Comment from Walsh, Leonard; UTC

The determination of what is feasible in one or more person’s opinion is wide and often speculative. No doubt OSHA will be bombarded with vendors with all kinds with Band-Aid fixes, as well as no we can’t do that from industry and multiple people. As an engineer I find there is way too much what if and guessing and not enough real applications of science. Moreover, if you had to deal with noises and this was your son or daughter, parent or spouse what would you do for them? Fix it. Your not worried about how little or much or what scale or where the sensor was or is. You still want to fix it. Noise reduction is achievable to great extent with engineering controls and without excessive cost. Naysayers are not stupid, but ignorant of facts and unfortunately of methods. Source mitigation at the ears is not a solution; it is an ear plug. I applaud OSHA in bridging and soliciting comments on feasible. To its credit NIOSH instituted a proactive method of recognizing those companies who engage in noise reduction, with its “Safe in Sound awards.” Certainly those companies are not just doing it for a simple plaque. So there is a business case in reducing noise, rather than have personnel in a hearing conservation program and maintaining records forever. Ignoring the noise or waiting for a chance visit and citation is unethical. There are tools in virtually every manufacturing and construction sector with noise elimination features. Some people never look outside their own town or live in one time zone. And think that is all there is. And if a person would not mind the esthetics of some add on features; existing tools can be retrofitted as well. So new and glitzy is not always the solution. Big, noisy and ergonomically abhorrent does not make for a user friendly tool. My recommendation set up a NIOSH and industry end users committee to review best practices and provide a broad range of best practice items that industry and construction can review. Get inputs from ACGIH and IIE and cover all the engineering controls. As everyone knows one method does not cover all ranges and types of noise. Then you have feasibility. OEM tool suppliers then have an objective and no one is guessing what is feasible at that point in history. Len Walsh Engineering Fellow