OSHA 29 CFR 1910.95 is the primary federal standard governing occupational noise exposure in general industry. It requires employers whose workers are exposed to noise at or above 85 dBA as an 8-hour time-weighted average to implement a complete hearing conservation program — covering noise monitoring, audiometric testing, hearing protection, training, and recordkeeping. This guide walks through every subsection of 1910.95, the specific actions each requires, the deadlines that govern them, the interactive compliance timeline, and how violations of each element are classified and penalized in 2026.
- What is OSHA 1910.95?
- Who must comply?
- Noise exposure thresholds
- Noise monitoring requirements
- Audiometric testing requirements
- Compliance timeline diagram
- STS detection and required response
- Hearing protector requirements
- Training requirements
- Recordkeeping requirements
- OSHA 300 log recordability
- 2026 penalty amounts
- Frequently asked questions
What Is OSHA 1910.95?
OSHA 29 CFR 1910.95 is the Occupational Noise Exposure standard for general industry. It was first promulgated in 1971, significantly amended in 1983 to add the hearing conservation amendment, and has been the governing standard for occupational hearing loss prevention in U.S. manufacturing, food processing, utilities, and most non-construction, non-mining industries ever since. For the full six-element program overview, see OSHA hearing conservation program: complete guide.
The standard operates on two tiers. The permissible exposure limit (PEL) of 90 dBA TWA establishes the maximum noise exposure allowed without engineering and administrative controls. The action level of 85 dBA TWA is a lower threshold that triggers the full hearing conservation program even when exposure is below the PEL. This two-tier structure means an employer whose workers are exposed to 87 dBA — below the PEL — still has full HCP obligations. See: NIOSH vs. OSHA noise exposure limits for how these thresholds compare to the scientifically recommended REL.
Who Must Comply With OSHA 1910.95?
1910.95 applies to all general industry employers subject to federal OSHA jurisdiction when any worker’s noise exposure equals or exceeds the action level of 85 dBA TWA. Key coverage notes:
- General industry only: Construction is governed by 29 CFR 1926.52. Mining is governed by MSHA 30 CFR Part 62.
- State plan states: 22 states operate OSHA-approved state plans. Their requirements must be at least as protective as 1910.95. Oregon and Washington impose additional technician certification requirements. See: federal OSHA vs. state plan OSHA.
- Federal workplaces: Federal agencies are governed by 29 CFR Part 1960, which mirrors 1910.95 requirements.
- Scope is per-worker: If even one worker has a TWA at or above 85 dBA, that worker must be enrolled. Not all workers in a facility need the same noise exposure level.
Noise Exposure Thresholds: Action Level, PEL, and Exchange Rate
| Threshold | Level | What It Triggers |
|---|---|---|
| Action Level | 85 dBA TWA | Full HCP: monitoring, audiometric testing, HPD offer, training, recordkeeping |
| PEL | 90 dBA TWA | Engineering/admin controls required; HPD use mandatory (not just offered) |
| Ceiling | 115 dBA | No exposure at or above this level at any time, even briefly |
| Impact/impulse peak | 140 dB | Absolute ceiling for impact or impulse noise |
Exchange rate: OSHA uses a 5 dB exchange rate (also called the doubling rate). The TWA integrates variable exposures using the formula TWA = 16.61 × log(D/100) + 90, where D is the percent noise dose. See also: OSHA vs. NIOSH exchange rate: 5 dB vs. 3 dB.
Noise Monitoring Requirements (1910.95(c)–(e))
Employers must monitor noise exposure when information indicates workers may be exposed at or above the action level. The monitoring must be sufficient to identify all workers who need to be enrolled in the HCP. See: area monitoring vs. personal dosimetry and noise monitoring and recordkeeping: OSHA requirements.
What must be monitored
- All continuous, intermittent, and impulsive sound levels from 80 to 130 dBA must be integrated into the measurement
- Dosimetry must use an 80 dBA threshold and 5 dB exchange rate to match OSHA’s calculation method
- Monitoring must be representative of the worker’s full work shift, not just peak periods
Worker notification
Under 1910.95(e), affected workers and their representatives must be given the opportunity to observe noise monitoring. Employers must notify workers of their individual noise exposure results in writing.
Audiometric Testing Requirements (1910.95(g))
All workers exposed at or above the action level must receive audiometric testing. The program must be conducted by or under the supervision of a licensed audiologist, otolaryngologist, or physician, or by a technician who has demonstrated competence whose work is reviewed by a licensed professional. See: microprocessor audiometer OSHA demonstrated competence and PLHCP role in OSHA 1910.95.
| Audiogram Type | Timing Requirement | Purpose | Key Conditions |
|---|---|---|---|
| Baseline | Within 6 months of first exposure ≥85 dBA (up to 12 months if mobile van used; HPD required in interim) | Establishes the reference point for all future STS calculations | Worker must have 14 hours away from workplace noise before the test |
| Annual | Within 12 months of baseline; annually thereafter | Detects threshold shifts; assesses program effectiveness | Age correction permitted; if better than baseline, may be substituted as revised baseline |
| Retest | Within 30 days of an identified STS (or accept annual if judged reliable) | Confirms whether the STS is real or a testing artifact | If confirmed, triggers notification and follow-up within 21 days |
| Revised baseline | When a persistent STS is confirmed, or when hearing improves significantly | Updates the reference threshold to reflect the worker’s current hearing level | Employer documents rationale; age correction decisions must be applied consistently |
Audiometer calibration
- Acoustic calibration (biologic check): Required before each day of use
- Exhaustive calibration: Required at least annually per ANSI S3.6
- Background noise check: Test environment must not exceed the Appendix D maximum permissible ambient noise levels
Compliance Timeline: Required Actions at a Glance
The diagram below maps the sequence of required employer actions from hire through annual cycle, with the STS trigger pathway and all statutory deadlines marked.
Required actions and deadlines under OSHA 29 CFR 1910.95. The red pathway shows the STS trigger sequence with statutory deadlines. Ongoing obligations in the bottom bar apply for the full duration of each worker’s enrollment in the HCP.
Standard Threshold Shift: Detection and Required Response (1910.95(g)(7)–(9))
A standard threshold shift (STS) is a change in hearing threshold relative to the baseline audiogram of an average of 10 dB or more at 2,000, 3,000, and 4,000 Hz in either ear. For the full STS calculation and age correction methodology, see standard threshold shift: definition, calculation, and action steps.
The required actions after STS confirmation, in sequence:
- Retest within 30 days (or accept the annual audiogram if judged reliable)
- If STS confirmed: notify the worker in writing within 21 days of confirmation
- If worker not already wearing HPDs: fit with hearing protectors, train, and require use
- If already using HPDs: refit, retrain, or require more protective HPDs
- Assess work-relatedness and determine if 300 log recordability criteria are met
- Evaluate whether a revised baseline is appropriate
- Medical referral if the STS cannot be attributed to workplace noise
OSHA permits employers to apply age correction factors from Appendix F when calculating whether an STS has occurred. The choice must be applied consistently and documented. Age correction can reduce the number of recordable STS events, but it cannot be used retroactively to escape notification obligations for an STS already communicated. See: OSHA audiogram age correction: Appendix F guide.
Hearing Protector Requirements (1910.95(i)–(j))
| Exposure Level | HPD Requirement | Enforcement |
|---|---|---|
| 85–89 dBA TWA (at action level, below PEL) | HPDs must be offered; worker may voluntarily decline | Offer and provision required; use not enforced by OSHA |
| 90+ dBA TWA (at or above PEL) | HPD use is mandatory | Employer must enforce actual wear; citation if workers observed not wearing |
| Any level with confirmed STS | HPD use mandatory regardless of dB level | Must be enforced even if worker is at 85–89 dBA |
| New hire, baseline audiogram pending | HPDs must be worn until baseline is established | Required for protection during the pre-baseline window |
Attenuation adequacy
HPDs must attenuate worker exposure to below the PEL (90 dBA), or below 85 dBA for workers with confirmed STS. OSHA’s compliance method is (NRR − 7) dB. For workers with prior STS, the 50% derating method is required: (NRR − 7) ÷ 2. See: HPD fit testing: the complete employer guide and NRR vs. real-world attenuation.
Training Requirements (1910.95(k))
Annual training is required for all workers enrolled in the HCP, covering: the effects of noise on hearing; purpose, advantages, and disadvantages of HPDs, plus selection, fitting, use, and care; and the purpose of audiometric testing. See: OSHA 1910.95(k) annual training requirements.
Recordkeeping Requirements (1910.95(m))
| Record Type | Minimum Retention | Content Required |
|---|---|---|
| Noise exposure measurements | 2 years | Date, location, instruments, TWA results, employee identity |
| Audiometric test records | Duration of employment (+ 30 years under 1910.1020) | Employee name/job, date, examiner name, audiometer calibration date, noise exposure, thresholds at 500–6000 Hz both ears |
| Background noise records (test environment) | Duration of test room use | SPL measurements confirming compliance with Appendix D |
Under 29 CFR 1910.1020, employees have the right to access their own audiometric and noise exposure records. Records must be accessible for OSHA inspection without advance notice — typically within 15 working days. See: audiometric records security: HIPAA and SOC 2 compliance and OSHA 300 log hearing loss recordkeeping rules.
OSHA 300 Log Recordability: The Separate Calculation (29 CFR 1904.10)
A hearing loss event is recordable on the OSHA 300 log only when both of the following are true:
- The STS threshold is met (10 dB or greater average shift at 2,000, 3,000, and 4,000 Hz in either ear relative to baseline)
- The worker’s total hearing level in the affected ear averages 25 dB HL or more at 2,000, 3,000, and 4,000 Hz
Many STS events do not meet the 25 dB HL total hearing level criterion and are therefore not 300-log recordable even though they trigger the 1910.95 notification and follow-up obligations. The 300 log is retained for 5 years under 29 CFR 1904.33. See OSHA 300 log hearing loss recordkeeping rules.
2026 Penalty Amounts for 1910.95 Violations
| Violation Category | 2026 Max Penalty | Common HCP Application |
|---|---|---|
| Serious | $16,550 | Missing baseline audiograms, STS not acted on, no training records |
| Other-Than-Serious | $16,550 | Missing audiometric record fields, monitoring records not retained 2 years |
| Repeat (within 5 yrs) | $170,046 | Same or substantially similar violation to prior citation — 10x multiplier |
| Willful | $170,046 | Employer knew requirement applied and deliberately failed to comply |
| Failure to Abate | $16,550/day | Failure to correct cited violation by abatement deadline |
For the full penalty calculation methodology including good-faith and size reduction factors, the interactive penalty estimator, and informal conference strategy, see: OSHA hearing conservation violations and penalties: 2026 guide.
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Get a Free Quote Book a demo →Frequently Asked Questions
The action level (85 dBA TWA) triggers mandatory HCP requirements — monitoring, audiometric testing, HPD availability, training, and recordkeeping. The PEL (90 dBA TWA) triggers additional obligations: HPD use is mandatory and feasible engineering and administrative controls must be implemented. Workers between 85 and 90 dBA have the full HCP but can choose whether to wear offered HPDs (unless they have a confirmed STS).
OSHA 1910.95(m)(2) requires audiometric records to be retained for the duration of employment. Under 29 CFR 1910.1020, an additional 30-year post-employment retention period applies. Occupational health attorneys recommend treating this as 30 years beyond termination, given that workers’ compensation hearing loss claims regularly surface decades after the noise exposure ended.
Not in most states. OSHA 1910.95(g)(3) requires audiometric tests to be conducted by a licensed audiologist, otolaryngologist, or physician, or by a technician who demonstrates competence under the supervision of a licensed professional. Oregon and Washington require CAOHC certification specifically.
Within 6 months of the employee’s first exposure at or above the action level (or within 1 year if a mobile audiometric testing unit is used). The worker must have at least 14 hours away from workplace noise before the baseline test to avoid temporary threshold shift contaminating the baseline record.
No. Construction is governed by 29 CFR 1926.52, which has a higher threshold (90 dBA TWA) and does not require audiometric testing programs. Only noise controls and hearing protection are required in construction under 1926.52.
An STS is a change in hearing threshold averaging 10 dB or more at 2,000, 3,000, and 4,000 Hz in either ear relative to the baseline audiogram. Confirmed STS triggers written employee notification within 21 days, HPD refitting and retraining, work-relatedness assessment, and possible OSHA 300 log entry under 29 CFR 1904.10.
OSHA uses a 5 dB exchange rate. Every 5 dB increase in noise level halves permissible exposure duration. At 90 dBA: 8 hours. At 95 dBA: 4 hours. At 100 dBA: 2 hours. TWA = 16.61 × log(D/100) + 90, where D is the percent noise dose.
A hearing loss event is recordable only when both of these are true: (1) an STS is confirmed, AND (2) the worker’s total hearing level in the affected ear averages 25 dB HL or more at 2,000, 3,000, and 4,000 Hz. Many STS events do not meet the 25 dB HL total criterion and are therefore not 300-log recordable, even though they trigger notification and follow-up obligations.
- OSHA Hearing Conservation Program: Complete Guide
- OSHA 1910.95 Requirements: The 6 Elements in Detail
- Standard Threshold Shift: Definition, Calculation & Action Steps
- NIOSH vs. OSHA Noise Exposure Limits Compared
- OSHA Hearing Conservation Violations & Penalties: 2026
- OSHA 300 Log Hearing Loss Recordkeeping Rules
- Workers’ Compensation for Occupational Hearing Loss: 50-State Guide
- Audiometric Records Security: HIPAA & SOC 2 Compliance
- HPD Fit Testing: The Complete Employer Guide