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As part of the Hearing Conservation Program, the employer is required to evaluate the effectiveness of any hearing protection provided to employees. Hearing protectors are rated using a system developed by the EPA, the noise reduction rating (NRR). The NRR is derived in a laboratory setting. There is some controversy about how accurate the NRR is. OSHA’s method for evaluating the effectiveness of hearing protection includes subtracting seven from the NRR to account for real world versus laboratory setting.

For OSHA compliance officers, OSHA divides the result in half before subtracting from the exposure level to account for individual improperly inserting the hearing protection. OSHA does not currently require employers to divide the result in half. Which method of evaluation of hearing protection devices do you believe employers should be required to use and why? Do you believe there is a better way to evaluate hearing protection devices? Please explain your response. 

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