Hearing Conservation Program

Firefighters lose hearing slowly, from sirens and air horns in the cab, positive-pressure fans, saws, hydraulic tools and pump panels, and discover it at retirement when there is no baseline to prove where it came from. This program prevents that loss and, where it happens, documents it. When the program is working, the department knows where its noise is because it has measured it; the loudest sources have been engineered down (enclosed cabs, intercom headsets, siren placement); members wear hearing protection at the pump panel, at the saw and at the fan as naturally as they wear gloves; every member has a baseline audiogram and an annual one, and a change is caught early and acted on; and a member with occupational hearing loss has the records for a compensation claim. The measure of success is a falling number of standard threshold shifts and a rising number of members who still hear well at retirement.

Required for every department. Program Profile Worksheet Part C item 23 (“Sirens, pumps, saws, aircraft: Required”). Applies to all operational members, apparatus operators, mechanics, training staff, airport and marine crews where those modules are on, and anyone else the noise survey identifies. It is a sub-program of the medical program (Medical, Fitness and Wellness Program) for audiometry and of the apparatus and facilities programs for engineering controls; this note holds the whole picture.

Consistent with 06 Glossary and Acronyms.

• A-weighted decibel (dBA): a sound level measurement weighted to the sensitivity of human hearing.
• Audiometry: the measurement of hearing thresholds by frequency in each ear.
• Baseline audiogram: the first audiogram against which later ones are compared; taken on hire or at program start, after a period away from loud noise.
• Exchange rate: the decibel increase that halves the permitted exposure time; the ACGIH TLV uses 3 dB (ACGIH, n.d.).
• Hearing protection device (HPD): earplugs, earmuffs or headsets that reduce noise at the ear.
• Noise dose: a member’s cumulative noise exposure over a shift relative to the exposure limit.
• Occupational hearing loss: a permanent change in hearing caused by workplace noise.
• Standard threshold shift (STS): a change in hearing threshold from the baseline that the program defines as significant and that triggers follow-up (the department adopts a definition with its audiometric provider).
• Time-weighted average (TWA): the average noise level over an eight-hour shift.
• Psychological safety: the shared belief in a team that it is safe to speak up, ask, admit error and challenge (Edmondson, 1999)DOI; here, that it is safe to ask for the headset or to say “I can’t hear the radio.”

Only the differences from 01 Roles and Responsibilities. Owning team: Health, Wellness and Rehab Program Improvement Team (06 Program Improvement Teams), with the Apparatus, Driving and Roadway team and the Facilities team for engineering controls.

Requirement. The department measures the noise its members are exposed to, by source and by task, and repeats the survey when apparatus, equipment or facilities change and at least every five years (ACGIH, n.d.; see J23 Noise and Hearing Conservation for the limit your jurisdiction applies). (S1)

Minimum method. A sound level survey with a calibrated meter, and personal dosimetry for a sample of members on representative shifts, covering: apparatus cabs with the siren and air horn in use, windows open and closed; pump panels at operating pressure; positive-pressure fans at the operator position; rotary and chain saws; hydraulic rescue tools and their power units; air compressors and fill stations; apparatus bays with vehicles running; shops; training grounds; alerting systems in stations; airport and marine equipment where applicable. The worksheet is in the toolkit (section 17.1). Results are compared with the TLV (85 dBA eight-hour TWA, 3 dB exchange rate) and with the impulse ceiling; sources over 85 dBA are listed with their control. Fire-service sources commonly exceed 100 dBA in the cab with the siren running.

Evidence. Survey report with dates, instruments, calibration and results; the controls list.

Requirement. Noise is controlled at the source and the path before hearing protection is relied on. (S1 for the apparatus specification; S2 for retrofit)

Minimum method.

Evidence. Specification language; retrofit plan with dates; survey re-measurement after a control is installed.

Requirement. Hearing protection appropriate to the source is issued to every member, with training in fit and use, and is worn at the sources the survey identifies (NFPA 1550, 2024, ch. 9), as the applicable PPE regulation also requires (J13 Firefighter PPE and Protective Equipment). (S1)

Minimum method. Selection by the Equipment Standards team with the HSO: earmuffs for pump panels, fans and tools (quick on and off, visible compliance); earplugs on a cord for every member’s turnout coat pocket; intercom headsets in cabs; electronic level-dependent protection for officers who must hear radio traffic at the pump or tool position. Attenuation chosen so that the protected level is below 85 dBA without over-protecting (a member who cannot hear a mayday is not safer). Issue recorded per member; replacement on condition. Where to wear it is stated in the SWP for each task (pump operations, saws, fans, hydraulic tools, apparatus bays with engines running, training ground props) and marked with signage at fixed sources. Radio and fireground communication needs are considered in every selection; this is a selection problem to solve, not a reason to skip protection.

Evidence. Issue records; signage; officer observation of use; the JOHSC inspection.

Requirement. Every operational member and every other member the survey identifies has a baseline audiogram within six months of hire or program start, and an annual audiogram thereafter, performed by a qualified provider in a suitable environment, with results held by the provider and the determination held by the department (NFPA 1580, 2025; CCOHS, n.d.-a). (S1 baseline; S2 annual)

Minimum method. The audiogram is part of the annual medical (Medical, Fitness and Wellness Program section 17.1) or a separate mobile or clinic session; pure-tone air conduction at the standard frequencies in each ear; the baseline taken after at least 14 hours away from loud noise, with the member told to avoid noise before the test; the provider compares each annual audiogram with the baseline and flags a standard threshold shift under the definition the department adopts with the provider; the department receives only: completed (date), no shift, shift flagged, and any work restriction. Volunteers: baseline at Tier 1 entry and annually for SCBA-qualified and operator members; every three years for others (align with the medical tiers).

Evidence. Audiometry tracker (section 17.2); provider’s calibration certificate; aggregate shift count.

Requirement. A flagged shift is confirmed, the member is told, the cause is looked for, and controls are adjusted. (S2)

Minimum method. Retest within 30 days to confirm; the physician or audiologist counsels the member; the program manager and the HSO review the member’s noise exposure (role, apparatus, tasks) without clinical detail; hearing protection is refitted or changed; where the shift is work-related, the member is told about the compensation claim process and the navigator helps; the baseline is revised per the provider’s practice; the shift is recorded in aggregate and feeds the survey and the controls list. A pattern (several shifts at one station or on one apparatus) is a corrective action.

Evidence. Follow-up records (count, time to retest, actions); the register.

Requirement. Audiometric records are retained for the duration of service plus 30 years, the US benchmark (OSHA, n.d.-a, 29 C.F.R. § 1910.1020), unless the applicable rule sets a longer period (J09 Records Retention); the department can produce a member’s audiometry history and noise exposure history for a compensation claim within 10 working days. (S1)

Minimum method. The provider holds the audiograms and sends the determination; the department’s tracker holds dates and flags; the noise survey and the member’s role and apparatus history are the exposure record; the claim navigator from the cancer program handles hearing loss claims by the same checklist. Confidentiality per Medical, Fitness and Wellness Program section 17.9.

Evidence. Tracker; retention schedule in 05 Document Control and Records; a sample export.

Requirement. Every member understands how hearing is lost, where the department’s noise is, how to fit and wear protection, and what the audiogram is for. (S1)

Minimum method. Section 6.

(a) Work-as-done. Before the hearing protection SWP or the audiometry schedule is written or changed, the learning team describes the real noise day: who wears the headset in the cab and who leaves it off to hear the radio; whether the pump operator puts muffs on before or after the first line is charged; where the earplugs actually are at 0300; what the saw operator does when the officer is shouting; how many members have ever had an audiogram and what they think it is for; and whether a member who cannot hear the radio well would say so.

(b) Capacity and margins. Hearing is protected most days because the cab has headsets, the muffs hang at the pump panel, and the task is short. The margin erodes when headsets are broken and not replaced, when the fan runs for an hour at a long overhaul, when the only earplugs are in the station, when the siren is used for emphasis, and when a member who is losing hearing hides it to stay on the truck. The program protects the margin with the apparatus specification, the issue record, the replacement rule and the annual audiogram that catches the loss early enough to do something.

(c) Just culture. A member who did not wear protection at the saw because the muffs were full of water, or who left the headset off because the intercom failed, adapted to conditions; the learning team finds the condition and the program fixes it (Dekker, 2016). The learning firewall applies. A member who hides a hearing loss that affects radio communication is helped, not punished; the response is an assessment and an accommodation, and the conduct process is not used for health.

(d) Psychological safety. A member says “I can’t hear the radio over the pump” or “The headset on this truck is dead” and the officer thanks them and fixes it, with a defect report the same shift. A member asks for an audiogram between annual tests and gets one. Leaders show it is safe by wearing the protection themselves at the pump and the fan, by having their own audiograms, and by reporting back what the survey found and what was retrofitted (Edmondson, 1999)DOI.

(e) Learning link. A member with a confirmed standard threshold shift, a cluster of shifts, or a communication failure at an incident attributed to noise is a Tier 2 Post-Incident Analysis as a system learning event (The Human Factor, 2026a). After any noisy evolution the Tier 1 after-action review asks: “Who could not hear a message that mattered, and what was the noise?” “Where was the protection, and why was it not on?” Method: Incident Investigation and Learning Program; tiers: Manual 02 - The Three Tiers and Event Triage.

• Hearing protection requirements are written into the task SWPs rather than a stand-alone SWP: pump operations and roadway scene blocking (Apparatus, Driving and Roadway Operations Program), ventilation and saw operations, hydraulic rescue tools, fan operations, apparatus bay and shop work (Facilities and Station Safety Program), training ground props (Training Safety and Live Fire Program).

• Noise survey worksheet (toolkit 17.1)
• Audiometry tracker (toolkit 17.2), a column set on Form - Annual Medical and Fitness Completion Tracker
• Hearing protection issue record (toolkit 17.3)
• Standard threshold shift follow-up record (toolkit 17.4)
• Training and competency sign-off (toolkit 17.5)
• Retention: audiometry and noise survey records, duration of service plus 30 years (OSHA, n.d.-a, as the benchmark)

Loop test. An operator at a volunteer station tells the HSO on Monday that the tanker’s headsets have been dead for a year and the crew rides with the windows down and the siren on. By Wednesday the defect is in the register with fleet as owner and a repair date, a box of earplugs is on the truck, and the operator has heard back. Within the quarter the headset coverage indicator is reported by station so that the other dead headsets show up, and the retrofit plan has a line for every one.

Hearing items are scored within Checklist - Medical, Fitness and Wellness. Accreditation crosswalk: this program supplies the audiometry element of regular medical evaluations under CPSE (2019) criterion 11B.1. The five questions an auditor asks first:

1. Show me the noise survey: when, what instruments, which sources were over the limit, and what was done about each.
2. Get in the nearest front-line cab: do all the headsets work?
3. Show me the muffs at the pump panel and the earplugs on the truck.
4. Pull 10 members: does each have a baseline and a current audiogram for their tier?
5. How many standard threshold shifts were flagged last year, and how many were retested within 30 days?

• Hearing loss claims surface at retirement with no baseline. Neither the member nor the department can show where the loss came from. The baseline on hire answers it.
• No audiometry because the law does not require it. Several Canadian jurisdictions have no statutory audiometric testing requirement (CCOHS, n.d.-a), as J23 Noise and Hearing Conservation shows; the standard of care does not depend on the statute. The medical program answers it (NFPA 1580, 2025).
• Headsets in the cab that nobody fixes. The daily check, the defect clock and the coverage indicator answer it.
• Over-protection at the pump panel so the operator cannot hear the radio or a mayday. The selection rule (protected level below the limit, not as low as possible) and level-dependent devices answer it.
• The siren used for emphasis. Siren and air horn discipline in operator training answers it.
• Volunteers excluded because the test is at a clinic during the day. Mobile audiometry at station nights answers it.

Stage 1 minimum (first 12 months).

• Noise survey of apparatus cabs, pump panels, fans, saws, hydraulic tools, bays and shops.
• Hearing protection issued to every member; muffs at every pump panel, fan and tool station; earplugs on every apparatus.
• Headset specification written into the next apparatus purchase; retrofit plan dated.
• Baseline audiogram for every operational member (mobile audiometry at station nights for volunteers).
• Tracker started; provider agreement in place.
• Training at recruit level and a one-hour session for all members.

Cost (order of magnitude; confirm locally).

• Noise survey: HSO time with a borrowed or rented meter and dosimeters, or a contracted hygienist for two to three days.
• Hearing protection: earmuffs per panel and tool station, earplugs per member per year; a modest recurring line.
• Headsets: the largest capital line; per riding position per apparatus; stage by apparatus age.
• Audiometry: a per-test fee from a mobile or clinic provider, or included in the medical contract.
• Staff time: program manager about two hours a month; HSO survey and follow-up time.

Record the figures in the team’s budget worksheet (06 Program Improvement Teams section 11).

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

Surveyed by (role), date; instrument serial and calibration; reviewed by program manager (date); JOHSC informed (date); next survey due.

American Conference of Governmental Industrial Hygienists [ACGIH]. (n.d.). Threshold limit values for chemical substances and physical agents and biological exposure indices (current edition).

Canadian Centre for Occupational Health and Safety [CCOHS]. (n.d.-a). Audiometric testing by jurisdiction (OSH Answers). https://ccohs.gc.ca/oshanswers/phys_agents/audiometric_testing.html

Occupational Safety and Health Administration [OSHA]. (n.d.-a). Access to employee exposure and medical records (29 C.F.R. § 1910.1020). U.S. Department of Labor. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1020