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If you manage a noisy workplace, OSHA 29 CFR 1910.95 is the federal regulation that governs almost everything you do to protect workers' hearing. It tells you when a hearing conservation program is legally required, what that program must include, how to test employees' hearing, what records to keep, and what happens when a worker's hearing deteriorates on your watch. This guide breaks down every section in plain English so safety managers, HR teams, and business owners know exactly what compliance looks like in 2025.
Soundtrace is a digital hearing conservation platform that automates OSHA 1910.95 compliance -- audiometric testing, noise monitoring, recordkeeping, and training -- for industrial employers.
If any employee is exposed to an 8-hour average noise level of 85 dBA or higher, OSHA 1910.95 applies to you. That threshold triggers mandatory noise monitoring, hearing tests, hearing protection, annual training, and 30-year recordkeeping. Ignoring it exposes your company to citations up to $16,131 per violation or $161,323 for willful violations.
OSHA 29 CFR 1910.95 -- officially titled Occupational Noise Exposure -- is the federal standard that regulates how general industry employers must protect workers from noise-induced hearing loss (NIHL). It sits under Subpart G of Part 1910, which covers occupational health and environmental controls.
The standard was originally enacted in 1971 and significantly amended in 1983 to add the detailed hearing conservation program requirements found in paragraphs (c) through (o). Those amendments remain the backbone of the standard today.
OSHA 1910.95 applies to general industry. Construction sites are governed by a separate standard, 29 CFR 1926.52. Mining operations fall under MSHA's jurisdiction, not OSHA's.
The "1910.95" shorthand refers to Title 29 of the Code of Federal Regulations (CFR), Part 1910 (general industry), Section 95. When you see citations like 1910.95(c) or 1910.95(g)(10), those are subsections within this same standard.
Any general industry employer whose workers are exposed to noise at or above the action level of 85 dBA TWA (8-hour time-weighted average) must comply with the hearing conservation requirements in paragraphs (c) through (n). This covers manufacturing, warehousing, food processing, printing, utilities, petrochemicals, and dozens of other sectors.
| Threshold | Level | What It Triggers |
|---|---|---|
| Action Level (AL) | 85 dBA TWA | Full hearing conservation program: monitoring, audiometric testing, hearing protection, training, recordkeeping |
| Permissible Exposure Limit (PEL) | 90 dBA TWA | Mandatory hearing protection use AND feasible engineering/administrative controls required |
| Impulsive Noise Ceiling | 140 dB peak SPL | Exposure above this level is not permitted under any circumstances |
Many employers believe that providing hearing protection means they don't need a formal hearing conservation program. This is incorrect. Hearing protection is one component of the program -- the full program (monitoring, audiograms, training, records) is still required once noise reaches 85 dBA TWA.
OSHA uses a 5 dBA exchange rate to calculate permissible exposure times. Every 5 dBA increase cuts the allowable exposure time in half.
| Noise Level (dBA) | Max Permissible Duration |
|---|---|
| 90 dBA | 8 hours |
| 95 dBA | 4 hours |
| 100 dBA | 2 hours |
| 105 dBA | 1 hour |
| 110 dBA | 30 minutes |
| 115 dBA | 15 minutes (maximum) |
Note: NIOSH uses a stricter 3 dBA exchange rate and recommends action at lower exposure levels. Many occupational health professionals follow NIOSH limits as best practice.
When there is reason to believe any employee's noise exposure may reach or exceed 85 dBA TWA, the employer must implement a noise monitoring program. Practical indicators include employee complaints, signs of hearing loss, or high-noise equipment such as stamping presses, grinders, or pneumatic tools.
Employers may use area sound level meters or personal noise dosimeters worn during representative work shifts. All continuous, intermittent, and impulsive sounds from 80 dB to 130 dB must be integrated into the measurement.
Re-monitoring is required whenever production, equipment, or process changes may increase noise levels -- or when results suggest additional workers may have been exposed above the action level.
Under 1910.95(e), workers must be notified of their individual monitoring results and have the right to observe monitoring procedures. These are legally enforceable rights, not optional courtesies.
Audiometric testing must be provided at no cost to the employee for all workers exposed at or above the 85 dBA action level.
A baseline audiogram must be obtained within 6 months of an employee's first exposure at or above the action level. If a mobile testing van is used, this may extend to 1 year -- but hearing protection must be worn during that interim period.
Annual audiograms must be performed at least once every 12 months. Each annual test is compared to the baseline to detect any Standard Threshold Shift (STS).
| Audiogram Type | When Required | Purpose |
|---|---|---|
| Baseline | Within 6 months of first exposure at or above 85 dBA | Establishes reference for all future comparison |
| Annual | At least every 12 months | Detects threshold shifts; assesses program effectiveness |
| Retest | Within 30 days of a detected STS | Confirms whether the STS is real or a testing artifact |
| Revised Baseline | When a persistent STS is confirmed | Updates the reference threshold to the new hearing level |
A Standard Threshold Shift is a change in hearing thresholds -- relative to the baseline -- of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. When an STS is detected, these actions are legally required:
HPDs must be made available at no cost to all employees exposed at or above 85 dBA. Use becomes mandatory at or above the 90 dBA PEL and for any employee who has experienced an STS.
NIOSH now recommends quantitative fit testing (QNFT) to verify that each worker's HPD actually performs as labeled. Lab NRR values consistently overestimate real-world protection. Soundtrace supports fit testing natively.
Training must be provided to every employee exposed at or above 85 dBA TWA and repeated annually. Each program must cover:
| Record Type | Retention Period | What Must Be Included |
|---|---|---|
| Noise exposure measurements | 2 years | Date, location, method, equipment, results, employees monitored |
| Audiometric test records | Duration of employment | Employee name, job classification, date, examiner, calibration data, results per ear and frequency |
| Audiometer calibration records | Duration of employment | Calibration dates, results, annual acoustic calibration |
Missing or incomplete audiometric records are among the most common OSHA noise inspection findings. If you can't produce records on request, you face citations regardless of how otherwise sound your program is.
| Violation Type | Maximum Penalty (2025) |
|---|---|
| Serious / Other-than-serious | Up to $16,131 per violation |
| Willful or Repeated | Up to $161,323 per violation |
| Failure to abate | Up to $16,131 per day beyond abatement date |
Generally no. OSHA 1910.95 only applies when workers are exposed to 85 dBA TWA or higher. Typical offices run 50-65 dBA. However, if an office is adjacent to a noisy production floor, measurements should be taken to confirm compliance.
No. Hearing protection is one component of a hearing conservation program, not a substitute for it. Audiometric testing, training, noise monitoring, and recordkeeping are all still required once noise reaches 85 dBA TWA.
The action level (85 dBA TWA) triggers the requirement to implement a full hearing conservation program. The PEL (90 dBA TWA) is the legal noise ceiling -- at or above it, hearing protection use becomes mandatory and engineering controls must be explored.
OSHA requires audiometric records to be retained for the duration of employment. Most compliance professionals recommend keeping records for at least 30 years beyond termination, since occupational hearing loss claims can surface long after employment ends.
Yes. The standard applies to any employee -- full-time, part-time, temporary, or contract -- whose noise exposure meets or exceeds the action level. Host employers and staffing agencies share certain compliance obligations for temporary workers.
Soundtrace is the only end-to-end digital platform built for OSHA hearing conservation -- audiometric testing, noise monitoring, fit testing, training tracking, and recordkeeping in one place.
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