Hearing Health and Technology -- Workshop, Project No. P171200
Thank you for organizing your planned Hearing Health and Technology Workshop and its examination of competition, innovation, and consumer protection issues involving hearing health and technology and, especially, hearing aids. As a Hearing Loss Support Specialist with over 20 years of experience helping people with hearing loss learn to live with their disability, I've found there is a major consumer protection issue that the FTC, as the public's monitor of the advertising and marketing practices of audiologists, hearing aid dispensers and manufacturers, should consider addressing. The Americans With Disabilities Act (ADA) mandates that all new or significantly upgraded assistive listening systems (ALS) in the US be hearing aid compatible and currently the only hearing aid technology that meets that standard is induction (hearing) loops. For that reason, the regulations require that the ALS either be an audio frequency induction loop system (a hearing loop) or that 25% of the receivers for Radio Frequency or Infra Red systems be equipped with neckloops in order to meet that mandate. For hearing aids (standard or the possible OTC variety under consideration), personal sound amplifcation products (PSAPS) and some other asisstive devices to function with an ADA compliant ALS, they must be equipped with telecoils - the receivers for the silent electromagnetic signal sent out by the induction loop. Although somewhere between 70% and 80% of all hearing aid models currently on the market and all cochlear implant processors contain telecoils, studies have found that over 60% of first time buyers are never told about their presence or purpose nor does the literature accompanying the devices always adequately alert the buyer to their presence and purpose. The general public is not aware of the ADA requirement nor is it reasonable to expect that they will be made so unless manufacturers and sellers of hearing aids and some types of PSAPS are required to alert them to the standard. In light of this, I suggest that the FTC consider requiring that the packaging and user information contained in the packaging of all such devices include a statement such as, "This (these) device(s) meet(s) hearing aid compatibly standards of the Americans With Disabilities Act for use with an assistive listening system" or "This (these) device(s) DO NOT MEET the hearing aid compatibility standards of the Americans With Disabilities Act for use with an assistive listening system." Beyond the packaging information requirement, any advertising by manufacturers and sellers of such devices in publications that are distributed accross state lines should also be required to contain such statements. Providing the public with this information will alert them to the hearing loop/telecoil technology available to them and cause many of them to ask the sellers of such devices to explain what it means and how they can use their devices with ADA compliant assistive listening systems. The result would be a raising of awareness and, over time, availability of such systems throughout the US to the benefit of the estimated 48,000,000 Americans with a measureable hearing loss.