How to Control Workplace Noise

Noise Controls Engineering controls should be the first choice for dealing with noise pollution issues in the workplace, and this is NIOSH policy - they have three categories that all involve engineering and all three are ranked higher than administrative controls and PPE (NIOSH, 2015). Engineering solutions would include designing noise buffers around particular pieces of equipment, whereas administrative controls would reflect things like supplying protective equipment or scheduling people to reduce their exposure to unsafe noise levels. There are two reasons for this.

First, an engineering solution is a one-time fix that hopefully will solve the problem, so that it no longer needs to be dealt with. Second, an engineering solution deals with the problem by reducing the amount of noise, where an administrative solution merely works around the problem, but the problem still persists. There are some instances where it is onerous to use engineering controls first. In some situations, the cost would be prohibitive.

A good example is in a mine -- there may not b enough space to implement engineering controls without dramatically increasing costs. It may be cheaper and easier to implement administrative controls. Alternatively, there are situations when the noise is a temporary issue, again rendering the engineering cost a poor value. If the administrative solution is the easier an cheaper of the two, in most cases that it what should be implemented. OSHA may wish to lower its bar a little bit.

The way that the rule is written -- especially the clause "threaten the employer's ability to remain in business" -- places a potentially heavy burden on the company. The ability to remain in business is dictated by a lot of things but overall an approach that is project-based might make more sense. The availability of the project is probably a better approach rather than framing the issue as being in respect to the business as a whole.

This part is definitely onerous -- they should not have left it out, but they should have reframed it in a more realistic manner. There is no question that if PPE fails the hazard still remains, but in some cases that is reality -- heavy equipment in particular is just plan loud. PPE may not be enough, but ultimately a balance has to be struck.

PPE should be enough in certain situations -- I feel that noise controls should be on a best efforts basis, not based on setting unrealistic expectations for prefect noise control. The economic impact of any policy matters, because project decisions are based on whether or not the project is economically viable. There are two views to this. The first view is that the project should be sufficiently profitable that the company can pay for proper safety equipment.

If the project is only profitable when it has no safety equipment and workers are put at risk, then perhaps that is not a project that should be undertaken. However, economic considerations should be taken into account at least a little bit -- a generally valuable project could be scuttled by strict regulations. There needs to be some sort of balance.

I take a utilitarian view of the issue, that there are definitely going to be instances where companies will try to take advantage of the workers and the role of OSHA is to be an intermediary and balance the bargaining power, so that both sides can work together.