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Noise pollution.

I read with interest Sidney A. Shapiro's recent article entitled, "Rejoining the Battle Against Noise Pollution" (Issues, Spring 1993). In the article, Shapiro stresses that noise pollution is ubiquitous, annoying, and often physically hazardous. He succinctly and eloquently reviews the Environmental Protection Agency's (EPA) congressional mandate under the Noise Control Act of 1972, the effects of long-term noise exposure, and his own suggestions for future action.

As someone immersed in the field of noise research for almost 20 years, I am well aware of the void created by the departure from the regulatory scene of the EPA's Office of Noise Abatement and Control (ONAC). An organization with which I am currently directly involved, the National Hearing Conservation Association (NHCA), has also observed and commented on this issue. NHCA is composed of professionals who are actively striving to prevent noise-induced hearing loss, not only in the American work force, but also in the general population. As such, our interests extend to all situations in which hazardous noise exists, whether that be occupational settings in industry and the armed forces, or nonoccupational applications in the consumer and recreational sectors.

In 1991, the Administrative Conference of the United States (ACUS) convened to discuss the dilemma of the EPA's congressional mandate, and the lack of funds and staff to enforce it. The NHCA responded in writing to ACUS, discussing some of the same issues mentioned in Shapiro's article. We pointed out the value of ONAC's prior sponsored research and the need for a renewed governmental presence in that arena. We endorsed EPA's public education and information dissemination activities and its technical assistance programs to state and local community noise control agencies. We noted the potential public health problem resulting from a proliferation of recreational noise sources and the importance of EPA's function as a coordinator of all federal noise control activities.

NHCA also addressed an additional issue, one not mentioned in Shapiro's article, namely the EPA's mandate to label noise-reducing as well as noise-producing products. The one kind of noise-reducing product that had been regulated by ONAC before its demise was hearing protection devices. Such devices are required to exhibit a noise reduction rating (NRR) as an indication of effectiveness. Unfortunately, in the decade subsequent to promulgation of the regulation, it has become clear that the NRR, which has grown to inappropriate importance in the minds of the purchasing community, is a misleading number for purposes of predicting in-field performance. Yet, because of lack of staffing and support, ONAC has been unable to examine this problem and revise the regulation.

With these perspectives in mind, I and the organization I represent applaud Shapiro's article and join him in his call to resuscitate ONAC and to rejoin the battle against noise pollution.

ELLIOTT H. BERGER President, National Hearing Conservation Association Des Moines, Iowa

I wish to acknowledge Sidney A. Shapiro's commendable efforts in the promotion of noise abatement and control. He has championed this noble cause for many years. I hope his tenacity and hard work will lead to a reinstatement of a federal noise prevention program.

Despite the federal program's shortcomings, during the early 1970s EPA's Office of Noise Abatement and Control made great progress in educating the public about the risks associated with noise pollution and improving livability in the nation's communities. Through technical outreach provided by the Each Community Helps Others (ECHO) program and technical assistance centers placed in several universities, a national network of advocacy groups and noise control programs was developed. Unfortunately, the demise of the federal program in 1981 was a death warrant for the continuance of an effective and systematic national effort to control environmental noise pollution. The state of Oregon, as well as several others, followed EPA's lead and abdicated all noise prevention and mitigation work in 1991.

One of EPA's notable accomplishments was developing the 24-hour averaged sound level, with 10-decibel nighttime penalty, known as the Ldn metric. This criterion standardized measurement of airport noise impacts on communities. The Ldn metric underestimates the health effects associated with acute noise exposures that occur during aircraft flyovers but nonetheless is still a valuable tool for evaluating environmental impacts.

The federal program fell short of its mandate in protecting the public from product noise, with the exception of the "quiet" air compressor. Product noise performance standards were never promulgated for noise source categories that affect the greatest number of people. For example, noise generated by air and heating systems (commercial and residential), lawn mowers, construction equipment, chain saws, backpack blowers, parking lot sweepers, and the like affects hundreds of thousands of people daily. In retrospect, applying existing technology to a wider range of consumer products would have significantly lowered ambient noise levels in our communities. The Department of Defense is known for its submarine fleet that has been made essentially undetectable to potential enemies by the application of noise and vibration control technology. The most expensive luxury passenger vehicles are not plagued by engine noise. Furthermore, some noisy products can be quieted using modern computer technology and the application of acoustic signals that cancel unwanted noise.

EPA's noise-labeling program and use of the marketplace to promote the manufacture of quieter consumer products produced limited results. But market-based programs can work when properly applied. The refrigerator is an excellent example of the marketability of "quiet." In the recent past, residential refrigerator compressor units were obnoxiously noisy. Consumer demand for a quieter refrigerator produced results and a restful night's sleep. The potential exists for big improvements in other products. For example, typical lawn mowers are three to four times louder than the quietest models. Labeling can also benefit industry by promoting sales of equipment that complies with Occupational Safety and Health Administration and community noise standards.

I strongly support Shapiro's recommendation to reinstate the federal noise program. Reauthorization of the federal noise act is a possibility under President Clinton. To be effective, EPA should give a very high priority to instituting noise prevention and mitigation activities within the federal bureaucracies and should not shield federal agencies from compliance or legally avoid enforcement by preemption.

Noise pollution should be controlled with the same due diligence accorded to chemical pollution.

TERRY OBTESHKA Small Business Assistance Program Air Quality Division, Oregon Department of Environmental Quality Portland, Oregon
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Title Annotation:response to Sidney A. Shapiro, Issues, Spr 1993
Author:Berger, Elliott H.; Obteshka, Terry
Publication:Issues in Science and Technology
Date:Jun 22, 1993
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