Management Responsibilities
Management should make available the facilities to store records and should provide sufficient resources to process them quickly and accurately. The forms or computer format used to gather information is the foundation of a good record keeping system. These forms should be designed so that necessary actions are triggered and then documented. If a company does not have the available resources to design a hearing loss prevention record keeping system compatible with the general safety and health record system, the company should turn to consultants for assistance.
Because hearing conservation program records can be complex, management should see that program implementers are fully trained in the record keeping system and its function. There should be working copies of records as well as archived copies. If an outside contractor keeps the records, a method should be established to ensure that original records are accurate, and are returned and entered into the company's files in a timely fashion. Hearing loss prevention records are medical records and, as such, deserve the same level of integrity and confidentiality as other medical records. The company needs to make sure that these records are accessible only to program implementers, affected employees or their designated representatives, and government inspectors.
Increasingly, companies maintain all of their employee health and safety records in a computer system. The use of computers supports easy access and storage of data, provides for automatic triggering of actions based on the data contained in the records, and generates hard copies to be maintained as archives. Prudent managers will see that original copies of records pertaining to individual audiometry and hazard exposure monitoring are retained in personal medical or industrial hygiene folders. The records should be made available at the time of audiometric testing.
Having the audiogram available will allow an instantaneous check of the new audiogram with the others on record so that checks for threshold shift can be made and so that the reliability of the new audiogram can be assessed. Having information about hearing hazard exposure, hearing protector use, and related information available will allow the tester to make an accurate and timely report to the employee of the outcome of the evaluation as well as conduct the one-on-one training that is so important to hearing conservation program success.