External factors are those forces and parameters that influence the program in one or more stages of progression, but over which the HLR program has no control. These factors include the more obvious issues like limited resources, a lack of surveillance data, a low sense of urgency or priority for hearing loss in the occupational safety and health arena, and a long, difficult regulatory process. Less obvious issues that influence the program include difficulties in gaining access to adequate study populations or records, the perception that interventions, particularly engineering controls, may be too costly to implement, and the rapidly shifting business climate that can result in frequent mergers or takeovers of manufacturing enterprises with which we have collaborated. The HLR program strives to recognize the external factors that provide challenges to the program, and to adapt in constructive ways that lead to progress or alternative research opportunities even in the face of those challenges.
An example of the importance of the regulatory environment as an external factor on the HLR program comes from the MSHA regulation on noise exposure published in 1999.15 Prior to that regulation, participation in hearing conservation programs by miners was low, interest in hearing loss research by mining sector stakeholders was low, and research activity was also minimal. Following the regulation, which placed a primacy on engineering control of noise in mines, a major shift in interest in the mining sector took place with respect to research on noise-induced hearing loss in general and engineering control of noise in particular. As a result of this shift, NIOSH has been able to engage partners in research planning and in the development, test and evaluation of noise control interventions. While this is a relatively recent shift, and much of the HLR program work on this topic is immature, the expansion of mining research activity within the HLR program brought about by the MSHA regulation is a striking example of how the regulatory climate can affect the program.
In cases where the regulatory climate is not as proactive toward advances in occupational hearing loss prevention, the HLR program works to advance hearing loss prevention activities through alternative means, e.g. consensus standards committees. Our work on hearing protector measurement and rating is an example of this approach (see Research Goal 2.1). Persistence is also a characteristic of the program, and breakthroughs are possible, as indicated by the recent moves – with NIOSH technical assistance – by EPA to reopen the HPD rating regulation that is over 25 years old. The approach of partnering with non-governmental standards organizations, or even government agencies from other countries, has proven successful in the case of ototoxic chemicals, where the HLR program has played a role in the development of guidance or legislation (see Research Goal 4.6).
In another case, the new requirements for recording occupational hearing loss on the OSHA 300 log (29 CFR 1904.10) promise to provide the first national record ever of occupational hearing loss. There is no national occupational hearing loss registry. Without these data, it is not possible to effectively track and evaluate the successes and failures of occupational hearing loss prevention programs. But the prospect of the surveillance data that may come from the new OSHA 300 log is quite exciting, and demonstrates both the influence of the regulatory external factor on HLR program abilities as well as the positive influence of persistent HLR program recommendations on an external factor. Our researchers were able to facilitate the implementation of this new regulation by demonstrating that certain technical difficulties that had held back such a system before could be resolved.
The nature of hearing loss as an occupational illness is also an external factor that presents both a challenge and an opportunity for the HLR program. While hearing loss is permanent, in most cases it has a gradual onset. Because of that, it is sometimes not considered serious enough in severity to warrant aggressive preventive actions (and the research that would identify and validate preventive actions). The gradual onset of hearing loss also works against employers’ motivation to overcome economic barriers to investing in quieter equipment, improved work practices, or better utilization of hearing protectors. We have increased training effectiveness and motivational research to evaluate how we can best influence workers and employers to be more proactive in working to prevent occupational hearing loss.
Today’s business climate, with many changes in work organization and management, is another external factor that can be a barrier to the HLR program. As with any field-oriented occupational health research program, the reality of employers’ limited resources is a factor that may profoundly affect the program. For example, a food processing and canning factory committed to a research partnership with the HLR program but then withdrew its cooperation after two subsequent ownership changes. Program resources had been spent on the project, but no useful data were collected beyond baselines. One lesson learned from this experience is that HLR program managers must evaluate not only the scientific climate but also the organizational climate of the potential research study site more carefully in the future. Another experience that did not go as we had expected was the patenting and development of a device for enhancing communication in noisy environments while providing hearing protection. This device was invented and patented by the HLR program and dubbed “Ear-Talk.”(see Research Goal 2.4) However, in spite of a number of attempts, no developer or market was secured for the device and it has not been effectively transferred into the workplace. The development of Ear-Talk preceded the existence of the ORTT in the NIOSH OD. This r2p office now offers additional assistance and expertise in technology transfer that lowers the risk of having this type of unsuccessful situation in the future.
Sometimes external factors require that HLR program researchers and managers be patient when the opportunity for which we had planned does not materialize. Recent opportunities to advance the program in engineering control of noise and in addressing the needs of hearing-impaired workers are examples of program breakthroughs that occurred when external factors finally shifted and barriers that had existed before either disappeared or were reduced. Our managers will need to be both creative and resourceful to direct resources to areas of research where we can have the most impact in the least amount of time.