This plain-language guide covers OSHA 29 CFR 1910.95 1910.95(m) — Recordkeeping — 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 recordkeeping — supervised by a licensed audiologist.
The Three Categories of Required Records
OSHA 1910.95(m) identifies three categories of records with different retention requirements:
Noise Exposure Measurement Records — 1910.95(m)(3)
Noise monitoring records must be retained for 2 years. Required content: measurement date, area or individual monitored, instrument used (type, serial number), calibration data, and exposure results. The 2-year minimum is a floor, not a recommendation — many employers retain noise monitoring records indefinitely as documentation of exposure conditions at the time of measurement, which is relevant to WC proceedings that may arise decades later.
Audiometric Test Records — 1910.95(m)(2)
Audiometric records must be retained for the duration of the affected employee's employment. This means: as long as the person works for you, every audiogram must be accessible. The practical minimum retention period is therefore the worker's full tenure.
Post-employment retention: OSHA does not specify a post-employment retention period for audiometric records. Occupational health attorneys and WC defense counsel universally recommend retaining audiometric records for at least 30 years beyond the last date of employment for workers with significant noise exposure, given the latency of occupational hearing loss WC claims.
Required audiometric record content per 1910.95(m)(2)(i)–(vii):
- Name and job classification of employee
- Date of audiogram
- Examiner's name
- Date of last audiometer calibration
- Employee's most recent noise exposure assessment (monitoring data)
- Background noise levels in the test room at time of testing
- Audiometric test results (threshold in dBHL at each frequency for each ear)
Access Rights — 1910.95(m)(4)
Employees, former employees, and their representatives have the right to access noise exposure measurement records and audiometric test records. OSHA also has the right to access these records. The employer must provide access within 15 working days of a written request.
If audiometric records are held exclusively by a mobile van vendor or audiometric service provider, the employer cannot guarantee the 15-working-day access requirement will be met if the vendor relationship ends or the vendor is unresponsive. OSHA cites the employer — not the vendor — for recordkeeping failures. Employers should maintain their own copy of all audiometric records or use a platform that guarantees direct employer access at all times.
Transfer of Records
1910.95(m)(5): If an employer ceases to do business, they must transfer all audiometric records to the successor employer (if one exists) or notify affected employees of their right to access records before the employer dissolves. Records cannot simply be discarded when a business closes.
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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