I believe interpreting feasible as "Capable of being done" is a mistake. I understand that hearing loss due to "work" has been on the rise. However, I believe this could be contributed to several factors that have nothing to do with the working environment such as ear buds, surround sound, and increased output in car stereo's. The issue is that a physician cannot determine exactly what noise caused the hearing loss. Therefore, employers are having to accept hearing loss claims even though they probably did not cause it (We Train our employees, protect our employees using PPE, enforce the use of PPE, conduct noise studies to ensure we are not over exposing them, we test their hearing annually, etc...). What do they do to protect their hearing when they are not at work?
Finally, a lot is capable of being done but when you are referring to acoustical modifications you start to talk about significant amounts of money that could add undue burden to manufacturers especially in these difficult financial times.
If you want to do something with regards to preventing noise induced hearing loss (work related) find a way to adequately measure what a person is exposed to OUTSIDE of work and compare that to what they are exposed to at work - then make the decision as to if it is work related.
Comment from Thomas, ASP, James; Plastipak Packaging
This is comment on Proposed Rule
Provisions for Feasible Administrative or Engineering Controls of Occupational Noise
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