A lot of workplaces have the “checkbox” version of hearing conservation: there is a policy, there are earplugs at the door, there is annual training, there are audiograms on file, and everyone can point to a binder if an auditor shows up. Then the audiometric results keep drifting, the same crews keep getting flagged, and the slow, permanent hearing loss continues anyway, which tells you something uncomfortable: compliance is not the same as control.
Most noise rules and guidance point you to a threshold where you must act, but the real goal is not to “meet the rule,” it is to reduce the actual dose workers receive across real shifts, real tasks, real overtime, and real equipment that wears out. NIOSH’s recommended exposure limit is 85 dBA as an 8-hour time-weighted average, and they frame it plainly: if you keep exposing workers at or above that level, you should expect risk over a working lifetime, which means you need a hearing loss prevention program that actually changes exposure, not just paperwork. (cdc.gov)
A big reason “compliant” programs still fail is that they lean too hard on hearing protection as the primary control, even though hearing protection is supposed to be the last line in the hierarchy, and it is also the easiest control to get wrong quietly. If you treat earplugs as the solution, you can look compliant while the dose stays high, because small fit problems, inconsistent use, bad selection, and communication needs can erase the protection you thought you had.
Noise monitoring that is too generic will mislead you, because it averages away the ugly parts of the job, and those ugly parts are often the exact moments that drive dose and damage. If your sampling is old, your crews have changed, your equipment has aged, your processes have drifted, or overtime is common, then your “compliance” numbers may not represent current reality, which means you are managing a problem you are not actually measuring.
Here are common ways exposure assessments go sideways in practice:
The easiest “tell” that your monitoring is insufficient is when audiograms show hearing shifts, but your noise surveys say everything is fine. When those two datasets disagree, the audiograms are usually telling you that your sampling plan missed the real exposures, or your controls are not working the way your paperwork claims they are.
If you want hearing conservation strategies that actually work, you have to chase noise at the source and along the path, because that is the only way to reduce dose for everyone, including visitors, contractors, and workers who “forget” hearing protection for short tasks. Good engineering controls do not have to be fancy, but they do have to be maintained, because worn bearings, loose guards, poor lubrication, misalignment, and failed dampening routinely turn “acceptable” equipment into a noise generator.
Practical engineering moves that often pay off faster than people expect include enclosure and isolation (partial or full), vibration dampening, upgraded mufflers and silencers, acoustic curtains for fixed stations, and preventive maintenance that targets noise as a performance metric rather than a nuisance complaint.
In Alberta, the OHS Code explicitly pushes the idea that noise should be designed and constructed to not exceed 85 dBA or be as low as reasonably practicable when you introduce new areas, processes, or significant equipment, which is basically a procurement and change-management rule hiding in plain sight. (search-ohs-laws.alberta.ca)
Administrative controls can help, but only if they are real controls and not wishful scheduling.
Rotation only reduces exposure if you track who actually rotated, how long they were exposed, and whether the “quiet task” stayed quiet in practice, because otherwise you just move the noise problem around while telling yourself it is managed.
If hearing protection is your primary control, you are betting workers’ hearing on a fragile system that depends on fit, consistency, and comfort, which is why technically compliant programs still produce hearing loss.
The fix is not to yell “wear your plugs,” the fix is to treat hearing protection like any other critical PPE: selection based on hazard, fit verification, training that includes hands-on practice, and supervision that checks quality, not just presence.
The rating on the box is not the protection workers actually get, because real-world fit and insertion depth matter.
Some workers need different styles because ear canals differ, and one-size-fits-all usually means “fits poorly for many.”
Double hearing protection is sometimes necessary, but if you do not plan for communication needs, workers will compromise by loosening or removing protection at the worst moments.
If you are not doing fit checking or fit testing, your program may be compliant on paper while still failing at the point of use. The goal is simple: make the correct protection the easiest choice, and make correct use the default habit, because the alternative is an endless cycle of retraining with the same audiogram trend lines.
Audiometric testing is not just a regulatory checkbox, it is a performance indicator for your noise controls and your PPE system. If you do audiograms and do nothing with the results, you are collecting evidence that your controls are failing and then ignoring it.
A strong program treats audiometric results like safety data: you trend them by department, task group, and location, and you investigate clusters the same way you would investigate repeated near misses. When you see threshold shifts, the right question is not “who messed up,” it is “where is exposure higher than expected and why,” because noise-induced hearing loss is usually the result of repeated, predictable exposure, not a single dramatic event.
This is also where “technically compliant” programs often fall apart: they do not connect audiogram findings back to hazard assessment, control selection, maintenance, and supervision. If you close that loop, your program becomes a living system that improves; if you do not, it becomes a yearly ritual that slowly documents preventable harm.
Most hearing conservation training is too generic, too classroom, and too disconnected from the job, which means it lands as background noise and then disappears. Good training is short, practical, and repeated in the field, and it answers the questions workers actually care about: when do I really need protection, what type works for my tasks, how do I know it is fitted right, and how do I communicate without pulling it out.
You also need to train supervisors differently than workers, because supervisors are the ones who set the local standard through what they notice, what they correct, and what they tolerate. If the supervisor only checks “earplugs present,” then the workgroup learns that appearance is the goal; if the supervisor checks fit and challenges unnecessary exposure, then the workgroup learns that protection and control are the goal.
Noise rarely feels like an “incident,” but it still creates high-potential situations, especially when impulse noise, tool misuse, missing guards, or uncontrolled releases create short bursts that can be damaging. If you want a program that works, treat uncontrolled noise exposures like other hazards: report, investigate, fix the control weakness, and verify the fix, because that is how you prevent repeat exposure in the same way you prevent repeat injuries.
If your program is compliant but hearing loss is still happening, start with a reset that prioritizes the biggest dose drivers and the weakest links in your control chain:
Canadian requirements vary by jurisdiction, which means the “right” program is the one aligned with the rules that apply to your workforce and the actual exposures they face. CCOHS outlines core elements of a hearing conservation program and points to CSA Z1007 as a program management benchmark, which is useful if you want structure and consistency across sites. (ccohs.ca) Ontario, for example, frames an 85 dBA Lex,8 exposure limit concept in its guidance, which is another reminder that you should check the local standard and then build your monitoring and controls to match it. (ontario.ca)
If you are seeing hearing loss trends in a “compliant” program, you do not need more posters, you need a sharper diagnosis and a tighter control loop, and that is exactly where Calgary Safety Consultants can step in. We can help you build or rebuild the parts that usually fail quietly: a practical noise monitoring plan that matches real work, a hearing conservation program aligned to your jurisdiction and expectations, and a control strategy that prioritizes engineering and maintenance over endless reliance on PPE. We also support field-ready training that focuses on correct fit and real-world decisions, supervisor coaching so enforcement is consistent and reasonable, and program verification so you can prove your controls are working instead of hoping they are.
If you want a straightforward assessment and a practical action plan you can actually implement, start at calgarysafetyconsultants.ca and we can scope the work to your sites, your exposures, and your regulatory footprint.
A hearing conservation program becomes “real” when it reduces dose, verifies fit, and uses audiometric results as feedback to improve controls, because you can meet the paperwork standard for years while workers quietly lose something they will never get back.
Connect with us here and let us help you improve your OH&S practices.
https://www.cdc.gov/niosh/noise/prevent/understand.html
https://www.cdc.gov/niosh/noise/about/noise.html
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95
https://www.ccohs.ca/oshanswers/phys_agents/noise/hearing_conservation.html
https://www.ccohs.ca/oshanswers/phys_agents/noise/exposure_can.html
https://www.canada.ca/en/employment-social-development/services/health-safety/reports/ears.html
https://search-ohs-laws.alberta.ca/legislation/occupational-health-and-safety-code/part-16-noise/
https://www.csagroup.org/store/product/2429917/
Because compliance often proves you have program elements on paper, while the real exposure dose stays high due to outdated monitoring, weak controls, and inconsistent hearing protection fit and use.
Most workplaces rely too heavily on hearing protection instead of reducing noise at the source, so small real-world gaps in fit and use quietly erase the protection you think you are getting.
You should re-check whenever equipment, processes, staffing, work methods, maintenance condition, shift length, or overtime patterns change, because these factors can materially change actual exposure even if the workplace “looks the same.”
Calgary Safety Consultants is here to help you ensure compliance, enhance safety, and streamline your OH&S program. Don’t wait—fill out the form, and we’ll connect with you to discuss how we can support your business. Let’s get started!
Calgary Safety Consultants delivers game-changing COR Audits and OH&S consulting designed to keep your business safe, compliant, and accident-free. With 30+ years of expertise in high-risk industries like oil & gas, construction, and manufacturing, we understand the unique challenges you face. We offer tailored safety solutions that not only meet regulatory standards but also reduce operational risks and protect your workforce. From conducting thorough safety audits to implementing comprehensive safety management systems, we ensure your team is fully supported. Our hands-on, collaborative approach means we're with you every step of the way, helping you achieve a safer, more efficient workplace. Let us handle the heavy lifting so your team stays protected, and your business thrives!
