Hearing Conservation Recordkeeping

1
Hearing Conservation Recordkeeping
2
Medical / Legal

• Most HCP forms are considered medical-legal
  documents.
• All must be filled out completely accurately.
• Invalid data entry or misinformation may result
  in the unjust awarding of compensation claims.

3
Noise Survey Data (DD Form 2214)

• Noise exposure measurements must be entered on DD
  2214 (Noise Survey Data) and a copy placed in the
  employees medical record. In most cases,
  measurements are made by an IH or IH technician.
• Noise survey data are retained locally for 5
  years.
• Each service must keep survey records for the
  duration of an individuals employment, plus 30
  yrs.
• Other service-specific requirements may
• vary.

4
Biological Calibration Check (DD Form
2217)

• Must be performed each test day and documented on
  a DD Form 2217 and printed out monthly.
• An individual DD Form 2217 must be established
  for each designated listener, whether human or
  artificial ear.
• A new DD Form 2217 baseline test
  must be established for each listener
  every time the audiometer is electro-
  acoustically calibrated (annually).
• Biological calibration records must
  be kept locally for 5 years.

5
DD Form 2215 Reference Audiogram
A baseline test For all military
personnel and noise-exposed civilian employees

• Requirements for taking test
• At least 14 noise-free hours (NFH)
• No ear, nose or throat problems

6
The DD 2215 is used for the following test
purposes

• Reference established prior to noise exposure
  
• (purpose 1)
• Reference established following exposure in
• noise duties (purpose 2)
• Reference re-established after follow-up
  testing
• (purpose 3)

7
DD 2215 Referral Criteria
High Frequency Hearing Loss 55 dB HL or more at
3000, 4000 or 6000 Hz (either ear) Low Frequency
Hearing Loss Greater than 25 dB average at
500,1000 and 2000 Hz (either ear)
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DD 2215 Referral Criteria (cont.)
When Masking Is Required 40 dB or difference
between ears at the same frequency Asymmetric
Hearing Loss 25 dB HL or more between ears at
any two consecutive frequencies
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DD Form 2216 Hearing Conservation Data
Completed annually/periodically A valid DD 2215
must be in the employees health
record Completed as a comparison to the
reference (baseline) hearing test
10
The DD 2216 is used for the following test
purposes

• 90-day (purpose 1)
• Annual (purpose 2)
• Follow-up 1 (purpose 5)
• Follow-up 2 (purpose 6)
• Termination (purpose 3)
• Other (purpose 4)

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DD 2216 Referral Criteria
When Masking Is Required 40 dB or
difference between ears at the same
frequency Asymmetric Hearing Loss 25 dB
HL or more between ears at any two consecutive
frequencies Significant Threshold Shift
(STS)
12
Definition of STS

• Positive STS
• 10 dB average at 2000, 3000 and 4000 Hz
• or
• 15 dB at 1000, 2000, 3000 or 4000 Hz
• Negative STS
• - 10 dB average at 2000, 3000 and 4000 Hz
• or
• - 15 dB at 1000, 2000, 3000 or 4000 Hz
• Employees supervisor (civilian)/unit commander
  (military) must be notified promptly

13
DD Form 2216 Follow-up Procedures
Negative STS

• Counsel patient signs form to document
• the need for a follow-up test.
• Complete Follow-up 1 the same day
• (patient must be noise free for 14 hours ).
• If STS, re-establish DD2215 audiogram.
• Follow-up 1 must be completed within
• 30 days of the annual test.

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DD Form 2216 Follow-up Procedures
Positive STS

• Follow-up 1
• Complete Follow-up 1 (14 hours noise free)
• Counsel patient signs DD 2216 (an OSHA
• notification requirement)
• If STS resolved, no further testing required
• Follow-up 2
• Complete FU 2 (can be same day as F/u 1)
• When STS noted, counsel patient signs form
• If STS resolved, no further testing required
• Follow-ups 1 and 2 must be completed
• within 30 days of annual test

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DD 2216 Follow-up Procedures (Cont.)
Positive STS

• Audiological Referral
• When STS is confirmed after Follow-up 2
• Refer for complete audiological evaluation
• Re-establish the DD 2215, Reference Audiogram

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STS

• "Red Flags" when STS confirmed
• Notify employee and their supervisor/commander
• within 21 days of F/u 2.
• Re-fit employee with hearing protection.
• Identify any new noise hazards in workplace.
• Enforce the use of hearing protection and
  increase
• supervision.
• Provide additional health education.

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OSHA REPORTABLE HEARING LOSS (ORHL)

• OSHA Reportable Hearing Loss
• - Occurs when a 25 dB or greater average
  change occurs
• at 2K, 3K, AND 4K Hz, in either ear,
  when compared to the
• original baseline (reference or
  re-established reference).
• - Only reported the first time per ear and again
  when an additional 25 dB or greater average
  decrease in hearing thresholds occurs in either
  or both ears.
• - DOEHRS-HC automatically identifies individuals
  with an OSHA RHL and prints an OSHA RHL log. A
  list of all individuals with OSHA Reportable
  Hearing Loss can be obtained from DOEHRS-HC
  Reports.

OLD CRITERIA
18
New Record Keeping Rule for Hearing Loss

• Title 29 CFR Part 1904.10
• If an employees hearing test (audiogram)
  reveals. . . a work-related Standard Threshold
  Shift (STS) in one or both ears, and the
  employees. . .average hearing level is 25
  decibels (dB) or more above audiometric zero
  (the average at 2000, 3000, and 4000 Hz) in the
  same ear(s) as the STS, you must record the case
  on the OSHA 300 Log.

19
New Record Keeping Rule for Hearing Loss

• Hearing loss is reportable when
• A STS occurs (an average 10 dB or greater change
  for thresholds averaged at 2,3, and 4 k Hz in
  either ear from the current baseline audiogram)
  and. . .
• Hearing thresholds for the current audiogram show
  an average of 25 dB or greater at 2, 3, and 4 k
  Hz from audiometric zero for the shifted ear

20
Department of Defense Policy (future changes)

• The 15 dB shift at 1, 2, 3 or 4 k Hz will be
  dropped from the DOD STS definition, but will be
  retained as an early warning flag. No follow-up
  will be required when a 15dB shift occurs

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Management of OSHA Reportable Hearing Loss

• Keep a copy for your records
• Use the OSHA RHL log to notify Safety and/or
  Occupational Health that an OSHA Reportable
  Hearing Loss has occurred
• Must notify the supervisor/unit commander in
  writing within 21 days.

• Supervisor/unit commander must complete the
  appropriate form (CA-1, CA-2), within 7 calendar
  days (DA 285) within 6 days and submit to the
  Safety and/or Occupational Health Office
• The CA-1, CA2, and DA Form 285 will be used to
  complete the OSHA 300 Log
• Only done once and each time another OSHA
  Reportable Hearing Loss occurs

22
New Record Keeping Rule for Hearing Loss (Forms)

• Three recordkeeping forms
• OSHA Form 300 Log of Work-Related Injuries and
  Illnesses
• OSHA Form 300A Summary of Work-Related Injuries
  and Illnesses (required annually.)
• OSHA Form 301 Injury and Illness Incident
  Report (individual report)
• Tutorial
• OSHA Forms for Recording Work-Related Injuries
  http//www.osha.gov/recordkeeping/OSHArecordkeepin
  gforms.pdf

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New Record Keeping Rulefor Hearing Loss

• The ruling is not retroactive and only applies to
  periodic (DD2216) audiograms performed after
  December 31, 2002.
• Authority to implement the new reporting rule has
  not yet been finalized by DOD.

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DD 2215 and DD 2216 Audiograms
Records Maintenance

• Copy for individuals medical record
• Other copies may be required by service
• regulation or local policy
• Audiologist or physician reviews audiograms
  with
• high reference thresholds and STS (must be
• confirmed and determined to be noise-induced)
• HC technician reviews all other audiograms

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Record Maintenance (cont.)

• Maintain audiometric and noise exposure data for
  duration of individuals enlistment or
  employment, plus 30 years.
• Provide copies of an employees audiometric test
  and noise exposure data to the employee, former
  employee, or people designated in writing by the
  employee to receive the records.
• Forward data from all DD 2215s 2216s to the
  DOEHRS Data Repository monthly.
• Maintain annual electro-acoustic calibration
  records for 5 years.

26
Hearing Test Booth Certification

• Must be certified annually (by audiologist or
  industrial hygiene).
• Post in plain view on
  booth.
• Retain these certification
  data locally for 5 years.

27
Rosters of Noise-exposed Personnel

• Personnel enrolled in a HCP must be identified by
  name and IDN/SSN.
• Rosters will be maintained by the medical
  surveillance personnel and updated at least
  semi-annually.
• Records of health education training for
  noise-exposed personnel should be kept for a
  minimum of 5 years.

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DoD Guidelines vs. OSHA Guidelines

• TWA (varies by service/organization)
• OSHA 85 dBA and 5 dB exchange
  rate
• Army/Air Force 85 dBA and 3 dB exchange rate
• Navy 85 dBA and 4 dB
  exchange rate
• STS Criteria
• All permanent STS after F/u 2 must be
  reported to
• Occupational Health Safety Offices.
• STS that meets OSHA Reportable Hearing
  Loss
• (RHL) must be submitted in writing (added to
  the Log
• of Federal Occupational Injuries and Illness).
• Civilians (CA-1 or CA-2 Form submitted)
• Military (DA Form 285 Accident Report)

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Audiology Workload Reporting

• Requirements for reporting workload may vary
  between commands.
• Utilize the Composite Health Care System (CHCS)
  and the Ambulatory Data System (ADS) for
  capturing workload information.
• Utilize the MEPRS code (FBN_) to capture
  hearing conservation program workload accurately.
• Add any alpha or numeric character to
  distinguish the type of provider (audiologist/
  technician) or level of service offered.

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Recordkeeping
I. The objective of this lesson is to learn
about the record-keeping requirements of a
Hearing Conservation Program by identifying the
forms and how they are used and by understanding
and implementing the guidelines for STS follow-up
procedures. II. REFERENCES Workbook
31
The DD Form 2217

• 1a-d Audiometer Information
• 2a-c Listener Information
• 3. Dates and Data Review - Dates of calibration
  and the examiner. Indication of daily
  calibration pass or failure.
• Threshold Levels - Daily calibrations must be
  within /-5dB of the baseline test for all
  frequencies except at 6000Hz (a /- 10 dB
  difference is allowed).
• Remarks - When calibration fails, the form should
  be printed and an explanation given for the
  failure and corrective action taken.

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The DD Form 2215
Patient Demographic Information

• Must be Installations Zip Code
• DoD Component
• Service Component
• SSN
• Name
• Date of Birth (YYYY/MM/DD)
• Sex
• Pay Grade Uniformed
• Pay Grade Civilian

• 10. Service Duty Occupation Code
• 11. Mailing address of assignment (the UIC
  information appears in this block)
• 12. Location Place of Work
• 13. Major Command
• 14. Duty Phone

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(No Transcript)
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The DD 2215 (cont.)

• Audiometer Information
• 23a. Microprocessor
• 23b. CCA-200
• 23c. Benson Medical
• 23d. Serial Number
• 23e. Test must be performed within 12 months of
  the last acoustic calibration date
• Personal Hearing Protection
• 24a. Indicates type of hearing protection
• 24b. Individuals can have different sizes for
  each ear
• 24c. Indicates whether double protection is used
• 24d. Glasses Worn (refers to eye glasses)
• 24e. Frequency of glasses used
• 25. Remarks (remarks cannot be entered at the
  time of testing, but can be through the audiogram
  edit process)

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The DD Form 2216

• Information in fields 1-14 are the same as those
  in the DD 2215
• Audiometry
• 15a. Most 2216s will be purpose 2 (annual).
  Upon leaving government employment, all civilians
  and military personnel should receive a
  termination audiogram (3).
• 15b. Current audiogram date the current
  audiogram is compared to the reference audiogram
  (15c) to determine whether a significant
  threshold shift has occurred. A positive shift
  indicates worse hearing thresholds and a negative
  shift indicates improved hearing thresholds (/-
  10 dB average shift at the frequencies of 2000,
  3000 or 4000 Hz or /- 15 dB shift at any one
  frequency between 1000-4000 Hz).

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The DD 2216 (cont.)

• 15d. Indicates whether a shift has occurred.
  Persons who have
• an STS must return for follow-up
  testing.
• 15e. Positive and negative shifts require
  follow-up within 30 days
• negative shifts may be performed on the same
  day as the test
• identifying the negative STS however,
  positive STS must be
• retested after 14 noise-free hours
• 15f. The individual must sign the 2216
  acknowledging that the
• STS has occurred and the need for a
  follow-up test.
• 15g. Hearing protection information
• 15h. Examiner name
• 15i. Examiner certification number (see DD 2215
  22b for further
• explanation)
• 15j. Examiners job title code (MOS - Army,
  AFSC - Air Force and
• NEC/NOBC - Navy)
• 15k. Examiners office symbol

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The DD 2216 (cont.)
The same audiometric data is required for both
the DD 2215 and the DD 2216

• Follow-up 1 - Individuals who show an STS on
  their annual test must return for a Follow-up 1.
  
• (a) The Follow-up 1 for a negative STS
  may be conducted on the same day as the annual,
  if performed after 14 noise-free hours.
• (b) When STS on Follow-up 1 is negative,
  the patients reference thresholds must be
  re-established to reflect the improved results.
• (c) If the STS on Follow-up 1 is
  positive, the patient must complete a Follow-up
  2 within 30 days.

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The DD 2216 (Cont.)
A positive STS on a Follow-up 2 requires medical
review for proper patient disposition. The
reference audiogram is re-established after
proper medical review to determine the cause of
the hearing loss. The patient is counseled and
fitted with new hearing protection. The medical
review may require referral to an audiologist or
a physician.