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OSHA 1910.95(c)–(g): Audiometric Testing Program Requirements

Matt Reinhold, COO & Co-Founder at SoundtraceMatt ReinholdCOO & Co-Founder9 min readApril 8, 2026
OSHA 1910.95·Plain Language·9 min read·Updated April 2026

This plain-language guide covers OSHA 29 CFR 1910.95 1910.95(c)–(g) — Audiometric Testing Program — explaining exactly what the section requires, what it means in practice for EHS managers, and the most common compliance gaps. According to CDC/NIOSH, approximately 22 million U.S. workers are exposed to hazardous occupational noise annually. See the complete OSHA 1910.95 guide for the full standard overview.

Soundtrace delivers audiometric testing and noise monitoring that meets every 1910.95 requirement — including audiometric testing program — supervised by a licensed audiologist.

Audiometer Requirements — 1910.95(c)

1910.95(c)(1): The audiometric testing program must use pure tone, air conduction, hearing threshold level determination, reference ANSI Z24.5-1951. The audiometer must be calibrated in accordance with Appendix E (acoustic calibration) and used in a test environment meeting Appendix D (ANSI S3.1 maximum permissible ambient noise levels).

Baseline Audiograms — 1910.95(g)(5)

Baseline audiograms must be established within 6 months of first exposure at or above the 85 dBA action level. Exception: employers using mobile test vans have up to 1 year to establish the baseline, but must provide HPDs to new employees during the extended window.

The baseline is the reference audiogram against which all future STSs are calculated. It must be conducted after 14 hours without exposure to workplace noise and without use of hearing protectors during that quiet period (or the employee must be notified of this requirement so they can achieve the quiet period).

Annual Audiograms — 1910.95(g)(6)

Annual audiograms must be conducted within 12 months of the previous audiogram. They are compared to the baseline (or the revised baseline if one has been established) to detect Standard Threshold Shifts.

The Professional Supervisor Requirement — 1910.95(g)(3)

Audiometric testing must be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC) or who has demonstrated competence in administering audiometric tests as required. All audiograms must be reviewed by an audiologist, otolaryngologist, or physician — the Professional Supervisor — who determines STSs, makes referral decisions, and supervises the program clinically.

Standard Threshold Shift — 1910.95(g)(7)–(10)

An STS is a change in hearing threshold, relative to the baseline audiogram, of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear.

When an STS is confirmed by the PS, the employer must within 21 days:

  • Inform the employee in writing
  • Refit or retrain on HPD use if the STS may have been caused by inadequate protection
  • Evaluate whether the employee needs clinical referral
  • Evaluate whether the STS is work-related for OSHA 300 log recording purposes under 1904.10

See: Standard Threshold Shift: complete action guide.

Age Correction — 1910.95(g)(1)(ii) and Appendix F

OSHA permits (but does not require) age correction of audiograms using the gender-and-age-specific tables in Appendix F. Age correction reduces the apparent STS by subtracting expected presbycusis from the measured shift. This can prevent false-positive STSs in older workers whose thresholds have increased due to aging rather than noise. See: age correction in OSHA audiograms: Appendix F guide.

OSHA 1910.95 compliant — every section covered

Soundtrace automates 1910.95 compliance across monitoring, audiometry, HPD, training, and records — with licensed audiologist supervision of the complete program.

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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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