To:		ANSI S12/WG11

From:	Elliott H. Berger

Date:		February 7, 2007

Re:		Report #53A – Addendum following informal EPA Workshop

As many of you know Ken Feith called an informal meeting on Jan. 23 and
24 in Washington, DC, on the impending EPA rulemaking process on hearing
protector labeling.  We had a wide-ranging and fruitful conversation
among those 20 or so who were present.  There was a strong interest in a
two-number rating system like what appears in the S12.68 draft.  

One change that was discussed that seemed well accepted by those present
was to include a graphical presentation of the two numbers in order to
make the data easier to understand at a glance, and to further diffuse
the tendency to “take a number and run.”

Dan Gauger has edited the 12.68 draft and his spreadsheets to include a
graphical presentation, thus, please consider the attached Version 4.6
as our working copy.  Since the standard is not intended to provide
explicit graphical guidance on how a label would look, Dan took a moment
to put together a separate suggestion, in color, that is also attached. 
Please bring your comments on the standard as I would like to get the
WG’s support in Savannah to send this on to S12 for review and voting.

ANSI S12.6-1997 (2002)

As I mentioned in Report 53, at this coming meeting we must look at
changes that should be made in S12.6 since it is up for review and
reaffirmation in 2007.  The Standards Secretariat needs to know from me
in March what our plans are.  Additionally, it became clear during the
EPA meeting that regardless of the procedure that is selected, A or B,
we should do whatever we can to tighten up the interlaboratory
variability.  To do this we must, whenever possible clarify the wording
in the document and the procedures so that all labs test similarly.

For example, in our discussion it became apparent that in the interlab
study, some labs worked with the Classic® differently than did others
for Method A.  Howard Leight labs discussed with the subjects how to fit
the product but did not actually fit one during the training process. 
E(A(RCAL labs not only gave verbal instruction but also an insertion
assistance/demonstration during the fitting.  WPAFB marked a line on the
circumference of the plugs and then visually checked to see that the
plugs were inserted at least to the mark; otherwise they had to be
refit.  All of the procedures meet the letter of the current S12.6
Method A and all are quite different.

The following revised wording is what we had agreed to put in Section
8.2 when we met in Hawaii.  Is this adequate?

The experimenter shall give each subject precise instructions and
practice in fitting the hearing protector in accordance with
instructions from the manufacturer, and the experimenter’s own
knowledge in fitting the same or similar devices.  The experimenter
shall provide verbal clarification and physical assistance in inserting
the products as part of the instruction process, and may also utilize
the subject’s assessment of the relative loudness off the fitting
noise (clause 4.3.6).  When the product is supplied in multiple sizes,
the experimenter shall assist the subject in selecting the proper size
hearing protector.  Trial sound attenuation measurements shall not be
part of the sizing or fitting procedures.  Once the experimenter has
determined that the subject can properly fit the device, the hearing
protector shall be removed.  

With respect to Method B, I have observed that the reading of the
required text to the subjects is pro forma, and that subjects often
appear to pay little attention.  It has been suggested that we require
during Method B testing that subjects repeat back to the experimenter
their interpretation of what they have just heard, and that the
experimenter require them to re-listen/re-read if they do not get it
correct.  Perhaps this or other ideas can be incorporated into the
Method-B process.

So please give these issues some thought and bring your comments on
S12.68 and your suggestions to tighten up S12.6.

See you in Savannah from 8:30 am – 1:00 pm on Sunday February 18,
following NHCA.  Please plan to attend the entire meeting if at all
possible.  This is an important meeting – our goal should be to
complete S12.68 at this time so it can be balloted and to make decision
on S12.6 for its reaffirmation.

 PRIVATE  

Elliott H. Berger 

Chair S12/WG11

Attach: T05-04 Draft S12.68.doc v4.6

	   HPDratings_S12.68_NRSA-G-OB v5.xls

	   NRSA bar graph example.pdf

  FILENAME  \* Lower \p  \* MERGEFORMAT  c:\...\_word
files\wg11\reports\rep53a mem.doc  

S12/WG11 Report #53A		Page -   PAGE  2 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

 E(A(RCALSM Laboratory 

