The Prevention of Recordable Hearing Loss (Part 3): Role of a Professional Supervisor

The Prevention of Recordable Hearing Loss (Part 3): Role of a Professional Supervisor


Continuing our discussion of the prevention of recordable hearing loss, today's question is: What information can help the professional supervisor make a determination regarding work-relatedness?


The National Hearing Conservation Association has recently published “NHCA Guidelines for Recording Hearing Loss on the OSHA 300 Log.” These guidelines provide general principles for Professional Supervisors. The primary principle is that Professional Supervisors must be able to substantiate their determinations and therefore, “unless there are clear and cogent reasons why the loss is entirely unrelated to the work environment” it should be considered work related and thus recordable.


Pitfalls in work-relatedness determinations

  • Ascribing hearing loss to non-occupational exposures without adequate documentation. Be very careful not to jump to conclusions. The burden of proof is on the PS/A and thus the employer to show that occupational exposure DID NOT contribute and that non-occupational factors are sufficient to cause the ENTIRE hearing loss. The PS/A has both ethical and medical-legal obligation to get the diagnosis right.
  • Assuming a given decrease in exposure due to use of HPD. You must measure this to be able to confidently assume protection. This can be measured by point measurement with earplug fit-testing or with continuous monitoring of protected exposure levels. 
  • Bending to pressure to reduce recordable cases. PS/As must follow legal and ethical standards as they use their professional judgment. Both physicians and audiologists are held to ethics codes in order to maintain their license to practice. 
  • Missing a diagnosis of other cause of hearing loss. This brings up the issue of who pays for the evaluation of hearing loss cases. While OSHA does not require the employer to pay, it may be in the employer’s best interest to pay for initial evaluation of the hearing loss. If the follow-up evaluation does not take place, the , the hearing loss is presumed to be recordable.



The prevention of recordble hearing loss is an issue that lies at the center of each and every Hearing Conservation program. In the coming weeks, we’ll continue to share – and discuss – those questions on this topic that we hear the most during our education and training sessions with employers around the U.S. 


Next: What Can Employers Do?





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