HPD Labeling:EPA Rulemaking and an Updated ANSI S12.42

NHCA Conference, Orlando, 2/27/10

Elliott H. Berger, Senior Scientist

U.S. HPD-Related Regulation and Standards

EPA Hearing protector labeling regulation

40 CFR Part 211

ANSI S3.19-1974 – REAT with optimum experimenter fit

ANSI S12.6-2008 – REAT with two methods: A and B

ANSI S12.68-2007 – Number ratings: NRSA, NRSG, OB

ANSI S12.42-2010 – MIRE and ATF methods, includes

procedures for impulse noise testing

EPA Labeling:Background

Why does not OSHA, MSHA, NIOSH, FDA, or CPSC regulate HPD labeling?

Noise Control Act of 1972 authorized noise labeling

Original EPA labeling rule promulgated in 1979

Work began on revisions in 2003 and heated up in 2009

Proposed rule issued August 5, 2009 with close of comments on November 4, 2009

Informal invitation-only meeting on January 13, 2010

Key IssuesIdentified by EPA

Applicability to a broader range of devices including electronic and level-dependent devices

Development of a more useful NRR that does not need derating

Update the test methodology to replace S3.19-1974 with reference to ANSI S12.6-2008

Require larger subject populations for earplug testing

Require periodic retesting

Principal Proposed Changes Multiple labels for different types of products such as

HPDs that are electronic and/or level-dependent Rating will still be NRR, but computed like NRSA from

ANSI S12.68-2007 (two-number rating) Intention was to provide realistic data, but … Will replace ANSI S3.19 with ANSI S12.6-2008 (Method A) Will incorporate ANSI S12.42-2010 Rating will be usable with dBA Effective date is not yet determined Periodic retesting will be required (5 yrs. proposed)

One Label Becomes Three

One Label Becomes Three Five (?)

New Materialsin ANSI S12.42

Still specifies MIRE and ATF procedures but …

New standard is more comprehensive and includes

Detailed description of MIRE and enhanced ATF

Method applicable to active sound cancellation devices (combination of MIRE and REAT)

Description of specific test noises, including generation of impulse test noises

How to Position MIRE Microphones

Acoustical Test Fixtures (ATFs) in Current Use

Institut de St. Louis (ISL) - Impulse Test Set-up

Range in SPLs110 – 195 dBP

National Institute for Occupation Safety and Health – Shock Tube

Range in SPLs130 – 164 dBP

Next Steps

EPA considering input from public hearings, docket submissions, and the informal labeling-discussion meeting

A draft final rule will be prepared this year, then circulated for internal agency approval and external OMB review

Final rule to appear sometime after August 2010? New labeling will begin about 12 months after promulgation,

and will be complete ~ 30 months or more thereafter ANSI S12/WG11 developing a standard for FAMS (S12.71),

with a target publication date of late 2011

BasicAcoustical Test Fixture

(ATF)ANSI S12.42-1995 (R2004)

Suitable only for earmuffs

Lacks refinements called for in the

new S12.42

ANSI S12.6-2008

Corresponds to prior ANSI standards

2008 version more explicit in fitting instructions

Will likely be required in updated EPA rules

Method A – Trained-Subject Fit

Method B – Inexperienced-Subject FitApproximates upper limits of attenuation for groups of workers – best real-world estimate2008 version has only minor updatesMay not provide sufficient reproducibility

0

5

10

15

20

Gai

n a

t E

ard

rum

(d

B)

Frequency (Hz)125 250 500 1k 2k 4k 8k 16k

TFOE = A - B

Transfer Function of the Open Ear

Hazard measured here

Earphones measured here