ASSE Comments on OSHA’s Interpretation of Hearing Protection Economic Feasibility
In submitting a comment on OSHA’s withdrawn Interpretation of Provisions for Feasible Administrative or Engineering Controls of Occupational Noise, ASSE said OSHA was correct in attempting to ensure that employers are appropriately recognizing the hierarchy of controls in minimizing noise risks. ASSE did not believe, however, that OSHA staff were prepared to make economic feasibility determinations that would be required. To assure stakeholders and learn more about making such determinations, ASSE suggested OSHA conduct an NEP to gather employer, inspector and SH&E professional views of specific situations. Incorporating efforts of OSHA’s cooperative programs and NIOSH in Prevention through Design was also urged. In this interpreation, “OSHA…propose(d) to consider administrative or engineering controls economically feasible if they will not threaten the employer’s ability to remain in business or if the threat to viability results from the employer’s having failed to keep up with industry safety and health standards.”