National Consumers League
https://www.regulations.gov/comment/FDA-2021-N-0555-0737
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“The proposed output limit of 120 dB SPL is consistent with the standards used for consumer electronics products, but there is a significant difference between earbuds used to listen to music for short periods of time, and hearing aids that a person with mild-to-moderate hearing loss will wear for most of a day. Prolonged exposure to 120 dB amplification can, according to hearing and medical experts, place the user at risk for suffering increased hearing loss. The World Health Organization has declared, in fact, that sound levels as high as 100 dB can only be safely endured for 15 minutes each day.
