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Cookie-Bite Audiogram: What It Means for OSHA and Workers' Compensation

Matt Reinhold, COO & Co-Founder at SoundtraceMatt ReinholdCOO & Co-Founder9 min readApril 8, 2026
Audiometric Testing·OSHA Compliance·9 min read·Updated April 2026

Understanding audiogram patterns is essential for EHS managers who review occupational audiometric surveillance results. This guide covers cookie-bite (mid-frequency) hearing loss: what it looks like on an audiogram, what it means clinically, what OSHA 1910.95 obligations it triggers, and the required employer response. Note that audiogram interpretation in the context of OSHA compliance always requires involvement of a licensed Professional Supervisor — a licensed audiologist, otolaryngologist, or other physician. The EHS manager's role is to understand the pattern well enough to act appropriately and ensure timely PS review.

Soundtrace provides audiometric testing supervised by a licensed audiologist who reviews all audiograms, identifies STSs, and makes clinical determinations — ensuring employer compliance with every 1910.95 audiometric obligation.

What Is Cookie-Bite (Mid-Frequency) Hearing Loss?

A cookie-bite audiogram shows hearing loss concentrated in the mid-frequency range (1000–2000 Hz) with relatively better thresholds at low frequencies (500 Hz) and high frequencies (3000–6000 Hz). When plotted on an audiogram, the threshold curve dips in the middle, resembling a bite taken from a cookie. This pattern is uncommon and presents very differently from typical occupational NIHL.

Clinical Significance

Cookie-bite hearing loss significantly impacts speech understanding because the mid-frequencies carry critical speech information. Workers with this pattern typically have substantial communication difficulties disproportionate to their overall hearing threshold level. The pattern is most commonly associated with hereditary sensorineural hearing loss (often bilateral and symmetric), making it one of the audiogram patterns most likely to represent a non-occupational condition in a noise-enrolled worker.

Professional Supervisor role

All clinical interpretations of occupational audiograms — including determinations of audiogram pattern, work-relatedness, and STS confirmation — must be made by the Professional Supervisor (licensed audiologist, otolaryngologist, or other physician) under OSHA 1910.95(g)(3). EHS managers should understand these patterns to recognize when PS review is needed and to act on PS findings promptly, not to replace the PS role.

OSHA 1910.95 Implications

The cookie-bite pattern has direct implications for OSHA STS calculation. The STS is calculated at 2000, 3000, and 4000 Hz. If the mid-frequency notch is centered around 2000 Hz, it may register as an STS on the first audiogram or on a comparison audiogram if the notch deepens. However, establishing work-relatedness for a cookie-bite pattern requires careful audiological analysis because the pattern is strongly associated with hereditary loss rather than occupational NIHL. A Professional Supervisor's work-relatedness determination is particularly important for cookie-bite audiograms in OSHA 300 log recording decisions.

Required Employer Response

1
Professional Supervisor review essential

Cookie-bite patterns are not typical of occupational noise exposure and must be reviewed by the supervising audiologist or physician. The work-relatedness determination will significantly affect OSHA 300 log recording requirements.

2
Document that noise exposure does not explain the pattern

If the work-relatedness determination concludes the pattern is not related to occupational exposure, document this conclusion with clinical rationale in the audiometric record. This documentation is essential if a WC claim is later filed asserting the loss is work-related.

3
Consider hereditary history in counseling

Cookie-bite hearing loss is often hereditary. Workers with this pattern should understand the likely genetic contribution. This is relevant to both clinical counseling and WC defense.

Audiologist-supervised audiometric testing with automatic STS detection

Soundtrace audiometric testing is supervised by a licensed audiologist who reviews every audiogram, identifies all STSs, and makes clinical determinations — ensuring your program meets every 1910.95 requirement.

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Frequently Asked Questions

What does cookie-bite (mid-frequency) hearing loss mean on an OSHA audiogram?

A cookie-bite audiogram shows hearing loss concentrated in the mid-frequency range (1000–2000 Hz) with relatively better thresholds at low frequencies (500 Hz) and high frequencies (3000–6000 Hz). When plotted on an audiogram, the threshold curve dips in the middle, resembling a bite taken from a cookie. This pattern is uncommon and pre

Does cookie-bite (mid-frequency) hearing loss trigger an OSHA Standard Threshold Shift?

The cookie-bite pattern has direct implications for OSHA STS calculation. The STS is calculated at 2000, 3000, and 4000 Hz. If the mid-frequency notch is centered around 2000 Hz, it may register as an STS on the first audiogram or on a comparison audiogram if the notch deepens. However, establishing. The Professional Supervisor must review all audiograms with significant findings to determine STS status and work-relatedness.

Who must review cookie-bite (mid-frequency) hearing loss on an occupational audiogram?

The Professional Supervisor — a licensed audiologist, otolaryngologist, or other physician — must review any audiogram with clinically significant findings. OSHA 1910.95(g)(3) requires PS involvement in all STS determinations and medical referral decisions. EHS managers should not attempt to interpret audiogram patterns independently.

Matt Reinhold, COO & Co-Founder at Soundtrace

Matt Reinhold

COO & Co-Founder, Soundtrace

Matt Reinhold is the COO and Co-Founder of Soundtrace, where he drives strategy and operations to modernize occupational hearing conservation. With deep expertise in workplace safety technology, Matt stays at the forefront of regulatory developments, audiometric testing innovation, and noise exposure management — helping employers build smarter, more compliant hearing conservation programs.

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