Hearing Protection Devices Labeling Meeting 

January 13, 2010 

Attendees

Catrice Jefferson, EPA 

Kenneth Feith, EPA 

William Murphy, NIOSH 

Sheli DeLaney, NIOSH 

Mark Stephenson, NIOSH 

Carol Stephenson, NIOSH 

Surehder Ahir, OSHA 

Claire Slupski, NIOSH 

Elliott Berger, 3M/ANSI 

Dan Shipp, ISEA 

Meeting Minutes

• Limited discussion to only primary labels. 

• Principle concern: Language on the primary labels. Move away from technical jargon 

and make labels understandable to a layperson. 

• Primarily, wanted to change the wording on “active” and “passive” hearing protector 

devices (HPDs). 

• Wanted to come up with simple, understandable phrases that could still convey the 

meaning of the original technical word. 

• Discussed how to differentiate between different hearing protector devices. 

• Decided to label a conventional HPD “BASIC.” The language is clear, not 

controversial, and it’s close to the Spanish equivalent. 

• Discussed whether the description of the HPD had to indicate what the product 

actually does. Decided that ultimately, the label was not intended to give the 

functionality of the device. If there was any essential information, it would be allotted 

to Section C. 

• The “active” label was confusing because while the public thinks that it only includes 

electronic devices, it also includes Level Dependent HPDs. 

• Discussed different possibilities as substitutions for the “active” label. Originally 

decided to use “POWER ON” as a substitute, but the phrase was deemed too vague 

and confusing. Finally chose “NOISE CONTROLLING ON” as an appropriate 

substitute, because it was completely accurate, gave more information, and was easy 

to comprehend. 

• Discussed briefly what a better substitute for “impulsive” could be. “Impulse” was 

the designated substitution, because it was easier to understand. Additionally, 

impulsive noises were described as “gunfire type noises” in Section C to further aid 

the user. 

• Some were worried that the noise reduction ratings (NRRs) for “BASIC” and 

“NOISE CANCELLING ON” functions would change with impulsive noises. 

However, it was established that the NRRs for both of those types of hearing 

protectors would not change, even if an impulsive noise was applied. 
• Decided to employ “market research” to find out if a layperson can understand the 

new labels. 

• Discussed the possibility of pictograms. Idea was not accepted, because 

manufacturers will likely put instructional pictures on the packaging, and there was a 

limit to the amount of space inside the labels. 

• Emphasized consistency with wording and general design. 

• Discussion on how to differentiate between “BASIC,” “IMPULSE,” and “NOISE 

CONTROLLING ON” with active noise reduction HPDs. “BASIC” is the NRR of 

the device when it is not “turned OFF,” “NOISE CONTROLLING ON” is the NRR 

of the device when it is “turned ON” and the sound levels are low, and “IMPULSE” 

is the NRR of the device when an impulsive noise is introduced. 

• Removed excess scaling for the bar graphs. Standardized a design for all labels. 

• Wording of Section C discussed. “All types of noise” was inaccurate, so it was 

changed to “most common noises.” 

• “BASIC” defined: “The performance of a device absent any special features. This 

includes electronic and level-dependant features.” 

• Discussed the NRR testing for “IMPULSE” for the active noise reduction HPD. NRR 

range was based on 3 different impulses and not on user fit. Determined a phrase to 

add to Section C to accommodate the variation in testing. 

• Determined that there would be no testing of different ranges of the electric sound 

transmission HPD. Only high-level impulses will be tested, as this HPD has no 

attenuation at lower levels. 

• Discussed possible re-labeling of “IMPULSE” for the passive level-dependent HPD 

and the electric sound transmission HPD to more accurate labels that would 

differentiate between the three impulsive HPDs. Proposal not accepted in favor of 

consistency, brevity, and ease of understanding.