Absolutely! To me what's most disturbing about "Just use headphones" is it's highly prevalent information-age companies but shows a deep _lack_ of understanding for the need for _focus_ and long periods of uninterrupted concentration essential for creative work.
Some people will tease you about wearing them, but honestly by the end of most of my stays at Companies I've converted at least 3-4 people to using them.
Like the article states, listening to music reduces your cognitive abilities, I prefer absolute quiet. I find it almost beautiful like a great song to hear nothing but the clarity of my own thoughts.
The standards of measurement are likely different. Measuring "volume" (sound pressure level) is a very tricky business.
However, it raises the question: "Should employees have to solve these problems?". Depending on the office size, a more private setting could be provided for the employees affected.
In many offices, you can't just re-orient your desk or choose to move.
It certainly would be conspicuous.
I have an office now and temp is my main problem since I am right next to the server room.