The following is a reply to an existing client of Workplace INTEGRA, Inc by George Cook, Au.D. CCC-A on the topic of OSHA proposing a new interpretation of occupational noise exposure standards.

I wouldn’t want to minimize anything the Federal government and OSHA might do, but it doesn’t seem much more than what we had to deal with before 1983. At one time, NC OSHA issued a noise control citation to every company with noise requiring them to document a noise control compliance plan. Each plant would show evidence that they had investigated noise control on existing equipment. If the company could not engineer out the noise, some of the following was done.
1. Show evidence of investigations to apply practical noise control, as moving a trash hog out of the production area.
2. Contact industry associations to see what other’s have done with the equipment.
3. Write the manufacturer to see if anything was available and to what extent it would reduce employee exposure. 
4. Inform purchasing of the need to purchase the quietest equipment available and to place noise output specifications into the  purchase orders
5. Document any maintenance or engineering efforts that reduce noise exposure. This should be done even when the main purpose of the engineering or equipment removal or equipment relocation was not noise control.
6. Document the direct and indirect costs of all related efforts.
Each plant would have a Noise Control Compliance Plan documenting their efforts and costs, showing a good faith effort.

Please contact George Cook @ gcook@wpintegra.com with any questions or comments.