A VA medical center asked whether employees must be enrolled in a hearing conservation program when they experience maximum impulsive noise levels of 140 dB during activities like annual weapons qualification firing, even though their 8-hour time-weighted average exposure stays below the 85 dBA action level.
OSHA said no program is mandated in that scenario. The hearing conservation program requirement in 29 CFR 1910.95(c) is triggered by exposure at or above the 85 dBA action level as an 8-hour time-weighted average — not by peak impulse levels alone. However, OSHA encourages employers to voluntarily implement a hearing conservation program for these exposures, particularly when hearing protection is the means of controlling noise.
Two measurement and control nuances matter. First, under 29 CFR 1910.95(d)(2)(i), all continuous, intermittent, and impulsive sound levels from 80 dB to 130 dB must be integrated into exposure measurements. Second, Table G-16 states that exposure to impulsive or impact noise should not exceed 140 dB peak sound pressure level, and employers must use feasible engineering and administrative controls when sound exceeds Table G-16 limits (29 CFR 1910.95(b)(1)).
OSHA added that single hearing protection may be inadequate above 140 dB — double hearing protection is recommended — and noted its enforcement policy permits reliance on a properly administered hearing conservation program with personal protective equipment when it effectively attenuates noise to acceptable levels.