May 2011- Occupational Noise Exposure & Toxic Release Inventory

What is occupational noise exposure?

Noise, or unwanted sound, is one of the most pervasive occupational health problems and is a by-product of many industrial processes. Exposure to high levels of noise causes hearing loss and may cause other harmful health effects as well. The extent of damage depends primarily on the intensity of the noise and the duration of the exposure. Noise-induced hearing loss can be temporary or permanent. Temporary hearing loss results from short-term exposures to noise, with normal hearing returning after period of rest. Generally, prolonged exposure to high noise levels over a period of time gradually causes permanent damage. OSHA's hearing conservation program is designed to protect workers with significant occupational noise exposures from hearing impairment even if they are subject to such noise exposures over their entire working lifetimes.

What monitoring is required?

The hearing conservation program requires employers to monitor noise exposure levels in a way that accurately identifies employees exposed to noise at or above 85 decibels (dB) averaged over 8 working hours, or an 8-hour time-weighted average (TWA). Employers must monitor all employees whose noise exposure is equivalent to or greater than a noise exposure received in 8 hours where the noise level is constantly 85 dB. Employers must repeat monitoring whenever changes in production, process, or controls increase noise exposure. 

What is audiometric testing?

Audiometric testing monitors an employee's hearing over time. It also provides an opportunity for employers to educate employees about their hearing and the need to protect it.

The employer must establish and maintain an audiometric testing program. The important elements of the program include baseline audiograms, annual audiograms, training, and follow-up procedures. Employers must make audiometric testing available at no cost to all employees who are exposed to an action level of 85 dB or above, measured as an 8-hour TWA.

When is an employer required to provide hearing protectors?

Employers must provide hearing protectors to all workers exposed to 8-hour TWA noise levels of 85 dB or above. This requirement ensures that employees have access to protectors before they experience any hearing loss.

Employees must wear hearing protectors:

  1. For any period exceeding 6 months from the time they are first exposed to 8-hour TWA noise levels of 85 dB or above, until they receive their baseline audiograms if these tests are delayed due to mobile test van scheduling; 
  2. If they have incurred standard threshold shifts that demonstrate they are susceptible to noise; and 
  3. If they are exposed to noise over the permissible exposure limit of 90 dB over an 8-hour TWA.

What training is required?

Employee training is very important. Workers who understand the reasons for the hearing conservation programs and the need to protect their hearing will be more motivated to wear their protectors and take audiometric tests. Employers must train employees exposed to TWAs of 85 dB and above at least annually in the effects of noise; the purpose, advantages, and disadvantages of various types of hearing protectors; the selection, fit, and care of protectors; and the purpose and procedures of audiometric testing. The training program may be structured in any format, with different portions conducted by different individuals and at different times, as long as the required topics are covered.

What exposure and testing records must employers keep?

Employers must keep noise exposure measurement records for 2 years and maintain records of audiometric test results for the duration of the affected employee's employment. Audiometric test records must include the employee's name and job classification, date, examiner's name, date of the last acoustic or exhaustive calibration, measurements of the background sound pressure levels in audiometric test rooms, and the employee's most recent noise exposure measurement.

Beginning January 1, 2003, employers also will be required to record work-related hearing loss cases when an employee's hearing test shows a marked decrease in overall hearing. Employers will be able to make adjustments for hearing loss caused by aging, seek the advice of a physician or licensed health-care professional to determine if the loss is work-related, and perform additional hearing tests to verify the persistence of the hearing loss

For links to more in-depth information see the Noise and Hearing Conservation page on OSHA’s website.

What do the toxic release inventory (TRI) regulations require?

Facilities must report release and other waste management information pursuant to EPCRA Section 313 if they:

  1. have 10 or more full-time employees or the equivalent;
  2. are in a covered NAICS code;  and
  3. exceed any one threshold for manufacturing (including importing), processing, or otherwise using a toxic chemical listed.

EPCRA Section 325 allows civil and administrative penalties ranging up to $10,000-$75,000 per violation or per day per violation when facilities fail to comply with the reporting requirements.

Click here for more information on reporting requirements

Toxic Release Inventory Facts

 Topic  Brief Overview  Deadline  Links

Toxic Release Inventory (TRI) Reporting (SARA, 313)

Facilities that manufacture process or otherwise use Section 313 chemicals must submit this report annually to the EPA. The TRI report outlines all activities including any releases, emissions or discharges from the site that may contain Section 313 Chemicals.  

TRI reports due July 1st of each year based on the previous year’s inventory amounts.

EPA’s Online TRI Thresholds Determination Tutorial

Laws and Regs

TRI Program home page

TRI Reporting Materials and Guidance

Basic Info


Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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