I have recently encountered an issue where I have an area that is required to wear hearing protection that is bordered on two sides where hearing protection is not required. I have asked that all employees that enter this area, even just to pass through, wear hearing protection. This is not a new area for the plant, but the stand of wearing hearing protection while passing through is. I am sure I have read somewhere in an interpretation of the standard that even passing through constitutes an exposure, therefore requiring everybody in the are to wear the prescribed PPE (Ear Plugs). Has any one else read this inerpretation or anything similar. Of course I have some plant personnel that disagree with this policy and fail to observe the new requirement.

What are the noise levels and how much time do they spend in the area?

Depending upon the employees' exposures (those that don't work in the noise area, but pass through), it is quite possible that they are not exposed to noise that exceeds the permissible exposure limit (expressed as an average decibel exposure on a time-weighted 8-hour basis).  That is to say, they may not need to wear hearing protection depending upon their exposure.

The hearing protection standard is a little different than most most occupational standards. Most standards give you a maximum of three limits to comply with (PEL 8 hours, STEL 15 minutes, Ceiling Instantaneous). The hearing protection standard gives you time weighted average based upon the noise levels. So you can be exposed to 90 dB for 8 hours, 95 db for 4 hours, 105 dB for 1 hour up to an absolute maximum of 140 dB and still be legal.

The easiest solution (engineering) would be to install acoustic curtains to create and aisleway where employees can walk without hearing protection. the curtains are particularly expensive but they are heavy. You'll need intermediate supports for anything longer than 10 feet.

The easiest administrative solution would be to determine the noise level along the pathway. Compare the result to table G-16A in 1910.95 and see if you can live with the exposure time. As always document everything. You may want purchase a sign that employees working in the area and personnel residing the area for more than X minutes must wear hearing protection.

MikeCJ

The other problem you may come across is how often do they "Just Pass Through?"  My suggestion is the posted " Noise Hazard-  Hearing Protection Required" outside the entry areas. And a box of Disposable Plugs next to the sign.

TheFIRM:

What are the noise levels and how much time do they spend in the area?

Depending upon the employees' exposures (those that don't work in the noise area, but pass through), it is quite possible that they are not exposed to noise that exceeds the permissible exposure limit (expressed as an average decibel exposure on a time-weighted 8-hour basis).  That is to say, they may not need to wear hearing protection depending upon their exposure.

 

I rule on the side of being cautious. Hearing loss or Db shifts count as recordable injuries if the shift is too great. Make the rule and make them wear their hearing protection. What's wrong with asking them to protect their own ears? We have adopted plenty of rules in our plant that are more stringent than CalOSHA. So whether or not OSHA requires it, think of ways to make everyone more safe in your own way.