What should I tell the employees in our hearing conservation program about medical referrals?

You need to understand the medical referral requirements in OSHA’s noise standard so you can explain them to your employees. OSHA has recently issued a letter of interpretation to clarify these concerns.

The professional reviewer determines if an employee needs a medical referral. Examples that might indicate the need for referral are when an employee is unable to take a hearing test on a self–recording audiometer, does not respond reliably, or has visible irritation or pain that may be caused or aggravated by earplugs.

The employer is responsible for paying for referrals that are needed to accurately determine an employee’s hearing status, or if it is suspected that the provided earplugs are causing or aggravating an irritation or infection of the employee’s ear canals. Medical pathologies which are clearly not related to the wearing of hearing protectors or an otoscopically abnormal eardrum due to an allergy or cold are not the employer’s responsibility. However, the employee must be informed of the need for examination or treatment.

An audiogram is not the sole indicator of a need for a referral. As mentioned above, the professional reviewer would determine if an employee needs to be referred for further testing or examination. Often, just a retest may be indicated, especially if the first test was done when the employee was suffering from an allergy or a cold.

If the employee refuses to see a physician, employers may use whatever documentation they prefer to document that they have offered the referral.

The employer must have some form of proof that the employee was notified of his standard threshold shift, but keeping a copy of the employee notification letter is not required. And, if the employee has no hearing loss and no medical problems, then no notification letter is required.