Leading the responsibility for safety for my company, I am in agreement that all feasible efforts should be taken to protect and enhance the well-being of all employees. The conditions under which citations can be issued under this interpretation is troublesome, however. If the current company hearing conservation program works, it will manifest itself in the results of the audiograms. If employees are not experiencing hearing loss as documented by these scientifically derived results, then the ability to cite must be tightly controlled or removed.
Comment from Huff, William; C.R. Hudgins Plating, Inc.
This is comment on Proposed Rule
Interpretation of Provisions for Feasible Administrative or Engineering Controls of Occupational Noise
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