

workers.

• Vibrating watches or other type of body alarm

that is strapped on to the individual to alert a

hearing-impaired worker.

• Two-way vibrating pagers that receive text

messages and have the ability to respond in

full length text.

• “Hearing Dogs”- trained to alert the hearingimpaired worker to a person entering the

room, abnormal machinery sounds,

malfunctioning equipment, the telephone

ringing or other alerting needs.

• Buddy systems [5,7] where a coworker alerts

a hearing-impaired worker to an emergency

situation. This system should not be relied on

as the sole means of alerting the hearingimpaired worker to an emergency situation

because of the relatively low reliability of this

approach.

• Amplified telephone ring signaler to alert the

worker to a phone ringing.

• A modem that converts the personal computer

into a Telecommunications Device for the

Deaf (TDD).

• Instant messaging or e-mail pop-up.

• A flashlight provided to hearing-impaired

individuals for signaling their location in the

event they are separated from the rescue team

or buddy.

The Job Accommodation Network (JAN) website, a

service of the Office of Disability Employment Policy,

has a wealth of information on alerting devices at

www.jan.wvu.edu. JAN’s “Employers’ Guide to

Including Employees with Disabilities in Emergency

Evacuation Plans” covers requirements for including

people with disabilities, guidelines and accommodation

considerations. Toll-free (800) 526-7234 [14].

Other useful resources are DisabilityInfo,

www.disabilityinfo.gov, and the Center for Disability

Issues and Health Professionals, www.cdihp.org.

The United States Fire Administration publishes many

guides on the subject of disability and related

emergencies at www.usfa.fema.gov, toll-free (800)

561-3356 [5,6,8].

Other Safety and Health Workplace

Accommodations

• TTY: A teletypewriter (TTY) is a telephone

device that enables hearing-impaired

individuals to make and receive telephone

calls. The device requires two TTY users to

type messages back and forth to

communicate. When messages are typed on

the TTY keyboard, the information is

displayed on the TTY display panel and

transmitted through the phone line to a

receiving TTY.

• TRS: The Telecommunications Relay Service

(TRS) is a 24-hour, 7 day a week, free

nationwide relay network service that handles

voice-to-TTY and TTY-to-voice calls. Using
5

a TTY or other mechanism (Voice Carry Over

phone, voice phone or videophone), an

individual dials the toll-free number to contact

the TRS system which will connect the caller

to a communications assistant (CA) who

directs the call. When the recipient answers

the call, the CA explains his or her role in the

call and will relay the communication between

the two parties exactly as stated by both

parties, either in text or voice. For more

information about Telecommunications Relay

Services, link to:http://www.nidcd.nih.gov/

health/pubs_hb/telecomm.htm, and

www.fcc.gov/cgb/dro

• Cell phone with a portable TTY. It is

important to make sure that the cell phone is

TTY compatible.

• Wireless TTY. Provides instant TTY access

anywhere within a selected wireless data

network. Such TTYs have e-mail, fax, textto-speech and speech-to-text message

capabilities.

The ADA Standards for Accessible Design, as well as

other technical assistance materials, can be obtained

from the U.S. Department of Justice ADA website at

www.ada.gov. The Department of Justice operates a

toll-free ADA Information Line at (800) 514-0301

(voice), or TTY (800) 514-0383, which directs

callers to an ADA specialist [5,6,10,12,14].

B. Workplace Safety and Health Considerations

for Hearing-Impaired Workers

Responding to Vehicles in the Workplace

Workers with hearing loss working around or

operating powered industrial trucks (e.g., forklifts) or

other heavy equipment may be concerned about their

ability to detect dangerous situations. The employer

should work together with hearing-impaired

employees in determining the accommodation or

combination of accommodations that work best for

their particular situation. The following are suggested

accommodations that can be made to minimize such

safety risks:

• Use tape, paint or ropes to highlight paths of

travel for forklifts, vehicles and heavy

equipment.

• Designate separate doors for mechanized and

people traffic.

• Establish rules requiring that all forklifts and

vehicles must stop at all intersections.

• Install sensor warning lights that blink as the

vehicle approaches. Directional warning lights

such as the left light signals traffic on the left,

and the right light signals traffic on the right,

may be beneficial.

• Install flashing strobe lights on vehicles or

forklifts to alert hearing-impaired workers to

oncoming vehicles.

• Install mirrors at all intersections within the

warehouse. Dome mirrors situated along

aisleways may be beneficial.

• Use vibrating pagers - place a transmitter in

the moving equipment so that the driver can

press a button that sends a signal to the

vibrating receiver worn by the hearingimpaired employee to alert the worker to the

approaching forklift.

• Position a rear vision camera so that a vehicle

operator will be able to see behind him/her.

Training Accommodations

Training is an integral component of a safe workplace,

yet training may pose unique challenges for employers

who have workers with hearing impairments. Training

programs that ensure that procedures are understood

and followed are paramount to creating a safe work

environment [15].

Hearing-impaired workers often need customized

training tools to ensure their safety. There are a

variety of training mechanisms that can be tailored to

hearing-impaired individuals in the workplace. Again,

the decision to use a particular training

accommodation is one that should be made by the

employer and employee after considering the needs of

a specific situation.

• Assisted Listening Devices (ALDs). These

devices amplify sound and transmit it to a
6

person’s hearing aid or to a receiver worn by

the individual. The speaker talks into a

microphone or transmitter and the listener

either uses the telecoil (t-coil) on their own

hearing aid or wears a receiver designed to

work with the specific ALD.

• Captioned videotapes; open or closed.

Closed captioning requires the use of a

decoder to view the captions, while open

captioning displays the text automatically.

These captions are identical to captions

displayed at the bottom of the screen in

foreign language films. No special equipment

is required to view open captioning.

• Scripting. A script of the video might be

provided as a last resort if there is no

captioning, and if the visual content is not of

great significance to the information provided

through the video. However, providing the

script as a supplement to the captioned video

in advance of viewing the video gives the user

additional preparation time to understand what

will be communicated.

• Qualified sign language interpreter. For more

information, see the Equal Employment

Opportunity Commission’s (EEOC) ADA

Technical Assistance Manual for Title I,

Chapter III, 3.10.9 Providing Qualified

Interpreters at http://www.jan.wvu.edu/links/

ADAtam1.html#111.

• Communication Access Realtime Translation

(CART) Services. CART is a service in

which an operator types the spoken word into

a computer that instantly displays the typed

words in English on a monitor or other display.

This service is useful during small and large

group situations when verbatim conversation is

essential to effective communication. CART

offers word-for-word translation. This service

typically needs to be scheduled in advance of

a meeting.

• Computer-Assisted Notetaking. This service

can be used to provide effective

communication during group training sessions.

It involves the use of a laptop or personal

computer, word processing software, and

possibly a PC projector. Typically, a typist

who participates in the group activity acts as a

notetaker while the hearing-impaired individual

either watches the computer monitor or the

text projected onto a wall or screen.

• Web-based training. Use web-based meeting

software or video conferencing.

• Tape recorded meetings. After the training

session, the tape can be listened to separately

in a controlled listening environment with the

ability to rewind and playback as often as

necessary. The tapes can also be transcribed.

• TTY Videophone in a video conferencing

format. This allows for full view of the group in

addition to TTY communication directly on the

TV monitor.

• Communication Access Software. Currently,

there are innovative systems that provide

multisensory, interactive communication by

converting speech to text, and to real-time onscreen sign language. More information about

these products is provided at

www.myicommunicator.com and

www.signtelinc.com.

• Area and meeting room systems. Options

may include: FM desktop systems: portable

sound field-desktop or tote bag; FM System

with Speakers–Wireless; Conference

Microphone; Ceiling Speakers.

[9,12,13,14,16].

Tips for Assisting People with Hearing

Impairments

• Speak in a clear, normal tone; do not overenunciate or exaggerate words.

• Speak directly to the individual, even if there is

a sign language interpreter present.

• Face into the light when speaking and do not

cover or turn your face away.

• Flick the light on and off when entering a room

to draw attention to your presence.

• Offer pencil and paper. While writing a

message, do not talk; a hearing-impaired

person cannot read a note and your lips at the

same time.
7

• In situations where lights may be inadequate,

provide the individual with a flashlight to help

the hearing-impaired person lip-read in the

dark. [5,8,13].

• Use a microphone when speaking to a group.

• A presenter should repeat a question raised by

the audience into the microphone before

answering the question.

Conclusion

The risk of miscommunication, injury, and other

dangers presented to hearing-impaired workers in the

workplace can be minimized through the

implementation of the practical steps described above.

The best way to help hearing-impaired employees feel

prepared for a workplace emergency and be

motivated to use safe work practices is to

solicit their input and provide knowledge, information,

and accommodation choices.

References

1) Northern Virginia Resource Center for Deaf

and Hard of Hearing Persons. “Emergency

Preparedness and Emergency Communication

Access” December 2004.

2) NIOSH, www.cdc.gov/niosh/topics/noise.

3) U.S. Department of Labor/OSHA.

www.osha.gov.

4) U.S. Department of Labor, Office of Disability

Employment Policy. “Emergency

Preparedness for People with Disabilities,

Summary Report”. April 2004.

5) Federal Emergency Management Agency,

U.S. Fire Administration. Emergency

10) U.S. Equal Opportunity Commission. U.S.

 Department of Justice, Civil Rights Division.

 “Americans with Disabilities Act:

 Questions and Answers.” August 23, 2002.

11) U.S. Department of Justice, Civil Rights

 Division, Disability Rights Section.

 Enforcing the ADA: A Status Report

 from the Department of Justice. Issue

 4, 2003.

12) U.S. Department of Justice, Civil Rights

 Division, Disability Rights Section.

 ADA Business Brief: Communicating

 with People Who Are Deaf or Hard

 of Hearing in Hospital Settings,

 October 2003.

13) NJ Arts Access Task Force. ADA Self-

 Assessment Survey and Planning Tool.

 March 2003.

14) Job Accommodation Network. “Employers’

 Guide to Including Employees with

 Disabilities in Emergency Evacuation

 Plans”. Linda Batiste and Beth Loy.

15) Occupational Health and Safety. “Safety

 First”. Jennifer Juergens, June 2004,

 Vol. 73, No. 6, p. 94. 6) U.S. Fire Administration. Fire Risks for the

Deaf or Hard of Hearing. Publication FA-202,

December 1999.

8) U.S. Fire Administration. Orientation Manual

 for First Responders on the Evacuation of

 People with Disabilities. Publication FA-235,

 August 2002.

 9) National Organization on Disabilities.

 Emergency Preparedness Initiative: Guide on

 the Special Needs of People with Disabilities

 for Emergency Managers, Planners and

 Responders 2002. www.nod.org, (202) 293-

 5960, TDD: (202) 293-5968.

7) USDA Employee Emergency Response

Guide. Emergency Evacuation Suggestions for

Individuals with Disabilities, pp. 29-30.

Procedures for Employees with Disabilities in

Office Occupancies.
8

16) ADA and Accommodation of the Hard of

 Hearing. Presentation at the National

 Hearing Conservation Association

 Conference, February 2005. George

 R. Cook, Au.D. CCC-A,

 Occupational Audiologist. Workplace

 Group (336) 931-0300.

 www.workplacegroup.net.

Other Useful Resources

1) U.S. Department of Justice, Civil Rights

Division, Disability Rights Section. “ADA

Information from the Department of Justice”.

The Department of Justice answers questions

about the ADA and provides free publications

by mail and fax. This 7-page document lists

pertinent ADA legal documents, general

publications and guides, Technical Assistance

Publications for Businesses and Non-Profit

Service Agencies, and Technical Assistance

Publications for State and Local

Governments.

2) The Office of Disability Employment Policy

Technical Assistance Programs: Training and

Technical Assistance to Providers (T-TAP) at

www.t-tap.org,The National Center on

Workforce and Disability for Adults (NCWDAdults) at www.onestops.info, National

Collaborative on Workforce and Disability for

Youth (NCWD/Youth) at www.ncwdyouth.info, The Job Accommodation Network

(JAN) at www.jan.wvu.edu, and The

Employer Assistance Referral Network

(EARN) at www.earnworks.com.

3) Resources for Assisted Listening Devices.

Hearing Products Report

www.hearingproductsreport.com.

4) U.S. Department of Justice, Disability Rights

Section, ADA Information Services, Revised

February 2004.

5) The Better Hearing Institute,

 http://www.betterhearing.org/

 hearing_solutions/listeningDevices.cfm

6) The Access Board, An independent federal

agency devoted to accessibility for people

with disabilities. Provides technical assistance

in ADA and ADAAG.

www.access-board.gov/links/disability.

U.S. Department of Transportation,

www.dot.gov, Federal Transit Administration,

Easter Seals Project ACTION,

www.projectaction.org. ACTION is a

national technical assistance program to

facilitate cooperation between the disability

and transportation communities. It offers

various resources, training and technical

assistance to make the ADA work for everyone.

7)
9

 www.jan.wvu.edu

U.S. Department of

Justice...

www.justice.gov

ADA Information

Services...

www.usdoj.gov/crt/

adahom1.htm

U.S. Fire

Administration...

www.usfa.fema.gov

Federal Emergency

Management

Agency...

www.fema.gov

National Institute

Occupational Safety

and Health...

Federal Agency Resources-Public Education

Websites

U.S. DOL www.dol.gov ODEP - Job

Accommodation Network (JAN)

www.jan.wvu.edu

U.S. Department of Justice www.justice.gov

 ADA Information Services www.ada.gov

U.S. Fire Administration www.usfa.fema.gov

Federal Emergency Management Agency

www.fema.gov

National Institute Occupational Safety and

Health www.cdc.gov/niosh/topics/

The Access Board www.access-board.gov

Independent Federal Agency

U.S. Department of Commerce www.doc.gov

National Oceanic and Atmospheric

Administration www.noaa.gov

U. S. Department of Transportation

www.dot.gov

Easter Seals Project Action

www.projectaction.org

U. S. Department of Education www.ed.gov

National Institute on Disability and

Rehabilitation Research (NIDRR)

U.S. Federal Communications Commission

www.fcc.gov. For information on

Telecommunication Relay Services

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