Comment from Kearney, Tim, CSP; Enviroair Consultants

I am greatly encouraged to see OSHA recognize that it can no longer rest on its laurels regarding encouraging employers to make the beter decisions regarding how their work processes are designed and maintained. I honestly feel that requiring engineering controls be THE primary means of protection for employees exposed to excessive noise levels will bear fruit in other areas of the business operation often reducing cost and increasing efficiency as it forces a more thorough evaluation of the technologies in use or available to use to better control the work environment. I have felt for a long time that we in the US have fallen from the leadership role in improving technologies that could be implemented for noise control because everyone know the OSHA won't cite for Engineering Controls since the citations would be vacated were they to be tested in court.