U. S. Department of Labor
Occupational Safety and Health Administration
Directorate of Science, Technology & Medicine
Office of Science and Technology Assessment
Innovative Workplace Safety Accommodations
for Hearing-Impaired Workers
Safety and Health Information Bulletin
Introduction This Safety and Health Information Bulletin is not a
standard or regulation, and it creates no new legal
Approximately 28 million Americans have some obligations. The Bulletin is advisory in nature, infor-
degree of hearing loss [1,9]. Hearing loss can result mational in content, and is intended to assist employ-
from a variety of factors, including: heredity, disease, ers in providing a safe and healthful workplace.
physical trauma, and exposure to loud noises. The Pursuant to the Occupational Safety and Health
National Institute for Occupational Safety and Health Act, employers must comply with hazard-specific
(NIOSH) estimates that 10 million American workers safety and health standards promulgated by OSHA or
have permanent hearing loss resulting from exposure by a state with an OSHA-approved state plan. In
to excessive noise at work . The number of addition, pursuant to Section 5(a)(1), the General
American workers with hearing loss from all sources is Duty Clause of the Act, employers must provide their
expected to increase over time as the workforce ages. employees with a workplace free from recognized
hazards likely to cause death or serious physical harm.
Hearing-impaired workers face challenges responding Employers can be cited for violating the General Duty
to emergencies, working safely around machinery, Clause if there is a recognized hazard and they do not
communicating with coworkers, and receiving training. take reasonable steps to prevent or abate the hazard.
Accommodations necessary to address these However, failure to implement any recommendations
challenges may not be part of an employer’s current in this Safety and Health Information Bulletin is not, in
hearing conservation practice. This Safety and Health itself, a violation of the General Duty Clause. Cita-
Information Bulletin (SHIB) focuses on (1) tions can only be based on standards, regulations, and
Emergency/Evacuation Response Considerations the General Duty Clause.
for Hearing-Impaired Workers; and (2) Workplace
Safety and Health Considerations for Hearing-
Impaired Workers. 2. Informs employers of the wide range of
accommodations available for the hearing-impaired
Purpose worker and their application in the workplace as they
relate to emergency evacuation, training, responding to
The purpose of this SHIB is to provide employers, safety hazards and communication.
workers and professional organizations guidance on
accommodating the safety and health needs of 3. Encourages employers to develop and establish
hearing-impaired individuals in the workplace. procedures for hearing-impaired workers that further
Specifically, this SHIB: safety and health in their workplaces.
1. Raises awareness about the safety and health 4. Encourages worker participation in the
challenges faced by hearing-impaired workers. development, planning, and implementation of these
Background A. Emergency/Evacuation Response
Considerations for Hearing-Impaired Workers
The Occupational Safety and Health Administration’s
(OSHA) Occupational noise exposure standard Customizing Worksite Emergency Preparedness
includes requirements for a hearing conservation for Hearing-Impaired Workers
program (29 CFR 1910.95(c)). It covers employers
in general industry with employees exposed to noise at The OSHA Emergency action plans standard (29
85 decibels (dBA) or above measured as an 8-hour CFR 1910.38) requires an employer to develop a
time-weighted average sound level (TWA). It written emergency action plan when such a plan is
requires these employers to include their noise- required by a specific OSHA standard, such as 29
exposed employees in a hearing conservation program CFR 1910.120 hazardous waste operations and
that consists of noise exposure assessment, emergency response, and 29 CFR 1910.160 fire
audiometric testing, hearing protection and training.1 extinguishing systems. When the plan is required, it
The nature of the workplace has changed since the must describe the actions employees should take to
standard took effect; many workers in the United ensure their safety if a fire or other emergency situation
States are aging and have some degree of hearing occurs. At a minimum, the plan must include:
loss. There is also greater concern among workers emergency escape procedures; procedures for
about readiness to safely react to catastrophic events. employees who remain to operate critical plant
In addition to emergencies caused by natural operations before they evacuate; procedures to
disasters, and technological accidents; possibility of account for all employees after emergency evacuation;
acts of terrorism have become a concern. and procedures for reporting fires and other
Accommodations are available to enable hearing- emergencies. The plan must also include the types of
impaired workers to evacuate safely, and certain evacuation to be used in emergency circumstances.
accommodations may benefit workers with no hearing The employer must review the plan with each
loss, since some emergencies may adversely impact all employee covered by the plan when it is developed,
workers’ ability to hear or communicate. whenever the plan changes and upon an employee’s
Accommodation measures in the workplace are an initial assignment. Employers must consider
extension of good communication and safe practices employees with disabilities in the development of an
for all workers. emergency action plan when such a plan is required by
a specific OSHA standard.
Hearing-impaired workers also face routine
workplace safety and health challenges. In particular, The plan must be in writing, kept in the workplace,
hearing-impaired workers may have difficulty and available to employees for review. For employers
understanding audible warning signals and alarms with 10 or fewer employees, the plan may be
designed to indicate the approach of motorized communicated orally and the employer does not have
vehicles. For those with severe and profound hearing to maintain a written plan. The Appendix to 1910,
losses, a common safety concern is localization. For Subpart E, Exit Routes, Emergency Action Plans, and
example, “I know there are forklifts in the area but I Fire Prevention Plans is a nonmandatory guideline to
do not know where they are coming from.” Other assist employers in complying with the requirements of
concerns expressed by hearing-impaired workers the employee emergency plan .
include difficulty understanding conversation on the
telephone, at meetings and in training sessions . The Americans with Disabilities Act (ADA) does
Fortunately, accommodations and equipment not require employers to have an emergency
modifications are available to assist hearing-impaired evacuation plan, but if an employer decides to have
workers to perform their jobs safely [4,9]. such a plan, they are required to include people with
OSHA’s standard at 29 CFR 1926.52 addresses occupational noise exposure in the construction industry.
To help prepare workers for emergencies, the Office Alerting Device Options
of Disability Employment Policy (ODEP), at the U.S.
Department of Labor, provides recommendations on Traditionally, notification of an emergency has been
emergency preparedness for people with disabilities. done through the use of auditory devices which are
The ODEP report suggests three essential parts to an effective for most workers. OSHA’s Employee Alarm
emergency evacuation plan: plan development, plan Systems standard (29 CFR 1910.165), addresses all
implementation and plan maintenance . emergency alarms required to be installed by specific
OSHA standards. The standard indicates that an
Plan development includes identifying the potential alarm system must provide warning for necessary
hazards, the accommodation needs of persons with emergency actions and be capable of being perceived
disabilities, and key personnel who will be involved in above ambient noise by all employees. Since hearing-
an emergency. In developing a plan, employers impaired employees may not be able to hear auditory
should ask their employees for their input, and alarms, OSHA considers strobe lights or similar
workers with disabilities should take responsibility for lighting devices and tactile devices to meet the
their safety by offering their ideas and input. The plan requirement of the standard .
should address after-hours situations, and include a
method to identify visitors with special needs. The Hearing-impaired workers may also have difficulty
plan also should include details on how information understanding voice communication over the public
will be conveyed to hearing-impaired workers when address (PA) system. The alarm may interfere with or
they are away from their work areas. Finally, the plan drown out voice announcements, making the
should be easy to read and understandable. emergency voice communication system ineffective.
Alerting device accommodations are available to
Employers should consult with local fire, police and notify hearing-impaired workers of emergencies, and
emergency departments as well as community-based they cause minimal distraction to other workers.
organizations in developing the plan. While the plan Visual alarms equipped with flashing strobe lights or
should be in writing, it should be viewed as an ongoing vibrating alerting devices can be hard-wired into the
process, periodically revised and updated to reflect existing emergency notification system. The
changes in technology, personnel and procedures. Underwriters Laboratories Standard for Emergency
Signaling Devices for the Hearing-Impaired (UL
Plan implementation involves distribution of the plan 1971), establishes criteria for systems used for
in an accessible format to all employees and the emergency notification .
integration of the plan into the employer’s standard
operating procedures. Drills, both scheduled and Section 4.28 of the ADA Accessibility Guidelines
unscheduled, should be performed regularly. Such (ADAAG) 2 specifically addresses specialized alarms
practice drills should encompass the needs of all (www.access-board.gov/adaag/html/adaag/
individuals, including workers with disabilities, to htm#4.28). To be effective for notification, visual
ensure familiarity with the procedures and to alarms must be installed where hearing-impaired
determine where improvements are needed. persons can see them .
Plan Maintenance involves developing a system for Many alerting device options are available for use in
identifying new safety concerns and the needs of new the workplace, depending on the particular needs of
disabled employees, reviewing and modifying plans the hearing-impaired worker. However, not all of the
after practice drills, and ensuring that emergency devices listed below are appropriate for every
equipment is being properly maintained in good hearing-impaired worker. Some of the devices are
operating condition [4,5,9,10].
2 ADAAG contains scoping and technical requirements for accessibility to buildings and facilities by individuals with
disabilities under the ADA. These scoping and technical requirements are to be applied during the design, construction, and
alteration of buildings and facilities covered by Titles II and III of the ADA to the extent required by regulations issued by
Federal agencies, including the Department of Justice and the Department of Transportation, under the ADA.
more appropriate for individuals with a severe-to- • A modem that converts the personal computer
profound hearing loss, while others are appropriate for into a Telecommunications Device for the
workers with a mild hearing impairment. The Deaf (TDD).
employer should work together with hearing-impaired
employees, and perhaps with an occupational • Instant messaging or e-mail pop-up.
audiologist, in determining the device or combination
of devices that work best for their particular situation. • A flashlight provided to hearing-impaired
individuals for signaling their location in the
Some alerting device options include: event they are separated from the rescue team
• Exit signs set to flash when an emergency
alarm sounds. These signs are typically The Job Accommodation Network (JAN) website, a
connected to the emergency power system. service of the Office of Disability Employment Policy,
has a wealth of information on alerting devices at
• Strobe lights  or vibrating alarm signals www.jan.wvu.edu. JAN’s “Employers’ Guide to
placed in all areas occupied by hearing- Including Employees with Disabilities in Emergency
impaired workers. Evacuation Plans” covers requirements for including
people with disabilities, guidelines and accommodation
• Visual or vibrating alarm signals at the considerations. Toll-free (800) 526-7234 .
Other useful resources are DisabilityInfo,
• Vibrating pagers worn by hearing-impaired www.disabilityinfo.gov, and the Center for Disability
workers. Issues and Health Professionals, www.cdihp.org.
• Vibrating watches or other type of body alarm The United States Fire Administration publishes many
that is strapped on to the individual to alert a guides on the subject of disability and related
hearing-impaired worker. emergencies at www.usfa.fema.gov, toll-free (800)
• Two-way vibrating pagers that receive text
messages and have the ability to respond in Other Safety and Health Workplace
full length text. Accommodations
• “Hearing Dogs”- trained to alert the hearing- • TTY: A teletypewriter (TTY) is a telephone
impaired worker to a person entering the device that enables hearing-impaired
room, abnormal machinery sounds, individuals to make and receive telephone
malfunctioning equipment, the telephone calls. The device requires two TTY users to
ringing or other alerting needs. type messages back and forth to
communicate. When messages are typed on
• Buddy systems [5,7] where a coworker alerts the TTY keyboard, the information is
a hearing-impaired worker to an emergency displayed on the TTY display panel and
situation. This system should not be relied on transmitted through the phone line to a
as the sole means of alerting the hearing- receiving TTY.
impaired worker to an emergency situation • TRS: The Telecommunications Relay Service
because of the relatively low reliability of this (TRS) is a 24-hour, 7 day a week, free
approach. nationwide relay network service that handles
voice-to-TTY and TTY-to-voice calls. Using
• Amplified telephone ring signaler to alert the
worker to a phone ringing.
a TTY or other mechanism (Voice Carry Over • Use tape, paint or ropes to highlight paths of
phone, voice phone or videophone), an travel for forklifts, vehicles and heavy
individual dials the toll-free number to contact equipment.
the TRS system which will connect the caller • Designate separate doors for mechanized and
to a communications assistant (CA) who people traffic.
directs the call. When the recipient answers • Establish rules requiring that all forklifts and
the call, the CA explains his or her role in the vehicles must stop at all intersections.
call and will relay the communication between • Install sensor warning lights that blink as the
the two parties exactly as stated by both vehicle approaches. Directional warning lights
parties, either in text or voice. For more such as the left light signals traffic on the left,
information about Telecommunications Relay and the right light signals traffic on the right,
Services, link to: http://www.nidcd.nih.gov/ may be beneficial.
health/pubs_hb/telecomm.htm, and • Install flashing strobe lights on vehicles or
www.fcc.gov/cgb/dro forklifts to alert hearing-impaired workers to
• Cell phone with a portable TTY. It is • Install mirrors at all intersections within the
important to make sure that the cell phone is warehouse. Dome mirrors situated along
TTY compatible. aisleways may be beneficial.
• Wireless TTY. Provides instant TTY access • Use vibrating pagers - place a transmitter in
anywhere within a selected wireless data the moving equipment so that the driver can
network. Such TTYs have e-mail, fax, text- press a button that sends a signal to the
to-speech and speech-to-text message vibrating receiver worn by the hearing-
capabilities. impaired employee to alert the worker to the
The ADA Standards for Accessible Design, as well as • Position a rear vision camera so that a vehicle
other technical assistance materials, can be obtained operator will be able to see behind him/her.
from the U.S. Department of Justice ADA website at
www.ada.gov. The Department of Justice operates a Training Accommodations
toll-free ADA Information Line at (800) 514-0301
(voice), or TTY (800) 514-0383, which directs Training is an integral component of a safe workplace,
callers to an ADA specialist [5,6,10,12,14]. yet training may pose unique challenges for employers
who have workers with hearing impairments. Training
B. Workplace Safety and Health Considerations programs that ensure that procedures are understood
for Hearing-Impaired Workers and followed are paramount to creating a safe work
Responding to Vehicles in the Workplace
Hearing-impaired workers often need customized
Workers with hearing loss working around or training tools to ensure their safety. There are a
operating powered industrial trucks (e.g., forklifts) or variety of training mechanisms that can be tailored to
other heavy equipment may be concerned about their hearing-impaired individuals in the workplace. Again,
ability to detect dangerous situations. The employer the decision to use a particular training
should work together with hearing-impaired accommodation is one that should be made by the
employees in determining the accommodation or employer and employee after considering the needs of
combination of accommodations that work best for a specific situation.
their particular situation. The following are suggested
accommodations that can be made to minimize such • Assisted Listening Devices (ALDs). These
safety risks: devices amplify sound and transmit it to a
person’s hearing aid or to a receiver worn by possibly a PC projector. Typically, a typist
the individual. The speaker talks into a who participates in the group activity acts as a
microphone or transmitter and the listener notetaker while the hearing-impaired individual
either uses the telecoil (t-coil) on their own either watches the computer monitor or the
hearing aid or wears a receiver designed to text projected onto a wall or screen.
work with the specific ALD. • Web-based training. Use web-based meeting
• Captioned videotapes; open or closed. software or video conferencing.
Closed captioning requires the use of a • Tape recorded meetings. After the training
decoder to view the captions, while open session, the tape can be listened to separately
captioning displays the text automatically. in a controlled listening environment with the
These captions are identical to captions ability to rewind and playback as often as
displayed at the bottom of the screen in necessary. The tapes can also be transcribed.
foreign language films. No special equipment • TTY Videophone in a video conferencing
is required to view open captioning. format. This allows for full view of the group in
• Scripting. A script of the video might be addition to TTY communication directly on the
provided as a last resort if there is no TV monitor.
captioning, and if the visual content is not of • Communication Access Software. Currently,
great significance to the information provided there are innovative systems that provide
through the video. However, providing the multisensory, interactive communication by
script as a supplement to the captioned video converting speech to text, and to real-time on-
in advance of viewing the video gives the user screen sign language. More information about
additional preparation time to understand what these products is provided at
will be communicated. www.myicommunicator.com and
• Qualified sign language interpreter. For more www.signtelinc.com.
information, see the Equal Employment • Area and meeting room systems. Options
Opportunity Commission’s (EEOC) ADA may include: FM desktop systems: portable
Technical Assistance Manual for Title I, sound field-desktop or tote bag; FM System
Chapter III, 3.10.9 Providing Qualified with Speakers–Wireless; Conference
Interpreters at http://www.jan.wvu.edu/links/ Microphone; Ceiling Speakers.
• Communication Access Realtime Translation
(CART) Services. CART is a service in Tips for Assisting People with Hearing
which an operator types the spoken word into Impairments
a computer that instantly displays the typed
words in English on a monitor or other display. • Speak in a clear, normal tone; do not over-
This service is useful during small and large enunciate or exaggerate words.
group situations when verbatim conversation is • Speak directly to the individual, even if there is
essential to effective communication. CART a sign language interpreter present.
offers word-for-word translation. This service • Face into the light when speaking and do not
typically needs to be scheduled in advance of cover or turn your face away.
a meeting. • Flick the light on and off when entering a room
• Computer-Assisted Notetaking. This service to draw attention to your presence.
can be used to provide effective • Offer pencil and paper. While writing a
communication during group training sessions. message, do not talk; a hearing-impaired
It involves the use of a laptop or personal person cannot read a note and your lips at the
computer, word processing software, and same time.
7) USDA Employee Emergency Response
• In situations where lights may be inadequate, Guide. Emergency Evacuation Suggestions for
provide the individual with a flashlight to help Individuals with Disabilities, pp. 29-30.
the hearing-impaired person lip-read in the
dark. [5,8,13]. 8) U.S. Fire Administration. Orientation Manual
• Use a microphone when speaking to a group. for First Responders on the Evacuation of
• A presenter should repeat a question raised by People with Disabilities. Publication FA-235,
the audience into the microphone before August 2002.
answering the question. 9) National Organization on Disabilities.
Emergency Preparedness Initiative: Guide on
Conclusion the Special Needs of People with Disabilities
for Emergency Managers, Planners and
The risk of miscommunication, injury, and other Responders 2002. www.nod.org, (202) 293-
dangers presented to hearing-impaired workers in the 5960, TDD: (202) 293-5968.
workplace can be minimized through the
implementation of the practical steps described above. 10) U.S. Equal Opportunity Commission. U.S.
The best way to help hearing-impaired employees feel Department of Justice, Civil Rights Division.
prepared for a workplace emergency and be “Americans with Disabilities Act:
motivated to use safe work practices is to Questions and Answers.” August 23, 2002.
solicit their input and provide knowledge, information,
and accommodation choices. 11) U.S. Department of Justice, Civil Rights
Division, Disability Rights Section.
Enforcing the ADA: A Status Report
from the Department of Justice. Issue
1) Northern Virginia Resource Center for Deaf
and Hard of Hearing Persons. “Emergency
Preparedness and Emergency Communication
12) U.S. Department of Justice, Civil Rights
Access” December 2004.
Division, Disability Rights Section.
ADA Business Brief: Communicating
2) NIOSH, www.cdc.gov/niosh/topics/noise.
with People Who Are Deaf or Hard
of Hearing in Hospital Settings,
3) U.S. Department of Labor/OSHA.
13) NJ Arts Access Task Force. ADA Self-
4) U.S. Department of Labor, Office of Disability
Assessment Survey and Planning Tool.
Employment Policy. “Emergency
Preparedness for People with Disabilities,
Summary Report”. April 2004.
14) Job Accommodation Network. “Employers’
Guide to Including Employees with
5) Federal Emergency Management Agency,
Disabilities in Emergency Evacuation
U.S. Fire Administration. Emergency
Procedures for Employees with Disabilities in Plans”. Linda Batiste and Beth Loy.
15) Occupational Health and Safety. “Safety
First”. Jennifer Juergens, June 2004,
6) U.S. Fire Administration. Fire Risks for the
Vol. 73, No. 6, p. 94.
Deaf or Hard of Hearing. Publication FA-202,
16) ADA and Accommodation of the Hard of 5) The Better Hearing Institute,
Hearing. Presentation at the National http://www.betterhearing.org/
Hearing Conservation Association hearing_solutions/listeningDevices.cfm
Conference, February 2005. George
R. Cook, Au.D. CCC-A, 6) The Access Board, An independent federal
Occupational Audiologist. Workplace agency devoted to accessibility for people
Group (336) 931-0300. with disabilities. Provides technical assistance
www.workplacegroup.net. in ADA and ADAAG.
Other Useful Resources 7) U.S. Department of Transportation,
www.dot.gov, Federal Transit Administration,
1) U.S. Department of Justice, Civil Rights Easter Seals Project ACTION,
Division, Disability Rights Section. “ADA www.projectaction.org. ACTION is a
Information from the Department of Justice”. national technical assistance program to
The Department of Justice answers questions facilitate cooperation between the disability
about the ADA and provides free publications and transportation communities. It offers
by mail and fax. This 7-page document lists various resources, training and technical
pertinent ADA legal documents, general assistance to make the ADA work for every-
publications and guides, Technical Assistance one.
Publications for Businesses and Non-Profit
Service Agencies, and Technical Assistance
Publications for State and Local
2) The Office of Disability Employment Policy
Technical Assistance Programs: Training and
Technical Assistance to Providers (T-TAP) at
www.t-tap.org, The National Center on
Workforce and Disability for Adults (NCWD-
Adults) at www.onestops.info, National
Collaborative on Workforce and Disability for
Youth (NCWD/Youth) at www.ncwd-
youth.info, The Job Accommodation Network
(JAN) at www.jan.wvu.edu, and The
Employer Assistance Referral Network
(EARN) at www.earnworks.com.
3) Resources for Assisted Listening Devices.
Hearing Products Report
4) U.S. Department of Justice, Disability Rights
Section, ADA Information Services, Revised
Federal Agency Resources-Public Education
1) U.S. DOL www.dol.gov ODEP - Job
Accommodation Network (JAN)
2) U.S. Department of Justice www.justice.gov
ADA Information Services www.ada.gov
U.S. Department of
3) U.S. Fire Administration www.usfa.fema.gov
4) Federal Emergency Management Agency
5) ADA Information and
National Institute Occupational Safety
6) The Access Board www.access-board.gov
Independent Federal Agency
7) adahom1.htm www.doc.gov
U.S. Department of Commerce
National Oceanic and Atmospheric
8) U. Fire
U.S. S. Department of Transportation
Easter Seals Project Action
9) U. S. Department of Education www.ed.gov
National Institute on Disability and
Rehabilitation Research (NIDRR)
10) U.S. Federal Communications Commission
www.fcc.gov. For information
Telecommunication Relay Services