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Hearing Conservation Program and Annual Audiogram Procedures

FSIS Notice 01-25
Issue Date Jan 14, 2025
Expiration Date Jan 01, 2026
Full Notice
FSIS Notice 01-25
  1. PURPOSE
    This notice provides the instructions the Agency follows to implement the FSIS Hearing Conservation Program (HCP) as required by the Occupational Safety and Health Administration (OSHA) and in accordance with 29 CFR 1910.95, Occupational Noise Exposure. This notice outlines the new process for scheduling and providing annual audiograms for FSIS employee utilizing portable audiometric testing devices (PATDs). The Office of Management, Office of Human Resources, Human Resource and Operations Division (HROD) will evaluate these new instructions at the end of the fiscal year for potential inclusion in FSIS Directive 4791.1, Basic Occupational Safety and Health Program.
  2. BACKGROUND
    FSIS is required to maintain an Occupational Safety and Health (OSH) Program that complies with the Occupational Safety and Health Act of 1970, Executive Order 12196, Occupational Safety and Health Programs for Federal Employees and 29 CFR 1960, Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters.
  3. HEARING CONSERVATION PROGRAM (HCP)
    1. FSIS employees who are at risk for, or have a known exposure to, continuous noise equal to, or exceeding, 85 decibels (dBA) for an 8-hourtime weighted average time weighed average (TWA) are included in the HCP and offered an annual audiometric examination by FSIS. 85 dBA is a noise or sound level equivalent to a food blender, heavy traffic while you're in the car, a noisy restaurant or a cinema. So typically, only in-plant field employees are exposed to this continuous noise level. Employees that are exposed and would like an annual audiometric examination are to coordinate with a PATD custodian (assigned by districts or supervisors). The HCP consists of the following elements:
      1. Hazard identification and exposure monitoring
      2. Control methods (using the hierarchy of controls)
      3. Hearing protection devices (selection, use, and maintenance)
      4. Baseline and annual audiometric testing
      5. Hazard communication, education, and training
      6. Recordkeeping, and
      7. Continuous monitoring and improvement (program review)
  4. CONTROLS/HEARING PROTECTION DEVICES
    1. As feasible, engineering and administrative controls are implemented by the Office of Management, Administrative Services Division's (ASD) Safety and Physical Security Branch as the first line of defense when employees are exposed to sound levels greater than an 8-hour TWA of 85 dBA. Hearing protection devices (HPDs) are provided to FSIS employees by FSIS when engineering or administrative controls fail to reduce the sound levels below the 8-hour TWA of 85 dBA. The Agency provides HPDs at no cost to all employees and are available through the FSIS Consolidated Supply Catalog.
    2. FSIS industrial hygienists (IH) and Occupational Safety and Health (OSH) staff can evaluate hearing protector attenuation for the specific noise environments in which the protector is to be used and use one of the evaluation methods described in OSHA Standard 29 CFR 1910.95 Appendix B: "Methods for Estimating the Adequacy of Hearing Protection Attenuation."
  5. AUDIOMETRIC TESTING
    1. On a monthly basis, the FSIS HCP Contracting Officer's Representative (COR) creates a list of FSIS employees that are eligible for their annual audiogram based on their date of hire and/ or previous test dates and provides it to the ASD District Representative (DR). The DR shares this list with the Front-Line Supervisor (FLS) or their designee. The FLS or designee is to subsequently notify the employees to offer onsite audiological testing using the PATD.
    2. Upon completion of the audiometric exam, the results are automatically transmitted to an audiologist for review by the testing device. The audiologist compares each annual audiogram to the employee's baseline audiogram to determine if any shifts in hearing have occurred. After evaluating the audiometric exam, the audiologist returns the evaluation results to ASD for inclusion in the employee's medical record.
    3. FSIS employees have the option to decline audiometric testing. If an employee chooses to decline, the FLS or DR ensures the employee signs a declination statement confirming that the offer for audiometric testing was made, but not accepted.
  6. BASELINE AUDIOGRAMS
    1. The initial audiogram conducted for all new hires serves as the employee's baseline audiogram. Baseline Audiometric Test Scores for all employees are stored in the Employee Medical Folder (EMF) shared drive and ASD Baseline Audiograms locations. The HROD Medical Team is to upload audiometric test scores for all new hires to these locations. The audiologist is to utilize the baseline results to evaluate any abnormal findings or Standard Threshold Shifts (STS) that may indicate hearing loss.
    2. The HCP COR identifies and removes Personally Identifiable Information (PII), and then transmit these scores to the contractor for review. Monthly, the COR is to provide the audiologist a list of baseline scores for all newly hired FSIS employees.
    3. The HROD Medical Team is to store all audiometric testing in the EMF.
    4. The HCP COR is to review accession reports, locate baseline results via medical files folder, and enters results into the portable audiometric testing system (PATS) database.
    5. The HCP COR is to de-identify the Baseline Test Scores during the transfer into the PATS Database by removing PII and substituting it with non-PII identifiers by:
      1. Removing PII, such as last names, dates of birth, and last four digits of Social Security Numbers.
      2. Replacing PII with non-PII identifiers, such as Employee ID number and a randomly assigned PIN; and
      3. If the COR is unable to locate a file for an employee, they are to contact the HROD Medical Team for assistance.
      NOTE: If an employee's baseline audiogram is missing, the new annual audiogram serves as a baseline going forward.
    6. The HROD team is to store the evaluation results in the employee's medical file and the audiologist uploads the results to the PATS database for comparative analysis of future testing.
  7. PROCEDURES FOR ANNUAL AUDIOMETRIC EXAMS
    1. Each district office (DO) is assigned 10 PATDs. The DO is to designate the PATD custodians who are responsible for the equipment and receive HCP correspondence.
    2. The PATD custodians are required to complete the Audiometric Testing Device training and Portal training before conducting any exams.
    3. Each month the HCP COR is to provide the PATD custodians a list of employees due for annual audiometric testing based on their last test dates. The PATD custodian is to inform employees on the list that they are due for an annual hearing test.
    4. Weekly, the PATD custodians is to connect the PATD to Wi-Fi- to receive data and device updates.
    5. To conduct an audiometric test the PATD custodian is to:
      1. Identify a compliant space to conduct the exam in accordance with the Testing Environment and Room Selection guidelines. Reviews the Testing Checklist to ensure functionality of hardware;
      2. Review the Hardware Cleaning and Infection Control guidelines before every exam to ensure the disinfection of hardware;
      3. Log into the portable device to begin the audiometric exam referencing the Audiometric Testing Device training as necessary;
      4. Provide the employee with their unique ID number and PIN and have the employee log into the device using the ID number, PIN and birth year.
      5. Provide the Hearing Test Instructions to the employee. The employee will complete the audiometric exam on the portable device.
      6. At the completion of the audiometric exam, connect the device to the internet, utilizing the Data Transfer guidelines to transmit the results to the audiologist. The audiologist will compare the current results against the employee's baseline audiometric scores to assist in this process.
    6. The audiologist is to identify abnormalities and provide a report to the Office of Field Operations (OFO) Representative. The HCP COR is to notify the OFO Representative to schedule a retest of the FSIS employee if warranted.
    7. The HCP COR is to download the report of audiometric testing results and restore the PII and job classification to the file by renaming the report according to the Human Resources (HR)-approved naming convention. (Last Name, First Name Last 4 digits of SSN). The HCP COR is to upload the file to the ASD Occupational Hearing Test Dropbox for Annual Audiometric Testing.
    8. HR is to access the ASD Occupational Hearing Test Dropbox to transfer all annual audiometric tests into the employee medical file (EMF).
  8. PROCEDURES FOR ABNORMAL RESULTS AND STANDARD THRESHOLD SHIFT
    1. An STS is any change in hearing threshold of 10 dB or more at 2000, 3000 and 4000 Hz in either ear (OSHA 1910.95(g)(10)(i) when compared to the baseline audiogram. At the completion of the testing, employees will be alerted by the COR via email of a possible abnormal result. Upon confirmation by the audiologist, a determination of a possible STS will be made.
      1. If the audiologist identifies a shift in hearing, they are to notify the employee, their supervisor, the COR and the OFO Representative in writing within 21 days of the annual testing, indicating that follow-up testing is required.
      2. The PATD custodian is to conduct follow-up audiometric testing when an individual's audiogram shows a possible STS relative to the applicable reference audiogram for each ear.
      3. Once notified by the audiologist, the OFO Representative is to schedule a retest to confirm the hearing shift within a 30-day period.
    2. A confirmed threshold shift is when the STS in one or both ears is confirmed by a second audiogram.
      1. If a positive STS is confirmed on the second follow-up hearing test, the HCP COR is to notify the employee, their immediate supervisor, and the OFO Representative in writing within 21 days after the completion of the audiogram.
      2. The COR is to use the results of the retest as the annual audiogram.
      3. The COR is to conduct further follow-up testing, if the STS persists, to validate the existence of a permanent noise-induced threshold shift or to determine if further medical referral is required.
    3. The FSIS provided audiologist, an otolaryngologist, or other physician is to perform evaluations to determine whether the STS is work-related or has been aggravated by occupational noise exposure. After the STS is documented the physician or audiologist may determine how to proceed.
  9. QUESTIONS
    Refer questions to the Safety and Occupational Health Specialist or Industrial Hygienist assigned to your respective District.