Portable music players with hearing protection

April 14, 1987

MEMORANDUM FOR: EDUARDAS J. SKLADAITIS
Regional Administrator

FROM: LINDA R. ANKU
Regional Administrator

SUBJECT: Use of walkman radio, tape or CD players and their effect when hearing protection is in use – Inspection No. 100499150.

Your technical request has been reviewed by Dr. John Barry who presents the following information:

Twenty different Walkman type headsets were evaluated for noise attenuation at North Carolina State University (NCSU). The NRR varied from a low of 0.3 dB to a high of 2.6 dB with an average NRR of 1 dB. Therefore, such headsets afford no ear protection.
If Walkman headsets are worn over otherwise effective ear protection, then the unit's volume control has to be adjusted to exceed the hearing protector's field attenuation. This obviates the effectiveness of the ear protection and is a violation of the noise standard 29 CFR 1910.95(i)(2)(i) or (ii).

The NCSU study also found the following facts. The typical commercial Walkman headset provided the following A-weighted decibel levels for these volume settings: 64 dBA/25%, 81 dBA/50%, 91 dBA/75%, and 96 dBA/100%. In a North Carolina textile mill where the TWA was 87 dBA NCSU researchers found the median Walkman level to be 84 dBA with 20% of the workers listening at 90 dBA or greater. The industrial hygiene department of GM found typical headset output levels of 99 to 100 dBA in auto workers with a maximum exposure level of 117 dBA. Most of the commercially-available headsets for Walkmen will produce 100 to 103 dB SPL for an output voltage of 1 mV. Therefore, listening to a Walkman unit at more than 50% to 75% rated output will generate sound levels in excess of the OSHA PEL creating a threat to the wearer's hearing, and this may also produce a safety hazard by masking environmental sounds that need to be heard.
The United States Postal Service has developed special ear muffs equipped with volume-limited music for use in monotonous high noise jobs to protect employee hearing but at the same time allowing them to enjoy background music. Such devices are in compliance with OSHA regulations if they meet the attenuation requirements relative to the workplace noise levels and their average music output is less than 90 dBA.
In summary, the following compliance direction can be put forward. Use of walkmen in noise environments in excess of Tables G-16 and D-1 is a violation. Use of Walkmen over required ear protection is a violation. Use of Walkmen in occupational noise less than Tables G-16 or D-1 is at managerial discretion unless its use causes a serious safety hazard to warrant issuance of a 5(a)(1). Management and employees must be made aware that Walkmen type devices do pose a hazard to hearing if they are played too loud for any significant length of time, whether on or off the job: The energy, not the esthetics, of sound poses the threat to human hearing sensitivity.
if you need further assistance or clarification, then contact Dr. Barry directly at the above address or by telephone (FTS 596-1201, Commercial 215-596-1201).
March 31, 1987

MEMORANDUM FOR: LINDA R. ANKU
Regional Administrator

ATTENTION: Kenneth W. Gerecke
ARA/Technical Support

SUBJECT: Use of Walkman Radio, and Its Effect on Hearing .

During an informal conference concerning a noise citation issued to the U.S. Postal Service, a question arose regarding the use of a walkman radio and its effect on hearing.
Employees of the Postal Service exposed to noise levels between 85 - 90 dBA routinely use walkman radios at their work stations. The Postal Service requested clarification on whether or not this practice has any adverse impact on hearing.
I am requesting clarification on this issue. Please forward your response to my attention (Inspection No. 100409150).
A prompt reply on this matter will be appreciated. If you have any questions, please contact Chrysoula J. Komis at 597-4955.
EDUARDAS J. SKLADAITIS
Area Director
[Corrected 04/03/2008]