Share article
OSHA's audiometric testing frequency requirements are precise, employee-specific, and non-negotiable -- yet lapsed testing cycles are among the most common 1910.95 violations found during inspections. This guide explains exactly when baseline and annual audiograms are required, what the countdown clocks look like per employee, and how to manage testing schedules for a workforce of any size.
Soundtrace tracks individual audiometric testing due dates for every enrolled employee and alerts program administrators before deadlines lapse -- eliminating the calendar-management burden that causes most testing cycle violations.
Under OSHA 1910.95, the baseline audiogram must be completed within 6 months of first noise exposure at or above 85 dBA TWA. Annual audiograms must follow at least every 12 months thereafter. These clocks run per employee -- not per facility or per year.
A baseline audiogram must be completed within 6 months of the employee's first occupational noise exposure at or above the action level (85 dBA TWA). This window begins on the date the employee first performs noise-exposed work -- which for a new hire in a high-noise role is typically the first day in that position.
If the employer uses mobile testing as its primary audiometric testing method, OSHA extends the baseline window to 12 months. However, hearing protection must be worn for the entire extended period until the baseline is complete.
The 14-hour quiet period requirement for baseline testing does not extend the 6-month deadline -- it is a condition of how the test must be administered, not a reason to delay beyond 6 months.
▶ Bottom line: The baseline clock starts on the employee's first day of noise-exposed work. Six months is the hard deadline; 12 months only if mobile testing is used and HPDs are worn throughout the extended window.
After the baseline, OSHA requires at least one audiogram per 12-month period for each enrolled employee. The 12-month cycle runs from the baseline date for the first annual, and from each annual date thereafter. This is an individual clock per employee -- not a facility-wide calendar event.
Example timeline for one employee:
| Event | Date | Notes |
|---|---|---|
| First noise-exposed shift | January 15 | 6-month baseline clock starts |
| Baseline audiogram | June 1 | Within 6-month window |
| First annual audiogram due by | June 1 (following year) | 12 months after baseline |
| Second annual due by | June 1 (year after) | 12 months after first annual |
▶ Bottom line: The 12-month cycle is per employee, not per calendar year. An employee tested in June must be retested by the following June -- regardless of whether the facility runs an annual testing event in February.
Several situations create complexity in testing frequency management:
For facilities with dozens or hundreds of noise-exposed employees, individual testing clocks become operationally complex quickly. The three common approaches:
If a facility uses an annual mobile van visit in February, an employee hired in October will have their baseline in April and their first annual due in April of the following year -- two months after the van's February visit. That employee will miss their annual cycle unless the employer supplements with an additional testing method. This is a systematic gap in many mobile-van-dependent programs.
▶ Bottom line: Annual event-based testing is the most common cause of individual testing cycle lapses. In-house or continuous testing is the only reliable method for maintaining every employee's individual 12-month clock.
A lapsed audiometric testing cycle is a direct violation of 1910.95(g). In an OSHA inspection, the compliance officer will typically request audiometric records for all enrolled employees and verify that each has a current annual audiogram within the past 12 months. Employees whose records show a gap of more than 12 months since their last test generate individual citations.
Beyond the compliance risk, lapsed testing means any hearing threshold change that occurred during the gap goes undetected -- and the employer loses the ability to intervene in time to prevent further loss.
Yes. OSHA sets the minimum frequency at once every 12 months. Employers may test more frequently -- semi-annually or quarterly -- particularly for employees in very high noise environments or those who have previously experienced an STS. More frequent testing catches shifts earlier.
Missing the 12-month window is a violation of 1910.95. If testing is disrupted (facility closure, vendor issues, etc.), document the circumstances and complete testing as soon as possible. OSHA considers good-faith efforts in enforcement, but does not waive the requirement.
Yes. The requirement applies based on noise exposure level, not hours worked or employment classification. A part-time employee exposed at or above 85 dBA TWA during their shifts is subject to the same audiometric testing requirements as full-time employees.
If an employee's noise exposure during remote work reaches 85 dBA TWA, the employer's obligation technically extends to that exposure. In practice, most remote work environments do not approach this level. For workers who split time between office and high-noise environments, monitoring of their actual noise exposure determines whether they are covered.
Yes. Off-site clinic testing is OSHA-compliant provided the equipment, environment, and tester meet 1910.95 requirements. The disadvantage is significant employee time loss due to travel and wait times -- typically 1-2 hours per visit compared to under 10 minutes for in-house automated testing.
Soundtrace tracks every employee's individual testing clock, sends automated reminders before deadlines lapse, and enables on-demand in-house testing so your 12-month cycles stay intact year-round.
Get a Free Quote See how Soundtrace manages testing schedules