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OSHA 29 CFR 1910.95 governs audiometric testing in general industry — it is federal law with civil penalties up to $16,550 per serious violation in 2025. This guide breaks down every compliance requirement your hearing conservation program must meet, from baseline audiogram timing to recordkeeping retention periods.
Soundtrace delivers OSHA 1910.95-compliant audiometric testing in-house, eliminating the scheduling gaps and documentation failures that trigger citations.
85 dB(A) TWA = hearing conservation program required. 90 dB(A) TWA = permissible exposure limit. Workers at or above the action level must be enrolled in the HCP and offered hearing protection.
OSHA’s noise standard applies to all general industry employers where workers are exposed to noise at or above an 8-hour TWA of 85 dB(A) — the action level. This threshold triggers the full hearing conservation program requirements under 1910.95(c). Under 1910.95(b)(1), employers must first use feasible engineering and administrative controls. Hearing protection devices are a supplement to those controls, not a substitute.
▶ Bottom line: If any worker’s 8-hour TWA reaches or exceeds 85 dB(A), a full hearing conservation program is legally required. The standard does not allow substituting HPDs for controls that are technically and economically feasible.
Section 1910.95(g) specifies four audiogram types, each with distinct timing rules:
| Audiogram Type | When Required | Key Requirement |
|---|---|---|
| Baseline | Within 6 months of first 85+ dB(A) exposure | 14 hours free of workplace noise before test; HPDs don’t satisfy this |
| Mobile van exception | Within 1 year if van is used | HPDs must be worn during the interim period |
| Annual | Every 12 months thereafter | Compared to baseline to detect STS |
| Revised baseline | When STS is confirmed permanent | Replaces original baseline; written justification required |
The 14-hour quiet period before baseline testing is frequently mishandled. Workers must have 14 hours free of workplace noise — wearing HPDs during that period does not satisfy the requirement under 1910.95(g)(5)(ii).
Schedule baseline audiograms for first thing Monday morning after a weekend. Document the quiet period in writing for each employee — this is the first thing an OSHA inspector will request.
▶ Bottom line: Invalidating baseline data by skipping the 14-hour quiet period is one of the most common audiometric testing citations — and one of the most preventable with proper scheduling.
Testing must be administered by one of the following:
Remote availability via teleaudiology satisfies the supervision requirement, but the supervisory relationship must be documented on each test day.
▶ Bottom line: A supervising audiologist or physician must be documented and available for consultation on every test day. Without that documentation, results may be uncertifiable in an enforcement proceeding.
Audiometers must meet ANSI S3.6 specifications and undergo calibration at three levels:
| Calibration Type | Frequency | Standard |
|---|---|---|
| Acoustic (biological) check | Each test day | Using a known listener; results documented |
| Exhaustive calibration | Annually | ANSI S3.6; certified by qualified technician |
| Electroacoustic calibration | When acoustic check fails | Full ANSI S3.6 required before further testing |
Test environment background noise must not exceed ANSI S3.1 permissible ambient noise levels. Testing in an environment that is too loud produces falsely normal results — which is actually worse for the employer than a failed test because it masks genuine hearing loss.
▶ Bottom line: Failing to document the daily biological calibration check is a recordkeeping violation under 1910.95(h)(4) even if the audiometer was functioning perfectly.
An STS under 1910.95(g)(10) is an average change of 10 dB or more at 2000, 3000, and 4000 Hz in either ear compared to baseline. Age correction using Appendix F tables is permitted. When an STS is identified, the employer must:
Under 29 CFR 1904.10, a work-related STS resulting in a threshold of 25 dB HL or worse (age-corrected) must be recorded on the OSHA 300 Log as a hearing loss recordable.
▶ Bottom line: The 21-day notification window begins when the STS is determined, not when the audiogram was administered. Delays in professional review create a separate citation risk for late notification.
| Record Type | Retention Period | Required Contents |
|---|---|---|
| Noise exposure measurements | 2 years | Date, area, noise levels, equipment used, technician name |
| Audiometric test records | Duration of employment | Worker name/ID, all audiograms, calibration records, audiologist name |
| OSHA 300 Log (hearing entries) | 5 years | Per 1904.33 requirements |
▶ Bottom line: Audiometric records must be retained for the full duration of each worker’s employment. A worker hired at 22 may require records maintained for 40+ years.
Annual training must be provided to every enrolled employee and must cover:
▶ Bottom line: “Annual” means within 12 calendar months of each employee’s last training date — a single cohort schedule can create gaps for workers whose dates drift.
| Inspection Area | Common Deficiency | Citation Risk |
|---|---|---|
| Noise monitoring records | No monitoring conducted; surveys not updated after process changes | Serious |
| Baseline audiogram timing | Conducted outside 6-month window; quiet period undocumented | Serious |
| Audiometer calibration logs | Missing daily biological checks; annual calibration lapsed | Serious |
| STS notifications | Workers not notified within 21 days; no written notification on file | Serious |
| HPD documentation | No attenuation calculation; wrong NRR for noise level | Serious |
| Training records | No sign-in sheets; topics missing 1910.95(k) elements | Other-Than-Serious |
▶ Bottom line: OSHA inspectors cross-reference audiometric records against noise monitoring data. High-noise areas without corresponding audiometric records produce a Serious citation under 1910.95(g)(1).
Soundtrace delivers OSHA 1910.95-compliant in-house audiometric testing with built-in documentation, automatic STS alerts, and audiologist oversight.
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