Hearing Protection Devi ces 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 “passiv e” hearing protector devices (HPDs).

• Wanted to come up with simple, understand able phrases that could still convey the meaning of the origin al 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 th e HPD had to indicate what the product actually does. Decided that ultimately, th e label was not intended to give the functionality of the device. If there was a ny essential information, it would be allotted to Section C.

• The “active” label was confusi ng because while the public thinks that it only includes electronic devices, it also incl udes Level Dependent HPDs.

• Discussed different possibilities as substitu tions 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 accura te, 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 Sec tion C to further aid the user.

• Some were worried that the noise re duction ratings (NRRs) for “BASIC” and “NOISE CANCELLING ON” functions woul d change with impulsive noises. However, it was established that the N RRs 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 pictogr ams. Idea was not accepted, because manufacturers will likely put instructional pictures on the packaging, and there was a limit to the amount of sp ace inside the labels.

• Emphasized consistency with wording and general design.

• Discussion on how to differentiate betw een “BASIC,” “IMPULSE,” and “NOISE CONTROLLING ON” with active noise redu ction 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” a nd 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 t ypes 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 le vel-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 impulse s will be tested, as this HPD has no attenuation at lower levels.

• Discussed possible re-labeling of “IMPUL SE” 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.