Flexible Workforces Hiding Increased Risk

Is Your Flexible Workforce Hiding Increased Risks?

By John C. Dolehanty

September 2005

The utilization of the flexible workforce has become a staple in the manufacturing industry. The productivity gains from this flexibility in the workplace have been enormous as it allows companies to maximize the potential of their existing workforce. The increased flexibility also brings with it some challenges for employers. One of the questions raised is: How is risk potential assessed for employees that are no longer tethered to a single job or even a group of jobs? The impact of flexible workforce implementation on employee Noise Exposure Risk, Hearing Conservation Inclusion and Noise Control are just now being coming to the forefront.

For the purposes of this article, the definition of flexible workforce is one that allows, encourages or otherwise mandates employees to know and work a variety of different jobs and duties. The implication of worker cross-training is that skilled labor becomes a flexible resource that can be assigned dynamically to a number of machines, work centers, or manufacturing cells. This is typically implemented either through a team concept where employees cycle through a set number of jobs, or employees are assigned duties based upon varying daily workforce needs.

We reduced noise levels in the plant. Why are we including more people in our Hearing Conservation Program?

As a general rule, a flexible workforce will increase the number of employees at risk to being exposed to high noise exposure jobs. If there are jobs producing sound exposure levels in excess of 85 dBA TWA_8hr and management practices allow employees the potential to work any of these jobs, it should be assumed for the purpose of Hearing Conservation Program Inclusion that all those employees will work the loud jobs

For purposes of discussion, let’s say a facility has eight (8) jobs with the following average exposure levels:

Rotation Scenario #1: Let’s assume each employee on an eight (8) worker team rotates through these 8 jobs, working only 1 hour at each job per day. Even though 7 of the 8 hours worked per day are below 80 dBA, the overall noise exposure for each employee in this group is actually above 85 dBA TWA_8hr. This would require that all eight employees be included in the mandated hearing conservation program (HCP). This is a classic example of how one job can affect a large number of employees.

Rotation Scenario #2: Let’s assume each employee rotates through each of the jobs (for a full shift of 8 hours) on a daily basis. Even though each employee’s exposure level is 79 dBA TWA_8hr for seven out of eight working days, their overall exposure risk potential must be designated as 97 dBA TWA_8hr , since 29 CFR 1910.95(d) is based upon an 8-hour exposure time frame.

Scenario 3: Let’s assume any employee can work any of the eight jobs for any length of time, depending upon the production needs, management practices, and employee preferences. In addition, no tracking mechanism is in place to determine which employees have worked the high noise exposure job. Once again, each employee’s overall exposure risk potential must be designated as 97 dBA TWA_8hr, since the potential exists and there is no documentation to show otherwise.

Sometimes a flexible workforce can result in fewer employees being exposed to high noise levels. This is sometimes referred at as an ‘Administrative’ control, and occurs when a fixed rotation is in effect and individual job exposure levels are such that employees are rotating through jobs that are quiet enough and for sufficient duration to result in an overall sound exposure below 85 dBA TWA8hr. If the rotation has been identified as a means to reduce employee noise exposure, it can be interpreted as a control measure. In this case, deviating from this rotation pattern could affect decisions regarding Hearing Conservation Program inclusion. This has the potential to limit the amount of flexibility that employers have with their workforce.

When Henry Ford was evolving the modern manufacturing facility, one of the key innovations he introduced was job specialization. This allowed employees to repeat the same task over and over thereby improving quality while reducing time wasted changing tools and parts. In unionized environments this also led to employee ‘ownership’ of specific jobs either by job classification or seniority. This made the risk assessment straightforward because once a job was identified as having high noise levels, by extension so was the person. The job or task based exposure assessment method doesn’t really change with a flexible workforce, but employee movement between jobs changes the way Hearing Conservation Program inclusion is determined. No longer can the flexible workforce company be assured of including the right people solely based on identifying the jobs at risk.

An employer should assume a worst case noise exposure for all employees unless the employer can show, through documentation, which jobs an employee has and has not worked. Why? Consider the following responses to two questions posed to Michigan OSHA earlier this year:

Question 1: Does a one-time, one-day noise exposure to 85 dBA TWA or greater require mandatory hearing conservation program inclusion?

MI-OSHA Answer: Employee inclusion into the hearing conservation program is based on the worst case scenario, regardless of time.

Question 2: Would an employer that does not check for changes in employee work assignments (from jobs below 85 dBA TWA into jobs greater than or equal to 85 dBA TWA) on a daily basis be considered deficient?

MI-OSHA Answer: Without appropriate documentation to support individual employee noise exposure, and if employees rotate between different jobs or areas with noise levels above and below 85 dBA TWA, the employer would be remiss not to include all the employees in a hearing conservation program.

Based upon the two answers above, it is clear that tracking employee exposure potential is crucial if an employer with a flexible work force wishes to reduce the total number of employees (and the associated costs) in the Hearing Conservation Program.

Inadequate employee exposure tracking practices is a duel-edged sword: it opens the company to unnecessary liabilities for not adequately protecting its workforce, while it exposes employees to high noise levels without the protection of a Hearing Conservation Program

Why should I care about ‘Monitoring Strategies’, my Company includes ALL employees in the Hearing Conservation Program?

This option may not be appropriate for all companies. The long term costs associated with running a Hearing Conservation Program that includes all employees can indeed be daunting. In addition, the practice of including all employees into the program can actually increase Company liabilities in other areas. For example, hearing loss is a symptom to a few diseases, some fatal, (e.g. Barbiturate abuse, Lead poisoning, Meningitis, Wegener's granulomatosis.) The company could be at risk is there is a misdiagnosis of these diseases during the Company administered annual audiograms. I.e., the reviewing doctor cannot just summarily dismiss all hearing loss indicating audiograms as “non-occupationally related”.

How does Increased Noise Exposure Risk from Flexible Workforces Impact My Business?

Each employee exposed to levels of 85 dBA TWA_8hr or greater needs to be included in an on-going and effective Hearing Conservation Program. In the U.S. this requires employers to provide the following, free of charge to the employee.

Control actions for reducing employee noise exposure risks boil down to two categories: either an Administrative or an Engineering Control, or a combination of both.

Limiting exposure levels with administrative actions can be an effective control measure. The two biggest drawbacks to this approach are the constraints that are placed on workforce resources and the need for effective documentation of the administrative control.

An administrative control example can be demonstrated using the previously referenced “Job A … Job H”. If only employee X was authorized to work Job H, all other employees could be safely removed from the Hearing Conservation Program. Preventing a portion of the employee population from being exposed to high noise level jobs via an administrative control may however ‘fly in the face’ of management’s philosophy of employing a flexible workforce. In addition, the control can only be deemed effective, if the employer can prove that employees are not being exposed to high noise levels. This can be a major undertaking for some employers.

The effectiveness of reducing noise exposure levels using engineer controls will always depend greatly upon how a workforce interacts with its high noise level jobs.

For example, let’s explore the difference between the previously cited employee rotation scenarios #1 and #2. Under rotation scenario #1, a sound level reduction of 2 dBA at Job G will effectively remove all 8 employees from the mandated Hearing Conservation Program. This assumes that the 8 person work group rotation, as an administration control, is adequately documented. However, under rotation scenario #2, Job G must be reduced fully below 85 TWA_8hr in order for there to be any benefit to the employee’s noise exposure risk and their exclusion form the mandatory Hearing Conservation Program.

As effectively demonstrated by these two simple employee rotation scenarios, the effectiveness and scope of noise controls efforts is highly dependent upon the manner in which management dictates employee interaction with high noise source jobs.

This can dramatically affect noise control planning. The difference in cost to implement controls to reduce sound levels by 12 dB vs. 2 dB could be substantial and in many cases may be the stumbling block that prevents them from being implemented. Looking at the business case for implementation from a different perspective, it may be quite defensible to install control measures to reduce noise levels by 2 dB and thus remove a large number of people from inclusion in a Hearing Conservation Program.

The concept of large groups of people being affected by a few or as little as one job with high noise exposure has the potential to change the dynamics of noise control planning for many companies.

It’s vital that work force noise exposures be tracked correctly. As demonstrated above, the exposure level is more then just documenting a source’s sound level – it must also account for how an employee interacts with their noise source(s). The difficulty in tracking this ‘employee-source’ interaction will vary from company to company, and even from department to department with a single company.

Noise control strategies should acknowledge and account for how employees interact with their noise sources. The actual benefit of any noise control can only be known when this interaction has been fully revealed. If this ‘employee-source’ interaction is not being recognized at your facility, it may be a good time to reexamine your noise control strategies.

When an exposure assessment methodology does not account for ‘employee-source’ interaction (whether it be for noise, air contaminates, etc.), the Company and its employees are both at increased risk.

Mr. Dolehanty is the President of Phase To, Inc., and has over 18 years of experience in hearing conservation and noise control. Mr. Dolehanty can be reached at (517) 886-9379 and at johndolehanty@phaseto.com.

Copyright © 2006 Phase To, Inc.