HomeBlogAchieve Workplace Safety: OSHA Compliance with Audiometric Testing
audiometry

Achieve Workplace Safety: OSHA Compliance with Audiometric Testing

Ramsay Curry, Director of Client Success at SoundtraceRamsay CurryDirector of Client Success9 min readJanuary 1, 2025
Compliance Guide·9 min read·Updated 2025

OSHA 1910.95 is the federal standard governing workplace noise and hearing conservation for general industry. Compliance is not a single action — it is an ongoing program with seven interdependent elements, each independently citable. This guide explains exactly what compliance requires and how it is achieved in practice.

Soundtrace is designed to deliver OSHA 1910.95 compliance for industrial facilities — integrating every required program element into a single platform.

Who OSHA 1910.95 Applies To

OSHA 1910.95 applies to any general industry employer where employees are exposed to noise at or above the action level of 85 dB(A) as an 8-hour TWA. There is no size threshold. The standard also applies when noise exposures are uncertain — if there is reason to believe the action level may be reached, OSHA expects monitoring to confirm or rule it out.

▶ Bottom line: Operating without monitoring in a facility with obvious noise sources is itself a citation risk.

Element 1: Noise Monitoring

Under 1910.95(d), employers must institute a monitoring program when there is reason to believe any employee’s noise exposure may equal or exceed the action level. The monitoring must integrate all noise levels from 80–130 dB(A), be repeated when production or equipment changes may alter exposures, and include employee notification and right to observe monitoring under 1910.95(e). Monitoring records must be retained for at least 2 years.

Element 2: Audiometric Testing Program

The audiometric testing requirements under 1910.95(g): baseline audiograms within 6 months of first qualifying exposure (14-hour quiet period required, not satisfied by HPDs); annual audiograms within 12 months of the previous test; results reviewed by a qualified audiologist or physician; STS follow-up actions within 21 days; audiometric records retained for the duration of each employee’s employment.

Most Cited Element

Missed annual audiogram deadlines are consistently among the top OSHA 1910.95 citations. Each missed deadline is a per-employee Serious citation up to $16,550.

Element 3: Hearing Protection Devices

HPDs must be adequate to reduce worker noise exposure to below 90 dB(A) TWA (or 85 dB(A) for workers with confirmed STS). Workers who have experienced an STS must use HPDs. Employers must ensure proper fit through training per 1910.95(i)(5), and verify HPD adequacy using NRR derating or individual fit testing.

Element 4: Annual Training

Under 1910.95(k), employers must provide annual training to every enrolled employee covering all four required topics: noise effects on hearing, HPD types and attenuation, HPD fitting and care, and audiometric testing procedures. Training that covers some but not all topics is noncompliant regardless of duration.

Element 5: Recordkeeping

Record TypeRetention Period
Noise exposure measurement records2 years
Audiometric test records (all audiograms)Duration of employment
Audiometric calibration records2 years
OSHA 300 Log hearing loss entries5 years

Element 6: Employee Information Access

Under 1910.95(l), employees are entitled to monitoring results, their own audiometric test results, and information about the hearing conservation program. Failure to provide required access is a standalone citation.

What an OSHA Inspection Examines

Inspection FocusWhat They Look ForCitation Risk If Missing
Noise monitoring recordsCurrent survey; updated after process changesSerious
Baseline audiogramsPresent for all enrolled workers; 14-hr quiet period documentedSerious
Annual audiogramsWithin 12 months for all enrolled workersSerious (per worker)
STS recordsDeterminations documented; notifications within 21 daysSerious
Training recordsAnnual; all four topics; within 12 months per employeeOther-Than-Serious to Serious

Frequently Asked Questions

What are the elements of an OSHA-compliant hearing conservation program?
OSHA 1910.95 requires: noise monitoring, audiometric testing (baseline and annual), hearing protection provision and enforcement, HPD training, annual employee education, recordkeeping of all elements, and employee access to program information and records.
What is OSHA’s action level for noise?
85 dB(A) as an 8-hour TWA. Workers at or above this level must be enrolled in the HCP. The permissible exposure limit is 90 dB(A) TWA.

Build a Complete OSHA 1910.95-Compliant Program

Soundtrace integrates every required element of OSHA 1910.95 in a single platform.

Schedule a Demo
Ramsay Curry, Director of Client Success at Soundtrace

Ramsay Curry

Director of Client Success, Soundtrace

Ramsay Curry is the Director of Client Success at Soundtrace, where she works directly with employers to implement and optimize their hearing conservation programs. She brings a client-first perspective to everything from onboarding and training to ongoing program management — making sure teams get real results from their investment in hearing health.

Related Articles

Stay in the loop

Get compliance updates, product news, and practical tips delivered to your inbox.