Hearing Protection Requirements for Food Manufacturing

The issue of hearing protection in the food processing industry — and in process industries in general — is somewhat more complex than it is in other industries in that employers must protect workers' hearing as well as protecting the purity of the product.

Product Purity Requirements

OSHA regulations governing hearing conservation in the workplace (29 CFR 1910.95) have been in effect for over twenty years. But for food processors, a large body of additional Federal Codes, Regulations, and Compliance Policy Guides lie in wait for the manufacturer who does not pay heed to Good Manufacturing Practices. Here's a brief sample:

• Title 21, Chapter 9, Subchapter IV, Section 342(a)(1) of the U.S. Code states, "A food shall be deemed to be adulterated if it bears or contains any poisonous or deleterious substance which may render it injurious to health."
  
  
• Section 402(a)4 of the Federal Food, Drug, and Cosmetic Act (FD&C Act) further deems food to be adulterated, "if it has been prepared, or packed or held under unsanitary conditions whereby it may have become contaminated with filth, or whereby it may have been rendered injurious to health."
  
  
• The FDA lists "Defect Action Levels" which define the extent of contamination acceptable in food.
  
  
• However, 21 CFR 110.110 also clearly states that even in cases where contamination does not exceed the Defect Action Level, food manufacturers are still required to observe current good manufacturing practices (FD&C Section 402(a)4): "The manufacturer of food must at all times utilize quality control procedures which will reduce natural or unavoidable defects to the lowest level currently feasible."
  
  
• Title 21 of the Code of Federal Regulations, Section 110.80, regarding Good Manufacturing Practice in Manufacturing, Packing or Holding Human Food, stipulates that, "All reasonable precautions shall be taken to ensure that production procedures do not contribute contamination from any source. Chemical, microbial, or extraneous-material testing procedures shall be used where necessary to identify sanitation failures or possible food contamination. All food that has become contaminated to the extent that it is adulterated within the meaning of the act shall be rejected, or if permissible, treated or processed to eliminate the contamination."
  
  
• According to Chapter-5, Sub Chapter-555, Section 555.425 of the FDA/ORA Compliance Policy Guide, a food product that contains a hard or sharp foreign object between 7 mm and 25 mm or over 25 mm in length, "should be considered adulterated within the meaning of 21 U.S.C. 342(a)(1) if a health hazard is established by CFSAN review."
  
  
• Any food products considered adulterated are subject to seizure by the FDA's Division of Compliance Management and Operations (HFC-210).

Running afoul of federal regulation — as serious as that can be — may not even be the worst part. An item like a stray earplug turning up in someone's marmalade may not constitute a serious health risk, but in a litigious society like ours, the possibility of hefty lawsuits is very real. Even worse, in these days of media frenzy, the biggest potential danger to a company is public reaction, should such a story catch the eye of the press. Beyond fines and settlement costs, this kind of crisis can kill both a brand and a company.

Detectable Hearing Protectors

If you are the safety officer at a food process company, the issue of providing hearing protection that is safe for people and process is not one to be taken lightly. There are two basic approaches to protect product from stray hearing protectors: the first is to keep the hearing protector from falling into the product in the first place; and the second is to make it easily detectable if it does.

Manufacturers of hearing protection devices, such as Howard Leight, offer a wide selection of products that meet these objectives. Both single- and multiple-use earplugs are available with integral cords that can be hung about the neck. Should an earplug fall out during use, it remains attached to its mate. And should a set inadvertently fall into a vat, only one item needs to be retrieved instead of two, and they can be retrieved easily because of the cord. Cords also offer the convenience of allowing workers to remove earplugs when not needed and leave them hanging around their necks.

Similar in concept, banded earplugs mount the earplug onto a molded plastic band which is also worn about the neck. In addition to attaching the protector to the person, the band also applies slight pressure on the earplugs to keep them well seated in the ear. Another product, the Howard Leight Quiet Band series, incorporates a patented design that prevents the ear pods from touching dirty or contaminated surfaces when they are set down.

A number of detection schemes are also available to help retrieve earplugs from process batches. One approach is to make both earplugs and attached cords highly visible by using multiple, flashy—even stylish—colors. Another is to make the earplugs and often the cords, as well, metal detectable. This way, even if the cords are torn loose by a mixer or grinder or are cut into pieces, all components are readily detectable with X-ray scans. v For industries like pulp and paper where plastic is not allowed, attached cotton fiber cords are available which will not harm process or product. These products are also packaged in paper to further minimize the risk of plastic contamination.

Hearing Loss a Growing Problem

The bottom line in all this, however, remains the need to protect workers' hearing. In spite of growing awareness of hearing loss and increased efforts to combat it, the incidence of noise induced hearing loss among industrial workers — food process and otherwise — continues to rise. A recent National Health Interview Survey showed that hearing problems among individuals aged 45-64 have risen 26% over the past 30 years. This means safety professionals need to look beyond traditional Noise Reduction Ratings (NRR) in protective equipment and consider the human factors which undermine hearing conservation efforts.

This, combined with some new technologies in hearing protective devices which are just now becoming available, can help safety professionals make better purchasing choices and help reduce the likelihood of continued noise-induced hearing loss incidence. We call this approach the "four C's" of hearing protection: Caring, Comfort, Convenience and Communication.

The first step is to help workers understand and CARE about hearing protection. For many workers, hearing loss is a remote threat at best, and many don't realize that the impact of hazardous noise is cumulative, and even brief periods without protection can generate real, lasting hearing loss. This requires an educational effort.

Wearable Hearing Protectors

Safety officers must also make sure hearing protection devices are COMFORTABLE, CONVENIENT to use, and fitted correctly. The best hearing protection is that which is worn, and research clearly indicates that comfort is the prime driver of how diligently people will wear hearing protection.

But the biggest need is the fourth "C", the need to enhance workers' ability to COMMUNICATE while wearing hearing protection on the job. It's ironic that in order to protect workers from permanent hearing loss, we subject them to temporary hearing loss, and there is a growing body of research that suggests links between the inability to hear while wearing hearing protection and industrial accidents. In addition, workers who cannot communicate easily feel more isolated on the job and are less likely to be contented and productive.

A number of new products are available to facilitate protected communication. The unique design of some earplugs generates a uniform attenuation profile which helps block harmful noise while allowing voice and alarm frequencies to be heard more naturally. It is also important to guard against the dangers of overprotection by providing hearing protection devices in a variety of noise reduction ratings. These allow users to target the level of attenuation to the needs of their work environment, enhancing both their ability to communicate on the job and their psychological well-being, as well as saving resources.

Ultimately, hearing protection involves human beings. If we are to reverse the growing incidence of noise induced hearing loss — and protect the purity of valuable products in the process — we need to consider the human elements of the equation, and choose products and tactics that will allow us to address these elements successfully.