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Metal Fabrication: Hearing Conservation Program Guide

Matt Reinhold, COO & Co-Founder at SoundtraceMatt ReinholdCOO & Co-Founder11 min readApril 8, 2026
Industry Guide·Metal Fabrication·11 min read·Updated April 2026

Fabricated metal manufacturing (NAICS 332) includes stamping, forging, screw machining, and structural metal fabrication — all sectors with significant noise exposure from impact and grinding operations. Mechanical stamping presses are among the loudest sustained noise sources in any industry, OSHA 29 CFR 1910.95 applies to metal fabrication operations as general industry. According to CDC/NIOSH, approximately 22 million U.S. workers are exposed to hazardous occupational noise annually.

Soundtrace delivers in-house audiometric testing and noise monitoring for metal fabrication operations — ANSI S3.1-compliant, automated STS detection, and licensed audiologist review.

Noise Sources and TWA Ranges: Metal Fabrication

Equipment / ProcessTypical LevelTypical 8-hr TWAOSHA Status
Mechanical stamping press (impact)100–120 dBA95–110 dBAFar exceeds PEL — among loudest in manufacturing
Punch press / turret punch95–115 dBA92–108 dBASignificantly exceeds PEL
Shear / notcher / brake press90–105 dBA88–98 dBAAt or above PEL
Plasma / laser cutting85–100 dBA85–95 dBAAt or above action level
Welding (MIG/TIG)82–95 dBA82–92 dBAAt or above action level
Grinding / deburring90–105 dBA88–98 dBAAt or above PEL
Powder coating / painting78–88 dBA78–86 dBAMonitor; exhaust fans vary

Industry-Specific Compliance Considerations

Fabricated metal manufacturing (NAICS 332) includes stamping, forging, screw machining, and structural metal fabrication — all sectors with significant noise exposure from impact and grinding operations. Mechanical stamping presses are among the loudest sustained noise sources in any industry, with peak levels reaching 120+ dBA during impact. Workers in stamping shops develop occupational NIHL rapidly, and the WC liability for stamping employers is substantial. Job shops and contract manufacturers in this sector often lack formal HCPs because they don't perceive themselves as 'manufacturing plants' in the traditional sense — but OSHA 1910.95 applies regardless of company size or business model.

OSHA 1910.95 Requirements

All metal fabrication workers at or above the 85 dBA action level require the full six-element OSHA 1910.95 hearing conservation program. Workers above the 90 dBA PEL require documented engineering controls assessment. The most common citation patterns across metal fabrication match the broader manufacturing pattern: late baseline audiograms, annual audiogram schedule failures, and inadequate HPD for PEL-exceeding exposures. See: most common OSHA hearing conservation citations.

Violation TypeCitation FrequencyTypical Penalty (2026)
Late or missing baseline audiogramsVery high$2,000–$7,000 per instance
Annual audiogram schedule failuresHigh$2,000–$7,000 per instance
No noise monitoring (assumed below AL)High$1,000–$5,000
No engineering controls assessment above PELModerate$3,000–$9,000

Workers’ Compensation Defense

Metal fabrication workers, particularly those in stamping operations, develop occupational hearing loss at high rates from impact noise. Small and mid-size job shops often have no audiometric records from early years of operation, making apportionment defense against WC claims from long-tenure workers very difficult.

⚠ 30-year record retention

Occupational hearing loss claims arrive decades after exposure begins. Records held by mobile van vendors cannot be guaranteed beyond the active vendor relationship. Cloud-based retention with employer-controlled access is the only reliable long-term solution. See: workers’ compensation for occupational hearing loss.

In-house audiometric testing for metal fabrication operations

Soundtrace delivers OSHA-compliant audiometric testing and noise monitoring for metal fabrication employers — automated STS detection, 30-year cloud retention, and licensed audiologist supervision.

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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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