10 Questions to Audit Your Hearing Conservation Program (OSHA 1910.95)

OSHA 29 CFR 1910.95 sets the floor for hearing conservation — but being technically compliant does not mean your program is actually working. These 10 diagnostic questions help EHS managers and safety directors identify gaps before an OSHA inspection finds them first.

Soundtrace provides in-house audiometric testing, real-time noise monitoring, fit testing, and automated recordkeeping — built for facilities that want to move from checkbox compliance to a genuinely effective hearing conservation program.

1. Are all at-risk employees enrolled?

OSHA 1910.95(c) requires hearing conservation program enrollment for any employee whose 8-hour TWA noise exposure equals or exceeds 85 dBA. Many facilities undercount because they only enroll employees in historically loud areas and skip workers in adjacent spaces, maintenance roles, or relief positions who may also exceed the action level.

Ask yourself: Has every job category been noise-monitored? Are contract workers and temporary employees covered? When was the last time your enrolled employee list was compared against your current headcount?

▶ Bottom line: Enrollment gaps are a top OSHA citation driver. If a worker can demonstrate noise exposure above 85 dBA and was not enrolled, the employer is liable regardless of whether the worker ever suffered hearing loss.

2. Is noise monitoring current and documented?

OSHA 1910.95(d) requires noise monitoring whenever there is reason to believe employee exposure may equal or exceed 85 dBA. Monitoring must be repeated whenever a change in production, process, equipment, or controls may have affected exposures. Many facilities have a monitoring study from 2015 or earlier and have not re-surveyed since equipment was added or process speeds changed.

Ask yourself: When was your last noise survey? Have any machines been added, modified, or relocated since then? Is monitoring data stored in a retrievable format with calibration records attached?

▶ Bottom line: Outdated monitoring data exposes you on two fronts — you may be missing employees who should be enrolled, and you cannot defend your current controls without current data.

3. Are baseline audiograms completed on time?

OSHA 1910.95(g)(5)(i) requires a baseline audiogram within 6 months of first noise exposure at or above the action level — or within 1 year if a mobile van program is used. New hires in noisy jobs frequently fall through the cracks when onboarding is rushed or mobile van scheduling is delayed.

Ask yourself: Is baseline testing built into your onboarding workflow? Do you have a report showing every enrolled employee's baseline completion date relative to their hire date? Are any employees past the 6-month window without a baseline?

▶ Bottom line: A missing baseline audiogram makes STS determination impossible and eliminates your ability to defend against a workers’ compensation hearing loss claim, since there is no pre-employment reference point.

4. Are annual audiograms being completed?

OSHA 1910.95(g)(6) requires annual audiograms for all enrolled employees. Participation rates below 100% are common with mobile van programs — employees on different shifts, on leave, or absent on van day simply do not get tested, and re-scheduling through clinics is often slow and inconsistent.

Ask yourself: What percentage of enrolled employees completed their annual audiogram last cycle? How are missed employees tracked and rescheduled? Is anyone past their 12-month anniversary without a completed annual?

▶ Bottom line: High annual audiogram participation is the leading indicator of program effectiveness. Low participation means you have employees accumulating hearing damage without detection.

5. Are STS cases being followed up correctly?

When a Standard Threshold Shift is identified — a 10 dB or greater average shift at 2,000, 3,000, and 4,000 Hz compared to baseline — OSHA 1910.95(g)(8) requires the employer to fit or refit the employee with hearing protection, require the employee to use it, and refer the employee for further evaluation if the STS is not an age-corrected artifact. Many facilities detect STS but do not document follow-up actions or re-evaluate whether current controls are adequate.

Ask yourself: Does your system automatically flag STS events? Is there a documented workflow for follow-up? Are re-tests being completed within 30 days per OSHA guidance? Are STS trends being tracked across your workforce?

▶ Bottom line: Unaddressed STS cases are both a compliance failure and a leading indicator of future workers’ compensation claims. Documented follow-up is your primary defense.

6. Is hearing protection matched to actual noise levels?

Providing earplugs is not the same as ensuring adequate protection. OSHA 1910.95(i) requires that hearing protectors attenuate noise to at least 90 dBA (or 85 dBA for employees who have already experienced an STS). Derating NRR values by 50% for earplugs and 25% for earmuffs (per NIOSH recommendations) often reveals that standard foam earplugs are insufficient in environments above 100 dBA.

Ask yourself: Have you derated NRR values against your actual noise levels for each work area? Are employees in the highest-noise areas using double hearing protection where required? Is fit testing being conducted to verify real-world attenuation?

▶ Bottom line: Issuing hearing protection without verifying it provides adequate attenuation for specific noise exposures is a compliance gap that will not hold up under OSHA scrutiny or in litigation.

7. Is training annual and documented?

OSHA 1910.95(k) requires annual training for all employees enrolled in the hearing conservation program. Training must cover the effects of noise on hearing, the purpose and use of hearing protection, and the purpose and procedures for audiometric testing. Training records must be retained.

Ask yourself: When did each enrolled employee last complete training? Is training being delivered consistently across shifts and locations? Are completion records stored in a retrievable format with dates and employee signatures?

▶ Bottom line: Training recordkeeping failures are among the most common OSHA hearing conservation citations because they are easy to detect during an inspection and hard to remedy retroactively.

8. Are engineering controls being actively pursued?

OSHA’s general duty clause and the hierarchy of controls require employers to implement engineering and administrative controls to reduce noise exposure before relying on hearing protection. OSHA will cite facilities that default to hearing protection without documenting that feasible engineering controls have been evaluated and either implemented or ruled out with justification.

Ask yourself: Is there a written record of engineering control evaluations for high-noise equipment? Have administrative controls like job rotation been implemented and documented? Is hearing protection being treated as a supplement to, rather than a substitute for, noise reduction?

▶ Bottom line: Hearing protection is the last line of defense, not the primary control. Facilities with no documented engineering control evaluation are vulnerable to OSHA general duty clause citations.

9. Is your audiometric equipment calibrated?

OSHA 1910.95(h) requires annual exhaustive calibration of audiometers and acoustic calibration checks before each day of use. Calibration records must be maintained. Audiometric test results from an out-of-calibration audiometer are invalid and may require re-testing of your entire enrolled workforce.

Ask yourself: When was your audiometer last exhaustively calibrated? Are daily calibration checks being performed and logged? If you are using a platform like Soundtrace, are calibration swap-outs being tracked?

▶ Bottom line: Equipment calibration failures invalidate test results and can require re-testing hundreds of employees. This is one of the lowest-cost compliance items to maintain and one of the most operationally costly to fail.

10. Can you produce records during an OSHA inspection?

OSHA 1910.95(m) requires employers to retain noise exposure records for 2 years, audiometric test records for the duration of employment, and make records available to employees and OSHA upon request. Many facilities have audiogram data scattered across paper files, clinic records, and spreadsheets that cannot be retrieved within the timeframe an OSHA inspector expects.

Ask yourself: Can you pull up a specific employee’s complete audiometric history in under 5 minutes? Are noise monitoring records and calibration logs centralized and dated? If your safety director left tomorrow, would someone else be able to find everything?

▶ Bottom line: Recordkeeping accessibility is what turns a good program into a defensible program. Centralized digital records with audit trails are the standard OSHA expects to see.

Frequently asked questions