Safety Policies & Programs

Policy Key Points

Policy

Introduction

This policy initiates and establishes a hearing conservation program that complies with OSHA 29 CFR 1910.95 to protect Yaskawa America, Inc. associates from the effects of occupational noise exposure.

The Hearing Conservation Amendment to the OSHA Occupational noise exposure standard, 29 CFR 1910.95, requires that employers establish a hearing conservation program for employees whose noise exposures equal or exceed an 8-hour time-weighted average (TWA) of 85 dBA.

Scope of Policy

This policy establishes a Hearing Conservation Program (HCP) for Yaskawa associates who are assigned to duties where noise exposures are anticipated to be at or above 85 decibels (dBA) as an 8-hour time-weighted average (TWA).

Yaskawa work areas that are at or exceed 85 dBA TWA:

• As of October 26, 2016, there are no Yaskawa work areas where it is anticipated that an associate will be exposed.
• This program will be updated as work areas are identified that are at or exceed 85 dBA TWA.

Requirements for Hearing Protection outlined in this policy, apply to all Yaskawa facilities and work areas.

General Requirements

Whenever feasible, Yaskawa associates are encouraged to avoid exposure to hazards, including noise.

Yaskawa associates subject to this policy are to limit their exposure to noise to the minimum duration necessary, and to wear hearing protection as required for the safe completion of their duties.

Noise Monitoring

The success of this hearing conservation program depends on an accurate knowledge of the existing noise environment.

Accurate surveys define areas within acceptable guidelines for noise exposure and those areas where potentially harmful noise exposure exists.

• During Job Hazard Assessments, a smartphone application is used to perform the initial sound testing. (This is also used during safety audits and walk-throughs when the sound is louder than conversational level.) The smartphone applications used have been measured against calibrated noise meters and are within ± 2dB. Any measurements greater than 80dB require additional testing with a calibrated noise meter.

Effective noise exposure measurement prevents possible loss of hearing by detecting work areas where employees must wear hearing protectors and must be tested.

Therefore, Yaskawa conducts detailed noise surveys using sound level meters that meet the appropriate ANSI standard and are calibrated acoustically before and after each survey.

When information indicates that any employee's exposure may equal or exceed an 8 hour time weighted average of 85 decibels, Yaskawa will implement this monitoring program.

Yaskawa shall conduct sampling on an annual basis and whenever new equipment is installed which may contribute to any employee’s exposure.

This sampling will be designed to identify employees for inclusion in the hearing conservation program and to enable the proper selection of hearing protectors.

• Monitoring shall be repeated whenever a change in production, process, equipment or controls increases noise exposures to the extent that:
  • Additional employees may be exposed at or above the action level, or
  • The attenuation provided by hearing protectors being used by employees may be rendered inadequate.

The company shall notify each employee exposed at or above an 8 hour time weighted average of 85 decibels of the results of the monitoring.

Observation of monitoring. Yaskawa shall provide affected associates with an opportunity to observe any noise measurements conducted.

At this time, no Yaskawa work areas have been identified (exposure to at or above an 8 hour time weighted average of 85 decibels or greater) to trigger this monitoring program. This is re-evaluated annually.

Associate Monitoring

Associate Monitoring will occur when Yaskawa's Hearing Conservation Program is triggered. At this time, no associate monitoring is warranted.

The requirements in this section apply when Associate Monitoring is warranted.

Baseline Audiogram

Within 6 months of an employee's first exposure at or above the action level, this company will establish a valid baseline audiogram against which subsequent audiograms can be compared.

• Testing to establish a baseline audiogram will be preceded by at least 14 hours without exposure to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline audiograms be preceded by 14 hours without exposure to workplace noise.
• Yaskawa will notify employees of the need to avoid high levels of non-occupational noise exposure during the 14 hour period immediately preceding the audiometric examination.

Annual Audiogram

At least annually after obtaining the baseline audiogram, the Yaskawa shall obtain a new audiogram for each associate exposed at or above an 8 hour time weighted average of 85 decibels

Evaluation of Audiogram

Each associate's annual audiogram should be compared to her/his baseline audiogram to determine if the audiogram is valid and if a standard threshold shift has occurred. This comparison may be done by an individual trained to technician level. If the annual audiogram shows that an associate has suffered a standard threshold shift, a retest shall be accomplished within 30 days and the results considered as the annual audiogram.

Problem Audiograms

Yaskawa shall ensure that an audiologist, otolaryngologist, or physician review problem audiograms (those where the test results and expectations are vastly different indicating testing irregularity or a significant threshold shift has occurred) and determine whether there is a need for further evaluation.

Follow-Up Procedures

If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold shift has occurred, the employee shall be informed of this fact in writing, within 21 days of the determination.

Standard Threshold Shift

A standard threshold shift is a change in hearing threshold relative to the baseline audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.

In determining whether a standard threshold shift has occurred, allowance may be made for the contribution of aging (presbycusis) to the change in hearing level by correcting the annual audiogram according to the procedure described in Appendix F, 29 CFR 1910.95

Unless a physician determines that the standard threshold shift is not work related or aggravated by occupational noise exposure, the employer shall ensure that the following steps are taken when a standard threshold shift occurs:

• Associates exposed or potentially exposed to high noise shall be fitted with hearing protectors, trained in their use and care, and required to use them.
• Associates already using hearing protectors shall be refitted and retrained in the use of hearing protectors and provided with hearing protectors offering greater attenuation if necessary.
• Associates shall be referred for a clinical audiologic evaluation or an otological examination, as appropriate.
• Associates shall be informed of the need for an otological examination if a medical pathology of the ear that is unrelated to the use of hearing protectors is suspected.

Revised Baseline

An annual audiogram may be substituted for the baseline audiogram when, in the judgment of the audiologist, otolaryngologist or physician who is evaluating the audiogram determine that:

• The standard threshold shift revealed by the audiogram is persistent, or
• The hearing threshold shown in the annual audiogram indicates significant improvement over the baseline audiogram.

Audiometric Test Requirements

Audiometric tests conducted shall be pure tone, air conduction, hearing threshold examinations, with test frequencies including as a minimum 500, 1000, 2000, 3000, 4000, and 6000 Hz.

Tests at each frequency will be taken separately for each ear in accordance with 1910.95 ((h) Audiometric test requirements).

Hearing Protection

This section applies to all Yaskawa Facilities and all Yaskawa associates, whether or not the Hearing Conservation Program is triggered.

Yaskawa provides hearing protection at no cost to:

• Any associate who requests hearing protection,
• Any associate exposed to noise exposures at or above those shown in the following table:

Permissible Noise Exposures
Duration per day, hours	Sound level dBA slow response
8	90
6	92
4	95
3	97
2	100
1 ½	102
1	105
½	110
¼ or less	115

Yaskawa associates exposed to noise exposures equal or greater than shown in the above table must wear appropriate attenuating hearing protection.

Dual hearing protection shall be worn if exposures exceed 105 dB as an 8-hour TWA.

Yaskawa associates are provided the opportunity to choose their hearing protectors from a variety of types, with suitable attenuation characteristics.

Factors to consider include comfort, communication, hearing ability, compatibility with other personal protective equipment, and the environment in which they will be worn.

Training in use and care of hearing protectors is required. Hearing protectors must be properly fitted and their correct use must be demonstrated.

The associate’s immediate supervisor shall provide this training.

Hearing protectors must provide appropriate attenuation. (See 29 CFR 1910.95 Appendix B)

Hearing protectors must attenuate noise exposure to at least 90 dBA as an 8-hour TWA.

Associates who have experienced a standard threshold shift (average 10dB or more loss in one or both ears relative to the most current baseline audiogram averaged at 2000, 3000 and 4000 Hz) must attenuate noise exposure to at least 85 dBA as an 8-hour TWA.

Records and Forms

Elementary noise measurements taken with a smartphone application are recorded in the Job Hazard Assessment. (Where elementary measurement exceeds 83 dB, a calibrated measurement is taken and recorded on the Noise Measurement Log maintained by the EHS Department.)

Noise Measurement Log, maintained by EHS Department

Audiometric Tests are maintained by Human Resources and retained for the duration of the affected associate’s employment plus a minimum of 5 years.

Access to Records

All records cited in this policy are provided upon request to associates, former associates, representatives designated by the individual associate, and representatives of OSHA.

If Yaskawa ceases to do business, the records will be transferred to the successor employer and maintained by the successor employer. Should the company cease to function entirely, the records shall be provided to the respective associates, or as required by law.

Results of Breaches of Policy

Breaching this policy may result in an injury. Breaches of this policy may result in disciplinary action being initiated in accordance with Yaskawa America's discipline policy.

Training

All associates who are exposed to noise at or above an 8-hour time weighted average of 85 dB will participate in Yaskawa’s Hearing Conservation Training Program.

Yaskawa’s Hearing Conservation Training Program informs associates of:

• The effects of noise on hearing,
• The purpose of hearing protectors, the advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting, use and care,
• The purpose of audiometric testing, and an explanation of the test procedures.

General hearing conservation training is provided in new associate safety orientation and in periodic refresher training.

Revision History

Rev #	Description	Release Date	Approved by
0	Initial Release	5/11/2016	Thurwanger
1	Added use of iPhone for initial sound testing with threshold for when to use a calibrated noise meter	3/12/2018	Thurwanger
2	Added check during annual review that validates there continue to be no areas that exceed 85 dBA TWA	1/25/2019	Thurwanger
3	Added the Audiometric Test Requirements minimum frequencies tested	6/5/2020	Thurwanger
4	Added the steps taken when a standard threshold shift occurs	3/12/2023	Thurwanger

Program Review

Review Date	Reviewed by	Changes Required (Yes/No)	Revision # if updated	All work areas remains <85 dBA"
2/15/2017	Thurwanger	No
1/10/2018	Thurwanger	Yes	1
1/17/2019	Thurwanger	Yes	2	Yes
1/9/2020	Thurwanger	Yes	3	Yes
1/19/2021	Thurwanger	No		Yes
1/13/2022	Thurwanger	No		Yes
1/26/2023	Thurwanger	Yes	4	Yes
1/11/2024	Thurwanger	No		Yes
1/16/2025	Thurwanger	No		Yes