In the Machzor Siach Sifsoseinu for Pesach (pg. 715) they bring from R’ Chaim Kanievsky zt”l after bringing the Sifsei Chachomim: “Strictly speaking, when davening shemonah esrei one should say the words quietly in a clear manner, however, they shouldn’t be audible to others. Consequently here, when he could hear himself, and the words were said clearly, just there was outside interference that stopped him hearing due to the frogs, perhaps he fulfilled his duty according to all opinions, even according to those who hold that one must hear with his ears, the words that leave his mouth”. They also bring in the sefer Siach HaPesach (pg. 96) in the name of R’ Chaim, that since the reason Moshe couldn’t hear was because of outside interference, bedieved Moshe fulfilled his obligation of tefillah.
They also bring the Shulchan Aruch (Orach Chaim 101:2) which says: “One shouldn’t only daven in his heart, rather, one should enunciate the words with his lips and make sure they are audible to the ears, however, it should be done quietly, and the voice shouldn’t be heard.” The Mishnah Berurah (s.k. 5) writes: “Some write that we should be concerned about the Zohar that even lechatchilah the words shouldn’t be audible to the ears, however, the Magen Avraham writes there is no proof from the Zohar. The Gaon writes that the opinion of the Zohar is like the Shulchan Aruch. Other Achronim also write, that it is lechatchilah that the words should be audible to the ears. Bedieved, everyone agrees, if one said the words quietly, and they can’t even be heard by one’s own ears, he fulfils his obligation, as in the end of the day, he said the words.”
In Da’as Noteh (Vol. 1, Inyonei Krias Shema, Teshuvah 36, pg. 202) R’ Chaim was asked about the status of the din of השמיע לאזניו when in a noisy place and he answered, that reciting krias shema and berachos in such a place is ok, and the words of the Sifsei Chachomim are tzorich iyun [need explaining].”
Numerous Other Explanations for Why Moshe Rabbeinu “Screamed”
We mentioned the Sifsei Chachomim who learns that Moshe Rabbeinu “screamed” so that he could hear himself daven, however, the meforshim (besides for the Mabit we mentioned above) bring many other reasons for why he “screamed” and according to all these reasons we have no proof that one can’t daven normally in a place where there is loud music.
The Seforno explains: שיסיר אותם הצפרדעים בלבד אשר שם לפרעה וישארו ביאור בזה הוצרך לתפילה צעקה דפלגא מן שמיא לא יהבי – “(Moshe davened) that only the frogs that were affecting Pharoah should be removed, however, the frogs in the river should remain. For this Moshe needed to ‘scream’ (special prayer), as normally in Shomayim they don’t answer half things.” Since Moshe wanted something out of the ordinary, he only wanted half the frogs to leave, whilst the other half should remain in the river, therefore, he needed a special type of tefillah. From the fact that the Seforno needed to come on to this explanation, we see that he doesn’t learn like the Sifsei Chachomim, and he holds that Moshe didn’t need to shout for the din of השמיע לאזניו.
We can refute the above, as who says there is a din of השמיע לאזניו by all tefillos and requests that one davens to Hashem. Perhaps only by krias shema and its berachos and where we find this din explicitly is there such a din, however, by an ordinary tefillah who says there is such a din. Therefore, besides for this being a strong question on the Sifsei Chachomim, we don’t have a proof from the Seforno to the contrary, as perhaps it’s true that by krias shema there is a din of השמיע לאזניו and if there is loud music it’s a problem, however, here the reason Moshe “screamed” was not because of this din, but because he was davening for half a matter, therefore, he needed to daven an extra powerful tefillah.
