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OSHA 1910.95(g) sets detailed requirements for audiometric testing in industrial hearing conservation programs — and the specifics matter. The baseline audiogram timing, the 21-day STS response window, the background noise requirements for the test environment, the qualifications for testing personnel, and the recordkeeping obligations are all precisely defined. Getting any of them wrong generates citable violations and undermines the hearing protection the testing is supposed to provide.
Soundtrace delivers OSHA 1910.95(g)-compliant audiometric testing with built-in audiology oversight, automated STS calculation, and digital recordkeeping.
Baseline audiograms must be established within 6 months of first noise exposure (1 year with mobile testing and interim HPD use). Annual audiograms must be conducted within 12 months of the prior test. STS follow-up must occur within 21 days of confirmation. The test environment must meet Appendix D background noise levels.
The baseline audiogram is the reference audiogram against which all subsequent annual audiograms are compared to detect threshold shifts. OSHA 1910.95(g)(5)(i) requires a valid baseline within 6 months of first exposure at or above the action level. A 1-year exception applies when mobile audiometric testing is used and hearing protection is provided from day one. OSHA requires a 14-hour quiet period before the baseline audiogram.
▶ Bottom line: The baseline audiogram is the single most important document in a hearing conservation program. Without it, STS cannot be calculated, apportionment in workers comp proceedings cannot be established, and the entire audiometric testing program loses its primary protective function.
OSHA 1910.95(g)(6) requires annual audiograms within 12 months of the prior audiogram. The 12-month window runs from the date of the prior test — not from a fixed calendar event. An employee tested in March must be retested by the following March, not at the next scheduled van visit.
The most common audiometric compliance failure is lapsed annual testing cycles. In-house automated testing eliminates this gap by making testing available any day of the year.
An STS is defined as an average change in hearing threshold of 10 dB or more at 2000, 3000, and 4000 Hz in either ear, compared to the baseline audiogram. Age correction may be applied using Appendix F tables before making the STS determination. When an STS is identified, OSHA requires within 21 days of determination: written employee notification; re-evaluation of hearing protection adequacy (upgrade required if current HPDs are insufficient); referral for further clinical evaluation if medically indicated; and OSHA 300 log recordability assessment (work-related STS with hearing level ≥25 dB at 2k/3k/4k Hz must be recorded).
▶ Bottom line: The 21-day STS response clock is one of the most frequently missed deadlines in hearing conservation. Automated platforms detect shifts and track the 21-day window automatically.
OSHA Appendix D establishes maximum allowable background noise levels in audiometric test rooms. A standard audiometric booth or properly sound-treated room typically meets these requirements; an untreated conference room or break room typically does not.
Tests must be administered by a licensed audiologist, otolaryngologist, physician, or a CAOHC-certified technician operating under the supervision of a licensed professional. The supervising audiologist or physician must review audiometric data for adequacy, evaluate STS findings, and make clinical determinations about baseline revision and referral. All audiometers must be calibrated under ANSI S3.6, with acoustic calibration checks before each day of use and full calibration at least annually.
Audiometric test records must be retained for the duration of the employee’s employment under OSHA 1910.95(m)(2). Records must include the employee’s name and job classification, the date of the audiogram, the examiner’s name, the date of the last calibration of the audiometer, and the employee’s most recent noise exposure assessment. Employees must be provided access to their own audiometric records within 15 working days of a request.
OSHA 1910.95(g)(3) specifies that tests must be administered by a licensed audiologist, otolaryngologist, physician, or a CAOHC-certified technician. Technicians must operate under the supervision of a licensed audiologist or physician. In-house automated audiometry platforms like Soundtrace provide the audiology oversight required.
OSHA 1910.95(g)(5)(ii) allows the baseline to be established within 1 year of first exposure (instead of 6 months) if mobile audiometric testing is used and the employer ensures hearing protectors are provided from the first day of exposure until the baseline is completed. This exception is specifically for mobile testing programs.
A revised baseline is appropriate when an annual audiogram reveals an STS that the supervising audiologist or physician determines is persistent and not likely to reverse. OSHA 1910.95(g)(9)(ii) permits but does not require baseline revision — it is a clinical judgment made by the supervising audiological professional.
Soundtrace provides baseline and annual audiometry, automated STS calculation, 21-day follow-up tracking, and audiology oversight in one platform.
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