Comment from Thomas, ASP, James; Plastipak Packaging

Document ID: OSHA-2010-0032-0074
Document Type: Public Submission
Agency: Occupational Safety And Health Administration
Received Date: December 27 2010, at 12:00 AM Eastern Standard Time
Date Posted: December 28 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: December 21 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: March 21 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80bbfb9b
View Document:  View as format xml

View Comment

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.

Related Comments

    View All
Total: 31
Comment from Thomas, ASP, James; Plastipak Packaging
Public Submission    Posted: 12/28/2010     ID: OSHA-2010-0032-0074

Mar 21,2011 11:59 PM ET
Comment from Benjamin, Maynard H., President & CEO; Envelope Manufacturers Association (EMA)
Public Submission    Posted: 12/28/2010     ID: OSHA-2010-0032-0075

Mar 21,2011 11:59 PM ET
Comment from Frakes Jr., Hoy E., President; Metallurg Vanadium
Public Submission    Posted: 12/28/2010     ID: OSHA-2010-0032-0076

Mar 21,2011 11:59 PM ET
Comment from Courtney, Ann; Graham Packaging Company
Public Submission    Posted: 12/29/2010     ID: OSHA-2010-0032-0077

Mar 21,2011 11:59 PM ET
Comment from Tiller, Michael ; Compressed Gas Association
Public Submission    Posted: 01/14/2011     ID: OSHA-2010-0032-0078

Mar 21,2011 11:59 PM ET