DoD installations employ both military personnel and civilian workers, often in the same noise-hazardous environments. The two populations are governed by different frameworks, with different program elements for each. This guide maps the key differences so HCP administrators can run one installation HCP that correctly addresses both populations.
Military personnel: DoDI 6055.12 only — OSHA does not apply. DoD civilians: OSHA 1910.95 + DoDI 6055.12 — both apply; where DoDI is more stringent, DoDI controls.
Governing Frameworks: Military vs. Civilian
| Framework | Military Service Members | DoD Civilian Employees |
|---|---|---|
| OSH Act of 1970 | Exempt — military not covered by OSH Act | Covered via 29 CFR Part 1960 |
| OSHA 29 CFR 1910.95 | Not applicable | Required — 1960.16 makes it binding |
| DoDI 6055.12 | Required — primary governing document | Required — applies at DoD worksites |
| 29 CFR 1904 (Recordkeeping) | Exempt — military 300 Log exemption | Required — work-related civilian hearing loss must be recorded |
HCP Element-by-Element Comparison
| HCP Element | Military (DoDI 6055.12) | DoD Civilian (1910.95 + DoDI 6055.12) |
|---|---|---|
| Enrollment trigger | 85 dBA TWA; all personnel in designated hazardous noise areas | 85 dBA TWA action level per 1910.95(d) |
| Baseline timing | Before assignment to noise-hazardous duty (more stringent than OSHA) | Within 6 months of first exposure per 1910.95(g)(2) |
| Annual audiogram | Annual per DoDI 6055.12 | Annual per 1910.95(g)(6) |
| STS notification | 21 days; notification to unit commander and member | 21 days per 1910.95(g)(8)(ii); no commander notification |
| PAR fit testing | Required for >95 dBA TWA (Change 1, Nov 2023) | Required for >95 dBA TWA (Change 1, Nov 2023) |
| Record retention | Military health record — career-long and post-separation | Duration of employment per 1910.95(m) |
H-Profiles: Military Only
Military service members are assigned H1 (within standards), H2 (monitored loss), or H3 (potentially restricting loss) hearing readiness profiles. Civilian employees receive no equivalent classification. When a civilian’s audiogram shows an STS, the consequences follow OSHA: 21-day notification, possible retest, 300 Log assessment. No readiness profile, no commander notification, no MOS review.
Deployment Audiograms: Military Only
Pre- and post-deployment audiograms are required for military service members under DoDI 6490.03. DoD civilian employees follow the standard annual testing cycle regardless of deployment status — this requirement applies only to military.
Recordkeeping Differences
| Element | Military | DoD Civilian |
|---|---|---|
| Primary records system | DOEHRS-HC (MTF sites); career-long | DOEHRS-HC (MTF) or external platform (non-MTF) |
| OSHA 300 Log | Exempt | Required — work-related loss meeting 1904.10 criteria must be recorded |
| Retention | Military health record; accessible post-separation for VA claims | Duration of employment; Federal Records Center at separation |
When audiometric results show a shift, the first question must be: military or civilian? Military: no 300 Log entry. Civilian: evaluate for 1904.10 recordability. If work-related and post-shift average exceeds 25 dB HL, record it.
Who Administers Each Population’s HCP
Military: Installation Hearing Readiness Officer (HRO) and MTF audiometry clinic using DOEHRS-HC. Unit commanders receive STS notifications and readiness profile changes.
DoD civilians: Installation safety office or civilian occupational health program. Testing may occur at MTF via DOEHRS-HC or at the worksite using an external platform. Professional supervisor reviews civilian audiograms; no commander notification chain.
Practical Management at Mixed Worksites
- Maintain separate program documentation for military and civilian populations
- Track noise monitoring across both — update enrollment lists when surveys identify newly hazardous areas
- Know which audiometric system covers which worker — ensure civilian records are accessible for 300 Log assessment
- Don’t apply military STS follow-up to civilian shifts — commander notification and H-profile changes are not civilian workflows
- Track PAR fit testing completion separately for military and civilian populations above 95 dBA TWA
Frequently Asked Questions
Yes. DoD civilian employees are covered by OSHA 1910.95 through 29 CFR Part 1960, and also by DoDI 6055.12. Military service members are exempt from OSHA entirely.
H-profiles (H1, H2, H3) are military readiness classifications based on audiometric results. DoD civilian employees receive no H-profile. Their STS results trigger OSHA follow-up and 300 Log assessment, not readiness classification.
Yes. When a DoD civilian has a work-related STS meeting 29 CFR 1904.10 criteria (post-shift average exceeding 25 dB HL), the installation must record it on the OSHA 300 Log. Military shifts are never recorded on the 300 Log.
Civilian HCP Support at DoD Installations
Soundtrace supports DoD civilian safety managers with automated audiometric testing, licensed audiologist review, and documentation satisfying both OSHA 1910.95 and DoDI 6055.12.
Request a Federal Program Assessment- Federal Government & DoD Hearing Conservation: The Complete Compliance Guide
- DoDI 6055.12: Complete Guide for DoD Civilian Safety Managers
- DOEHRS-HC Explained: DoD’s Audiometric Data System
- The 2023 DoDI 6055.12 Update: Mandatory Fit Testing
- OSHA Hearing Conservation Program: The Complete Guide
- Workers’ Compensation for Occupational Hearing Loss: 50-State Guide