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.
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.
Baseline audiogram: the 6-month rule
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. If the employer uses mobile testing as its primary method, OSHA extends the baseline window to 12 months — but hearing protection must be worn for the entire extended period. The 14-hour quiet period requirement 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.
Annual audiogram: the 12-month cycle
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.
| Event | Date (Example) | 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: An employee tested in June must be retested by the following June — regardless of whether the facility runs an annual testing event in February.
Exceptions and edge cases
New employees mid-year each start their own individual 6-month baseline clock from day one. Employees who transfer to high-noise roles start the 6-month baseline clock on the transfer date. Employees who leave and return should have a new baseline considered, particularly after long gaps. Employees who have had an STS continue on the standard 12-month annual cycle but may benefit from more frequent monitoring.
Managing testing schedules for large workforces
Three approaches: (1) Rolling schedule — employees tested near their individual anniversary dates. Minimizes daily disruption but requires ongoing scheduling management. (2) Annual event (mobile van model) — all employees tested in a single period. Simple to administer but creates a fixed window where many employees fall out of their individual 12-month cycles. (3) Continuous in-house testing — employees test on-demand throughout the year. Eliminates scheduling bottlenecks and ensures individual clocks are always met.
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 supplemented with an additional testing method.
▶ 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.
What happens when the cycle lapses
A lapsed audiometric testing cycle is a direct violation of 1910.95(g). OSHA inspectors will request audiometric records for all enrolled employees and verify each has a current annual audiogram within the past 12 months. Employees with 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 during the gap goes undetected.
Frequently Asked Questions
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.
Yes. The requirement applies based on noise exposure level, not hours worked. 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.
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.
Never miss an audiometric testing deadline again
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.
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