OSHA Hearing Conservation: the real cost is not having a program

Last updated: August 31, 2025 · 10–12 min read

Key takeaways
• OSHA PEL is 90 dBA (8‑hr TWA); action level is 85 dBA (8‑hr TWA) → Hearing Conservation Program (HCP) required.
• Impact/impulse noise should not exceed 140 dB peak.
• The “average” occupational hearing loss claim + indirects often equals ~$35,000—about the annual cost of a 100‑person HCP.
• Penalties for non‑compliance can add five‑ to six‑figure risk on top of claims and productivity loss.
• Prevention wins: monitor, test, fit‑test earplugs, and engineer out noise where possible.

In this guide

• What is the OSHA noise exposure limit?
• When is an OSHA Hearing Conservation Program required?
• What’s inside a compliant HCP?
• The business case: why the real cost is to not have a program
• ROI quick math (copy‑ready for finance)
• Implementation roadmap (practical steps)
• FAQs

What is the OSHA noise exposure limit?

Featured answer (AEO‑style):

• PEL: 90 dBA (8‑hour TWA) using a 5‑dB exchange rate.
• Action level (HCP trigger): 85 dBA (8‑hour TWA).
• Impact/impulse peak: ≤140 dB.
• Noise monitoring should integrate 80–130 dB.

Why it matters: The PEL is a legal ceiling for exposure control. The 85 dBA action level is where OSHA requires you to run a continuing, effective Hearing Conservation Program—even if the PEL isn’t exceeded.

Best practice: NIOSH’s Recommended Exposure Limit (REL) is 85 dBA (8‑hr TWA) with a 3‑dB exchange rate—more protective than OSHA’s minimum. Design toward REL when feasible.

When is an OSHA Hearing Conservation Program required?

You must implement an HCP when employee noise exposure is ≥85 dBA (8‑hr TWA). Typical triggers include continuous manufacturing lines, fabrication shops, aviation ramp operations, mining, oil & gas, construction, waste/recycling, and certain public‑sector roles.

Plain‑English checklist for the action level (85 dBA TWA):

• Start/maintain noise exposure monitoring and notify affected employees
• Provide audiometric testing (baseline + annual)
• Provide hearing protection at no cost; ensure use where required
• Deliver training and program evaluation annually
• Keep required records (noise data ≥2 years; audiograms for duration of employment)

What’s inside a compliant HCP?

1) Noise Exposure monitoring

• Sample representative workers; re‑monitor when processes, equipment, or schedules change.
• Capture 80–130 dB; consider full‑shift personal dosimetry for variable tasks.

2) Audiometry (hearing tests)

• Baseline after 14 hours without workplace noise exposure, or allow baseline testing while wearing hearing protectors (instead of “quiet time”).
• Annual tests to detect Standard Threshold Shift (STS)—an average ≥10 dB change at 2, 3, and 4 kHz from baseline.

3) Hearing protection

• Offer multiple suitable options (sizes/models); provide at no cost.
• Require use above the PEL, before baseline is established, and after STS.
• Fit‑testing (best practice) verifies personal attenuation for each employee; correct poor fit on the spot.

4) Training

• Annual, practical training: correct earplug insertion, why consistency matters, how noise and ototoxic chemicals interact, early signs of loss, and reporting pathways.

5) Recordkeeping

• Keep noise exposure records for ≥2 years.
• Maintain audiometric records for the duration of employment (at minimum).
• Follow 29 CFR 1904.10 for recordability: work‑related STS and hearing level ≥25 dB at 2, 3, 4 kHz (same ear) makes the case OSHA‑recordable.

The business case: why the real cost is to not have a program

Direct costs (claims). U.S. workers’ comp data show occupational hearing loss (OHL) claims average in the low‑ to mid‑five figures after inflation. A commonly cited benchmark: ~$16–17K direct per claim (2025 dollars), while totals vary widely by state and severity.

Indirect costs (often bigger than the claim). Factor lost time, retraining, rework, overtime, investigation, admin, and morale. A conservative indirect multiplier of ~1.1× for claims ≥$10K pushes a “typical” event toward ~$35,000 total impact.

Health plan & productivity drag. Untreated hearing loss correlates with higher overall medical spend, more inpatient stays/readmissions, and lower communication efficiency—which shows up as errors, near‑misses, or slower throughput.

Citations & penalties. OSHA updates penalties annually (inflation). In 2025, serious violations can reach the mid‑five figures each, and willful/repeat can exceed six figures—on top of claims and disruption.

Bottom line: The cost of one preventable claim (plus indirects) can pay for a year of HCP for ~100 noise‑exposed employees.

ROI quick math (copy‑ready for finance)

Inputs you can swap in:

• Average direct claim: $16,700
• Indirect multiplier: 1.1
• HCP cost per worker: $350/year
• Noise‑exposed headcount: 100
• Profit margin: 3% (or use your own)

Totals:

• Claim total ≈ $16,700 × (1 + 1.1) = ~$35,000
• HCP annual cost (100 workers) = 100 × $350 = $35,000
• Sales needed to cover one claim at 3% margin: $35,000 / 0.03 ≈ $1.17M
• At 8% margin: $35,000 / 0.08 ≈ $437,500

Interpretation: Avoiding one average claim typically funds your entire HCP for 100 workers. Larger events, repeat violations, or quality fallout tilt the math even further toward prevention.

Implementation roadmap (practical steps)

Step 1 — Map your noise.
Run screening surveys; deploy personal dosimetry in variable tasks; remap after changes.

Step 2 — Engineer first.
Treat noise like a defect: isolate, damp, enclose, slow, maintain. The cheapest decibel is the one you never create.

Step 3 — Baselines and annuals.
Test new entrants early in employment; capture baselines with either 14‑hr quiet or HPDs during baseline; schedule annuals before shifts to minimize false STS.

Step 4 — Fit‑test earplugs.
Move from “label NRR” to measured personal attenuation. Coach, retest, document.

Step 5 — Train for behavior.
Short, hands‑on refreshers; supervisors model correct use; use visual cues and peer checks.

Step 6 — Trend & act.
Dashboard your STS rates, test no‑shows, refit events, and high‑dose tasks. Investigate clusters immediately.

Step 7 — Audit & improve.
Annual HCP review; refresh procedures; capture lessons learned; budget noise controls using saved claim dollars.

FAQs

What is the OSHA noise exposure limit?

Answer: The PEL is 90 dBA (8‑hr TWA) with a 5‑dB exchange rate; impulse/impact peak ≤140 dB. The action level is 85 dBA, which triggers a Hearing Conservation Program.

When do I have to start a Hearing Conservation Program?

Answer: When any employee is exposed at or above 85 dBA (8‑hr TWA). You must monitor, test hearing (baseline + annual), provide hearing protection and training, and keep required records.

What is an OSHA Standard Threshold Shift (STS)?

Answer: An average ≥10 dB change from baseline at 2, 3, and 4 kHz in either ear. If work‑related and the hearing level is ≥25 dB at those frequencies in the same ear, the case is OSHA‑recordable.

OSHA vs. NIOSH—what should I design to?

Answer: OSHA defines the legal minimum (PEL 90 dBA, 5‑dB exchange). NIOSH REL is 85 dBA with a 3‑dB exchange—more protective and aligned with modern best practice, especially when you fit‑test hearing protection.

How long do I keep records?

Answer: Keep noise exposure measurement records at least 2 years; keep audiometric test records for the duration of employment (at minimum), along with training and HPD selection/fit documentation.

Source notes & links

OSHA limits, action level, HCP requirements, monitoring scope (80–130 dB), 140 dB peak, recordkeeping windows – 29 CFR §1910.95 (eCFR). Includes Table G‑16, action level 85 dBA, impulse peak limit, integration band, audiometry, HPD use/fit, training, and recordkeeping. eCFR

Baseline audiogram “14 hours quiet” (HPDs allowed instead) & annual testing cadence – §1910.95(g)(5). eCFR

OSHA recordability criteria for hearing loss (STS + ≥25 dB HL at 2/3/4 kHz) – 29 CFR §1904.10. eCFR

NIOSH REL and 3‑dB exchange rate (best practice target) – NIOSH “Understand Noise Exposure.” CDC

NIOSH Science Policy Update (Jan 2025): individual fit‑testing recommended – DHHS (NIOSH) Pub. 2025‑104. CDC

Ototoxic chemicals + noise synergy – NIOSH “Chemical‑Induced Hearing Loss.” CDC

HCP cost per worker/year – Peer‑reviewed study across 14 US metal facilities: $308 ± $80 per worker (program elements detailed). OSHA stakeholder meeting summary cites $300–$350/employee/year. CDC StacksOSHA

Workers’ compensation burden for OHL (2009–2013) – Avg annual cost ≈ $60M (2013$); avg cost/claim ≈ $12,051 (2013$); average ~4,965 claims/year. (Method: NCCI + CA/Ohio data.) Thieme

BLS burden (recorded cases) – 14,500 hearing‑loss cases (2019) in private industry. Bureau of Labor Statistics

Healthcare system impact of untreated hearing loss – Longitudinal claims analysis: 46% higher 10‑yr costs (~$22,434/person); more inpatient stays and readmissions. JAMA NetworkJohns Hopkins Public Health

Noise → injury risk (dose‑response evidence) – Systematic review/meta‑analysis (Annals of Work Exposures & Health). Oxford Academic

OSHA $afety Pays (indirect cost multipliers & sales‑to‑cover) – Background and estimator (≥$10k 1.1× multiplier). OSHA+1

2025 OSHA penalties – Maximums effective Jan 15, 2025: $16,550 serious/OTS/posting; $165,514 willful/repeat. OSHA

Inflation adjustment reference – Use the BLS CPI Inflation Calculator when converting older cost figures (e.g., 2013→2025). Bureau of Labor Statistics