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Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.


September 11, 1991

C. John Hodgson, M.D.
Medical Director
Paul, Minnesota 55144-1000

Dear Dr. Hodgson:

Thank you for your letter of August 14, regarding the recording of hearing loss on the OSHA 200 Log. We appreciate the presentation of your professional opinion and value your offer to participate in the Occupational Safety and Health Administration's (OSHA) proposed rulemaking activities.

We are forwarding a copy of your letter to Mr. Stephen Newell, Director, Office of Statistics. Mr. Newell will be coordinating the agency's activities regarding any proposed changes to the current recordkeeping guidelines.

Again, thank you for your comments and interest in safety and health issues.

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs



August 14, 1991

Patricia Clark, Director
Directorate of Compliance Programs
U.S. Department of Labor
Occupational Safety and Health Administration
Washington, DC 20210

RE: Recording of Hearing Loss on the OSHA 200 Log

Dear Ms. Clark:

As occupational medical professionals in a corporation with an extensive hearing conservation program encompassing more than 12,000 employees, we are concerned about the recent memorandum directed to OSHA Regional Administrators regarding the recording of hearing loss on the OSHA 200 Log. In our opinion this memorandum neither enhances nor improves the safety and health of the work force, but rather compromises the effectiveness of 29 CFR 1910.95 and will have an adverse effect on industrial workers who are exposed to excessive noise levels in the workplace.

As a consequence, we strongly encourage you to revise your position in this area and adopt the position expressed to Secretary Scannell in a letter dated July 15, 1991 from a coalition consisting of: the American Speech-Language-Hearing Association; the National Hearing Conservation Association; the American College of Occupational Medicine; the Council for Accreditation in Occupational Hearing Conservation; and, the American Academy of Otolaryngology - Head and Neck surgery. 3M fully endorses the views expressed in this document and attaches a copy thereof to this letter. In essence, this organizational coalition suggests that the recordability recommendations made by the American Industrial Hygiene Association, which utilize a confirmed work-related average threshold shift of 10 dB at 2000, 3000 and 4000 Hz, be adopted.

If it is determined that formal rulemaking be undertaken on this issue, please be advised that 3M would welcome the opportunity to be an active participant and contributor in assisting your office in achieving an effective and feasible final rule.

In the interim, we urge your immediate attention to this matter and invite you to contact us for any further information.

Very truly yours,



C. John Hodgson, M.D.
Medical Director

Rena H. Glaser, M.A., CCC-A Manager, Hearing Conservation



Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.


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