When duty holders document how and when they implemented each of the elements of a Hearing Conservation Program (HCP) (or Noise Management Program) they may be better prepared to demonstrate compliance with applicable regulations.
In addition, good records may provide evidence to help a duty holder accurately track workers hearing over time and, if necessary, record cases of work-related noise-induced hearing loss in respect of worker compensation claims.
Many companies adopt a philosophy of, “document everything” while others keep records of only what is required. Despite the extra effort required to document all the actions that have been taken to reduce worker exposure to hazardous noise, doing so may help to strengthen the duty holders ability to demonstrate the effectiveness of the HCP in the event of an inspection, audit, or program evaluation.
Consider whether HCP records will be maintained electronically or on paper or both and whether records will be held in a central database or at each location. A well-defined process that is consistently followed helps to reduce the likelihood of missing records and may increase the usefulness of the data.
For each type of information that is included in HCP records, the employer needs to decide who is responsible for capturing the data and who will be able to view the records once they are saved. Limiting access to records to those who have a need to review data for program management purposes helps reduce the possibility that records are compromised in some way or that data are inadvertently modified or deleted.
Since HCP records may include confidential health information, it is recommended that these records be protected to help protect the privacy of individual workers and assure that only those who have the proper credentials have access to sensitive data. In addition, there may be applicable data or health privacy regulations governing the storage, access to, or transmission of information, so make sure to contact your legal advisor and ensure full compliance with any such rules and regulations.
For general industry, duty holders should keep an accurate record of noise exposure measurements and audiometric test records for the duration of employment of the worker who are in the HCP.
The types of hearing test records to be retained include:
Duty holders can only provide access to individual workers audiometric testing results to other parties with the consent of the worker. Unidentifiable individual audiometric testing results and group data can be accessed by Health & Safety representatives, Health & Safety Committee member/s, and OH&S inspectors. When ownership of the company changes or workers are transferred to a new duty holder, the noise exposure and hearing test records described above must be transferred to the successor duty holder.
Workers who suffer noise-induced hearing loss related to their employment can make a claim for compensation under their State or Federal Workers Compensation Legislation.
The benefits obtained when duty holders carefully record what they are doing to prevent hearing loss are, in large part, proportional to the accuracy, completeness and accessibility of the documents.
Most decisions made by the duty holders that manage HCPs are dependent on the quality of the data kept by the duty holders. When the data contain errors or there is excessive variability, it can lead duty holders to doubt the accuracy of the records and make it difficult to confidently manage their program. To help prevent that from happening, establish a robust process for keeping records and verify that the key duty holders in the program are following that process. Each duty holder who has access to HCP records should be trained to look for indications that records are not accurate or do not reflect what has been done to implement the program. In addition, make sure to consult with your legal advisor to ensure that all applicable government rules and regulations are followed with respect to storage, access to, and transmission of personal and health information.
Records are most useful when they are complete and have been kept consistently over time. This is especially critical when it comes to audiometric test data. If the audiometric records indicate that an worker has experienced a Significant Threshold Shift, the duty holder must conduct follow-up actions. If the Significant Threshold Shift is potentially recordable, key information is needed to determine if the hearing shift is due, at least in part, to workplace noise exposure. Missing records, inaccurate information, or gaps in the data make it very difficult for the audiologist or medical professionals who reviews the records to make that decision, and the duty holder may have no other option than to assume that the hearing loss is work-related.
Although the security of records must be maintained, duty holders must make key records available to workers, their Health and Safety representatives, Health & Safety Committees and inspectors or representatives of regulatory agencies. To help maintain control of documents, establish a system in which a limited number of people who have direct access to the records can share copies of documents with others who need to view them.
Under Work Health and Safety Legislation in Australia, Health surveillance records must be retained for 30 years after the date the record is made.
Consider keeping other records for the same period of time, including those related to:
Noise, SafeWork Australia
See “Codes and Guides” tab links to: Model Code of Practice: MANAGING NOISE AND PREVENTING HEARING LOSS AT WORK: October 2018
This page also includes links to State and Territory Regulators for specific local requirements
The Australian Standard AS/NZS 1269 series, Occupational noise management (1 – 4), provides technical requirements and guidance on all facets of occupational noise management.
IMPORTANT NOTE: This information is based on selected current national requirements. Other country or local requirements may be different. Always consult User Instructions and follow local laws and regulations. This website contains an overview of general information and should not be relied upon to make specific decisions. Reading this information does not certify proficiency in safety and health. Information is current as of the date of publication, and requirements can change in the future. This information should not be relied upon in isolation, as the content is often accompanied by additional and/or clarifying information. All applicable laws and regulations must be followed.