Hearing Protection Devices Labeling Meeting

January 13, 2010

Attendees

Catrice Jefferson, EPA

Kenneth Feith, EPA

William Murphy, NIOSH

Sheli DeLaney, NIOSH

Mark Stephenson, NIOSH

Carol Stephenson, NIOSH

Surehder Ahir, OSHA

Claire Slupski, NIOSH

Elliott Berger, 3M/ANSI

Dan Shipp, ISEA

Meeting Minutes

Limited discussion to only primary labels. 

Principle concern: Language on the primary labels. Move away from
technical jargon and make labels understandable to a layperson. 

Primarily, wanted to change the wording on “active” and
“passive” hearing protector devices (HPDs). 

Wanted to come up with simple, understandable phrases that could still
convey the meaning of the original technical word. 

Discussed how to differentiate between different hearing protector
devices. 

Decided to label a conventional HPD “BASIC.” The language is clear,
not controversial, and it’s close to the Spanish equivalent. 

Discussed whether the description of the HPD had to indicate what the
product actually does. Decided that ultimately, the label was not
intended to give the functionality of the device. If there was any
essential information, it would be allotted to Section C. 

The “active” label was confusing because while the public thinks
that it only includes electronic devices, it also includes Level
Dependent HPDs. 

Discussed different possibilities as substitutions for the “active”
label. Originally decided to use “POWER ON” as a substitute, but the
phrase was deemed too vague and confusing. Finally chose “NOISE
CONTROLLING ON” as an appropriate substitute, because it was
completely accurate, gave more information, and was easy to comprehend. 

Discussed briefly what a better substitute for “impulsive” could be.
“Impulse” was the designated substitution, because it was easier to
understand. Additionally, impulsive noises were described as “gunfire
type noises” in Section C to further aid the user. 

Some were worried that the noise reduction ratings (NRRs) for
“BASIC” and “NOISE CANCELLING ON” functions would change with
impulsive noises. However, it was established that the NRRs for both of
those types of hearing protectors would not change, even if an impulsive
noise was applied. 

Decided to employ “market research” to find out if a layperson can
understand the new labels. 

Discussed the possibility of pictograms. Idea was not accepted, because
manufacturers will likely put instructional pictures on the packaging,
and there was a limit to the amount of space inside the labels. 

Emphasized consistency with wording and general design. 

Discussion on how to differentiate between “BASIC,” “IMPULSE,”
and “NOISE CONTROLLING ON” with active noise reduction HPDs.
“BASIC” is the NRR of the device when it is not “turned OFF,”
“NOISE CONTROLLING ON” is the NRR of the device when it is “turned
ON” and the sound levels are low, and “IMPULSE” is the NRR of the
device when an impulsive noise is introduced. 

Removed excess scaling for the bar graphs. Standardized a design for all
labels. 

Wording of Section C discussed. “All types of noise” was inaccurate,
so it was changed to “most common noises.”

“BASIC” defined: “The performance of a device absent any special
features. This includes electronic and level-dependant features.”

Discussed the NRR testing for “IMPULSE” for the active noise
reduction HPD. NRR range was based on 3 different impulses and not on
user fit. Determined a phrase to add to Section C to accommodate the
variation in testing. 

Determined that there would be no testing of different ranges of the
electric sound transmission HPD. Only high-level impulses will be
tested, as this HPD has no attenuation at lower levels. 

Discussed possible re-labeling of “IMPULSE” for the passive
level-dependent HPD and the electric sound transmission HPD to more
accurate labels that would differentiate between the three impulsive
HPDs.  Proposal not accepted in favor of consistency, brevity, and ease
of understanding. 

