This plain-language guide covers OSHA 29 CFR 1910.95 1910.95(i) — Hearing Protectors — 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 hearing protectors — supervised by a licensed audiologist.
When HPDs Must Be Made Available vs. Mandatory
| Noise Level | HPD Requirement |
|---|---|
| 85–90 dBA TWA (at or above action level, below PEL) | Must be made available at no cost; not mandatory unless STS has occurred |
| 90+ dBA TWA (at or above PEL) | Mandatory use; employer must ensure HPDs are worn |
| Any level after confirmed STS | Mandatory use until audiologist/physician determines further loss unlikely |
| New employees (before baseline audiogram) | Mandatory use regardless of exposure level, for first 6 months |
The Variety Requirement
1910.95(i)(3): "Employers shall provide employees with a selection of hearing protectors from a variety of suitable hearing protectors. At the minimum, a selection of at least one insertion type hearing protector and at least one circumaural type hearing protector shall be available."
Translation: you must offer at least one earplug and at least one earmuff. A single style of foam earplug does not satisfy the variety requirement. Workers must have meaningful choice so they can select a protector that fits properly and can be worn comfortably throughout their shift.
Attenuation Adequacy: The Core Requirement
1910.95(i)(1): "Employers shall provide hearing protectors to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater at no cost to the employees. Hearing protectors shall be replaced as necessary."
1910.95(i)(2): Employers must ensure selected HPDs adequately reduce the worker's noise exposure. OSHA's Appendix B provides methods for calculating whether an HPD's NRR provides adequate attenuation for a given noise level. The derating calculation for NRR involves subtracting 7 from the labeled NRR, then halving the result for use with A-weighted measurements.
OSHA's Appendix B derating formula reduces a foam earplug's NRR 33 to an estimated real-world attenuation of 13 dB for A-weighted TWA calculations. A worker at 98 dBA TWA using a foam earplug with NRR 33 achieves estimated effective exposure of 85 dBA — barely adequate. Individual fit testing via REAT methodology verifies actual attenuation for each worker, replacing estimated derating with measured data.
Refitting After STS
1910.95(i)(4): When a Standard Threshold Shift is confirmed, "the employer shall ensure that the employee is informed of this fact in writing within 21 days of this determination" and shall provide refitting or retraining on proper HPD use if the STS is attributable to inadequate HPD use or the inadequacy of the HPD selected.
The STS is the audiometric signal that something in the program — HPD selection, fit, or noise levels — has failed. Refitting and verifying adequate attenuation after an STS is both an OSHA requirement and good clinical practice. See: HPD fit testing: complete employer 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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