Dobie and Clark (2014) have reviewed certain studies to determine whether the 3-dB or the 5-dB exchange rate (ER) more accurately predicts noiseinduced hearing loss. The authors have gone to considerable trouble and expense, including translations from German, Dutch, and Czech, to reanalyze data from studies, several of them more than 40 years old. In their discussion of the ER, the authors concentrate on the hearing loss studies analyzed by the Dutch scientist Wilhelmina Passchier-Vermeer in the early 1970s.From their results, Dobie and Clark have made recommendations that most of the rest of the world has already chosen not to implement. The 5-dB ER is used by Occupational Safety and Health Administration (OSHA) and two other U.S. agencies concerned with noise-exposed workers, the Mine Safety and Health Administration also in the U.S. Department of Labor, and the Federal Railroad Administration in the U.S. Department of Transportation. However, the origin of the 5-dB rule is characterized by oversimplification and economic/political considerations (Suter 1992).The original Department of Labor "Walsh-Healey" noise standard required a permissible exposure limit (PEL) of 85 dBA for continuous noise and a method for assessing noncontinuous noise that varied according to noise level and degree of intermittency. This standard was officially promulgated early in 1969 (Department of Labor 1969a). It was subsequently withdrawn after a change in administration, and later that year, a noise standard was issued with a 90-dBA PEL and a 5-dB ER, which regulation is still in effect today (Department of Labor 1969b). In the meantime, several U.S. Agencies and most other nations, including all the nations of the European Union, have adopted the 3-dB ER for all types of noise-continuous, varying, and intermittent.In her analysis on the effects of varying and intermittent noise, Passchier-Vermeer did not test whether the median data from the studies she selected supported either the 5-dB or the 3-dB ER. (The 5-dB rule had just been implemented by the Department of Labor and was not well known internationally.) Instead, she examined the extent to which the hearing loss data from varying and intermittent noise followed the hearing threshold levels resulting from exposure to continuous noise, either from the continuous noise data she had collected (Passchier-Vermeer 1973) or those collected by Burns and Robinson (1970). When compared with Passchier-Vermeer's continuous noise data, the hearing threshold levels from varying and intermittent noise generally followed the continuous noise curve, supporting the use of the 3-dB ER for noncontinuous noise. When Passchier-Vermeer compared the hearing threshold levels from varying and intermittent noise with the equal energy (3-dB) curve developed by Burns and Robinson, most of the data points fell above the curve, indicating that intermittent and varying exposures were at least as harmful as the continuous exposures. She attributes the difference between the two comparisons to the increased...