Why Ignoring Noise Levels Under 85 dBA TWA May Be Your Biggest Risk

Under 85 dBA TWA: The Most Misunderstood Hearing Risk

What is the OSHA Action Level for Noise?

OSHA requires employers to implement a hearing conservation program when employee exposure equals or exceeds 85 dBA TWA over 8 hours (29 CFR 1910.95). This is the legal action level.

But here’s the problem: millions of U.S. workers are regularly exposed to noise between 75–84 dBA TWA, and those exposures still cause hearing loss over time. According to the CDC, about 22 million U.S. workers are exposed to hazardous noise each year, and a significant portion of them fall below OSHA’s 85 dBA threshold (CDC NIOSH).

The Question Safety Leaders Keep Asking

“If my employees are exposed to noise levels under 85 dBA TWA, do I need a hearing conservation program?”

Many companies interpret OSHA’s rule to mean: “If we are under 85, we don’t need to worry.”

That is a dangerous assumption.

The NIOSH Recommended Exposure Limit (REL) is 85 dBA, but even NIOSH acknowledges this level will not prevent all hearing loss. The World Health Organization warns that prolonged exposure above 70 dBA can lead to measurable damage. The EPA sets 75 dBA as the environmental threshold to protect against hearing impairment.

In short: your employees are not “safe” just because they are under OSHA’s line.

Why Ignoring Sub-85 Exposures Is a Bigger Long-Term Risk

Companies that avoid hearing conservation programs for sub-85 exposures may believe they are saving money and avoiding compliance burdens. But the risks stack up quickly:

1. Hidden OSHA Recordables
   Hearing loss is still recordable if a Standard Threshold Shift (STS) occurs, even if exposures were under 85 TWA. Without baseline audiograms, you have no defensible evidence that the shift was work-related or pre-existing.
2. Workers’ Compensation Liability
   States often recognize occupational hearing loss claims regardless of whether the employer’s program met OSHA’s minimum requirements. Ignoring moderate exposures is an open invitation for claims years down the road.
3. Scientific Consensus
   WHO, NIOSH, and EPA all acknowledge risks below 85 dBA. Courts and employees are increasingly aware of these standards, which raises the bar for what is considered “reasonable employer action.”
4. Reputation and Retention
   Hearing loss is permanent. Workers who discover their employer chose to “do nothing” because OSHA didn’t force them will not stick around.

The Proactive Path: Data, Separation, and Protection

The smartest safety leaders take a proactive stance, even if their exposures average below 85 TWA. The playbook looks like this:

• Conduct Baseline Audiograms: Establish a reference point for every employee. Without this, you have no way to defend against future claims.
• Offer Annual Audiograms: Early detection prevents small shifts from becoming permanent recordables. It also shows employees you take their health seriously.
• Run Noise Surveys Regularly: Document exposures and use the data to separate employees into groups—low, moderate, and high risk—rather than treating everyone the same.
• Demonstrate Due Diligence: Even if you decide not to implement a formal OSHA program, you can show auditors, insurers, and courts that you acted responsibly with objective data.

Soundtrace’s Protected Exposure Program

This is where Soundtrace changes the equation. Our Protected Exposure Program gives companies a strategic way to safeguard employees without automatically triggering the full burden of an OSHA hearing conservation program.

• Baseline and Annual Audiograms for All Employees
  Every worker has a defensible record, regardless of exposure level.
• Exposure-Based Separation
  Employees are grouped according to actual noise levels. High-risk groups can be escalated into a full HCP, while moderate and low groups remain monitored without unnecessary cost.
• Noise Surveys to Justify Decisions
  Documented exposure data supports the choice to maintain voluntary protection for certain groups instead of a mandated HCP.
• Reduced Long-Term Liability
  By addressing the risk early, employers prevent OSHA recordables, minimize workers’ comp claims, and strengthen trust with their workforce.

Bottom Line

The real risk is not overprotecting employees under 85 dBA TWA. The real risk is ignoring them.

Hearing conservation is not just a regulatory checkbox. It is a long-term liability shield, a worker trust builder, and a smart financial strategy. Companies that take action now, using tools like Soundtrace’s Protected Exposure Program, are the ones that will avoid tomorrow’s claims, recordables, and reputational damage.

OSHA sets the floor. Leaders raise the standard.

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FAQ: OSHA Hearing Conservation and Sub-85 dBA Exposures

What is OSHA’s required action level for hearing conservation?

OSHA requires employers to implement a hearing conservation program when employee exposure equals or exceeds 85 dBA TWA over an 8-hour day (29 CFR 1910.95). At this level, companies must provide baseline and annual audiograms, training, and hearing protection. This is the legal minimum standard, but many experts note it does not fully prevent hearing loss in all workers.

Do I need a hearing conservation program if exposures are under 85 dBA?

No, OSHA does not mandate a hearing conservation program below 85 dBA TWA. However, organizations like NIOSH, WHO, and EPA recognize that noise in the 70–84 dBA range can still cause hearing loss over time. Many employers choose voluntary programs that include baseline and annual audiograms to protect employees and reduce long-term liability, even without a regulatory requirement.

Can hearing loss still be OSHA-recordable below 85 dBA?

Yes. If an employee experiences a Standard Threshold Shift (STS), it can be OSHA-recordable even if their exposures were below 85 dBA. Without baseline audiograms, employers cannot prove whether the loss was work-related or pre-existing. This makes untreated sub-85 dBA exposures a hidden liability, potentially leading to recordables and workers’ compensation claims years after the exposure occurs.

What are the risks of ignoring employees exposed between 75–84 dBA?

Employees in this “gray zone” face real risk. Long-term exposure at 75–84 dBA can cause permanent hearing loss, which is both recordable and compensable. Employers who ignore these groups may face increased workers’ comp claims, lawsuits, and employee distrust. Proactive steps like baseline audiograms and noise surveys help mitigate liability while showing employees their health is valued beyond compliance.

How do NIOSH and WHO guidelines differ from OSHA’s 85 dBA rule?

While OSHA sets its action level at 85 dBA, NIOSH also recommends 85 dBA as a limit but admits it does not protect all workers. WHO identifies 70 dBA as the threshold for long-term risk. The EPA sets 75 dBA as a protective benchmark. These stricter global standards highlight that OSHA’s rule is a floor, not a guarantee of safety.

Why does the EPA recommend 75 dBA instead of 85 dBA?

The EPA determined that an average daily exposure of 75 dBA over 8 hours protects nearly all individuals from hearing impairment. This is more conservative than OSHA’s 85 dBA rule, which balances health protection with regulatory enforcement. The EPA’s standard reflects scientific consensus that noise levels below 85 dBA can still damage hearing over time if left unmanaged.

What is a Standard Threshold Shift (STS) in hearing?

A Standard Threshold Shift (STS) is defined by OSHA as a change in hearing threshold of 10 dB or more in either ear, averaged at 2000, 3000, and 4000 Hz. An STS is significant because it can trigger an OSHA recordable injury. Employers can detect STS early through baseline and annual audiograms, helping them intervene before the loss becomes permanent.

How can baseline audiograms help prevent liability for employers?

Baseline audiograms establish an employee’s hearing level when they first join the workforce or program. Without them, employers cannot distinguish between work-related and pre-existing hearing loss. This gap exposes companies to OSHA recordables and compensation claims. Establishing baselines, even below 85 dBA, provides defensible evidence and allows early detection of small shifts before they become costly liabilities.

Can companies protect workers without triggering a full OSHA hearing program?

Yes. Employers can run voluntary protection programs that include baseline and annual audiograms, noise surveys, and exposure-based separation. These programs demonstrate due diligence and protect employees without automatically triggering all the OSHA requirements tied to 85 dBA. This proactive approach reduces long-term liability while avoiding unnecessary cost and compliance burden when exposures remain below the formal action level.

What is Soundtrace’s Protected Exposure Program and how does it work?

The Soundtrace Protected Exposure Program allows companies to safeguard employees exposed to 75–84 dBA TWA without automatically triggering a full OSHA hearing conservation program. It provides baseline and annual audiograms for all employees, noise surveys, and separation of workers into low, moderate, and high-risk groups. This ensures protection, defensible documentation, and reduced liability, while focusing resources where they matter most.

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