Education and Thought Leadership
Education and Thought Leadership
June 19, 2024

Noise Monitoring Recordkeeping: OSHA Requirements Under 1910.95(m)

Share article

Updated March 2026  ·  29 CFR 1910.95(m)(3)  ·  ~10 min read

OSHA 1910.95(m)(3) requires employers to retain noise exposure measurement records for at least 2 years. But the recordkeeping obligation for noise monitoring is broader than just the raw data—it includes the instruments used, calibration documentation, worker notifications, and the linkage between noise exposure and audiometric records. This guide covers every element required and the most common recordkeeping gaps that lead to citations.

Soundtrace automatically links noise monitoring records to employee audiometric files, satisfying the cross-reference requirement of 1910.95(m)(2)(i)(E) without manual documentation.

2 years
Minimum retention period for noise exposure measurement records under 1910.95(m)(3)
1910.95(e)
Section requiring workers to be notified of monitoring results—notification must be documented
1910.95(m)(2)
Section requiring each audiometric record to include the employee’s most recent noise exposure assessment

What Records OSHA Requires for Noise Monitoring

A complete noise monitoring record under 1910.95(m)(3) must include:

📅
Date of Measurement

The date the monitoring was conducted. Required to demonstrate timely monitoring and to support re-monitoring schedules.

🔧
Instrument Information

The make, model, and serial number of the sound level meter or dosimeter used. Demonstrates ANSI S1.4 Type 2 compliance.

Calibration Records

Pre- and post-measurement calibration check results. Without calibration documentation, the measurement data may be challenged.

👤
Worker Identification

Name and job classification of each monitored worker (for dosimetry), or identification of the work area (for area SLM surveys).

📊
Measurement Results

TWA, dose percentage, and LAVG for each monitored worker or zone. Include the exchange rate and criterion level settings used.

📢
Worker Notifications

Documentation that each monitored worker was notified of their results as required by 1910.95(e). May be a signed form or email record.

Retention Periods: 2 Years Is the Floor, Not the Ceiling

The statutory minimum is 2 years per 1910.95(m)(3). However, because each audiometric record must include the employee’s most recent noise exposure assessment, the practical retention requirement is longer. Noise exposure assessments linked to audiograms should be retained for the duration of employment.

Record TypeMinimum RetentionPractical Retention
Noise exposure measurements2 yearsDuration of employment (if linked to audiograms)
Audiometric test recordsDuration of employmentDuration of employment
Calibration recordsNot specifiedBest practice: retain with the measurements they support
Worker notification recordsNot specified separatelyBest practice: retain 2 years minimum

The Audiogram Linkage Requirement: The Most Missed Element

Under 1910.95(m)(2)(i)(E), each audiometric test record must include the employee’s most recent noise exposure assessment. This means there must be an active linkage between the noise monitoring database and the audiometric records system. Whenever an annual audiogram is conducted, the file must include or reference the most current noise exposure measurement for that employee.

⚠ Paper Systems Always Fail This Requirement

In paper-based programs, noise surveys live in a binder in the EHS office and audiograms live in employee health files. The cross-reference between the two is almost never maintained systematically. During an OSHA inspection, an inspector who picks up an audiogram file and finds no noise exposure assessment linked to it has grounds for a recordkeeping citation under 1910.95(m)(2).

Employee Access Rights

Under 1910.95(l), employers must make noise monitoring records available to employees, former employees, and their designated representatives upon request. Workers have the right to observe noise monitoring as it is conducted. Notifications under 1910.95(e) must be provided proactively to all workers whose exposure was monitored, regardless of the result.

The 5 Most Common Noise Monitoring Recordkeeping Mistakes

#MistakeCitation Risk
1No linkage between noise exposure records and audiometric files1910.95(m)(2)(i)(E)
2Missing calibration records for the instruments used in each monitoring session1910.95(h) / 1910.95(m)
3No documentation that workers were notified of their monitoring results1910.95(e)
4Monitoring results retained for only 2 years when audiograms exist for the same employees1910.95(m)(2)
5Area SLM readings filed without worker classification linkage1910.95(m)(3)

Noise monitoring records that satisfy every OSHA requirement automatically

Soundtrace links every monitoring session to employee audiometric records, stores calibration documentation, and produces audit-ready records that include every required element under 1910.95(m).

Book a DemoGet a quote for your facility →

Frequently Asked Questions

How long must noise monitoring records be kept under OSHA?

Under 1910.95(m)(3), noise exposure measurement records must be retained for at least 2 years. However, because audiometric records must include the employee's most recent noise exposure assessment per 1910.95(m)(2)(i)(E), noise monitoring records linked to audiograms should be retained for the duration of employment.

What must be included in a noise monitoring record?

A complete noise monitoring record must include: the date of measurement, the instruments used (make, model, serial number), calibration documentation, the names and job classifications of workers monitored, the TWA results, and documentation that workers were notified of their results as required by 1910.95(e).

Do employees have the right to see their noise monitoring results?

Yes. Under 1910.95(l), employers must make noise monitoring records available to employees, former employees, and their designated representatives upon request. Additionally, 1910.95(e) requires employers to proactively notify all monitored workers of their results.