Note: OSHA 29 CFR 1910.95 refers to this as a “hearing conservation program,” though it is also commonly called a hearing protection program. The terms are used interchangeably in this guide.
If noise exposure at your facility reaches or exceeds 85 dBA as an 8-hour time-weighted average, OSHA requires you to implement a hearing conservation program — and failure to do so is one of the most commonly cited violations in industrial workplaces. This guide covers every element OSHA mandates under 29 CFR 1910.95: noise monitoring, audiometric testing, hearing protection, employee training, and recordkeeping — so your program holds up when an inspector walks in.
Soundtrace replaces paper-based and mobile-van workflows with in-house audiometric testing, real-time noise monitoring, automated STS detection, and 30-year cloud recordkeeping — fully aligned with OSHA 1910.95 and supervised by a licensed audiologist.
- Action Level (85 dBA TWA): Noise monitoring, audiometric testing, and hearing protector availability required
- PEL (90 dBA TWA): Hearing protection use becomes mandatory
- 140 dB peak: Applies to impulse/impact noise regardless of duration
These thresholds apply to any employer covered under 29 CFR 1910.95, including manufacturing, construction, and utilities.
- What is a hearing conservation program?
- What triggers the obligation: the 85 dBA action level
- The 6 required program elements (overview)
- Interactive program flow diagram
- Element 1: Noise monitoring
- Element 2: Audiometric testing
- Element 3: Hearing protection devices
- Element 4: Employee training
- Element 5: Recordkeeping
- Element 6: Access to information
- Interactive HCP self-audit checklist
- Frequently asked questions
What Is a Hearing Conservation Program?
A hearing conservation program (HCP) is a coordinated set of employer-administered measures required by OSHA 29 CFR 1910.95 to prevent occupational noise-induced hearing loss. Unlike a single safety policy, an HCP is a structured system with six interdependent required elements — monitoring, testing, protection, training, recordkeeping, and information access — each with specific performance standards and documentation requirements.
The program applies to any general industry employer with workers exposed to noise at or above 85 dBA as an 8-hour TWA. It must be employer-administered and provided at no cost to employees. The purpose is both preventive — catching early threshold shifts before they become permanent hearing loss — and defensive, creating the audiometric and compliance record that protects employers in workers' compensation proceedings.
Many employers confuse providing earplugs with running a hearing conservation program. Hearing protection is only one of six required elements. An employer who distributes foam earplugs but skips noise monitoring, audiometric testing, and annual training is not running a compliant HCP — and faces citations under each missing element.
What Triggers the Obligation: The 85 dBA Action Level
The program requirement kicks in at 85 dBA as an 8-hour TWA — not 90 dBA. Under OSHA 1910.95(c), the permissible exposure limit (PEL) is 90 dBA, above which engineering controls become mandatory. But the hearing conservation program is triggered at 85 dBA. Every employer with workers at or above that threshold must implement all six elements.
Many employers believe the hearing conservation program only applies above the 90 dBA PEL. It applies at 85 dBA TWA. If any employee's exposure meets the action level, the entire six-element program is required. The PEL triggers additional engineering control requirements on top of the program obligations.
| Threshold | Level | What It Triggers |
|---|---|---|
| Action Level (AL) | 85 dBA TWA | Full 6-element hearing conservation program required |
| Permissible Exposure Limit (PEL) | 90 dBA TWA | Engineering/administrative controls required; HPD use becomes mandatory |
| STS Threshold | 10 dB avg shift at 2k/3k/4k Hz | Employee notification, HPD refitting, retraining, OSHA 300 log evaluation |
Note that OSHA 1910.95 applies to general industry only. Construction sites are governed by 29 CFR 1926.52. Federal agencies follow 29 CFR 1960.70. DoD civilian employees have additional obligations under DoDI 6055.12.
The 6 Required Elements
OSHA 1910.95 requires all six elements for every employer with workers at or above the action level. There is no partial compliance. An employer who monitors noise but skips audiometric testing has not implemented a compliant program — and will face citations under each missing element.
| # | Element | Core Requirement | Record Retention |
|---|---|---|---|
| 1 | Noise Monitoring | Identify all employees at or above 85 dBA action level | 2 years |
| 2 | Audiometric Testing | Baseline + annual audiograms; STS identification and follow-up | Duration of employment |
| 3 | Hearing Protection | Variety of HPDs at no cost; mandatory above PEL or post-STS | N/A |
| 4 | Training | Annual training for all enrolled employees | Best practice: 3 years |
| 5 | Recordkeeping | Retain noise measurements and audiograms per schedule | 2 yrs noise / employment duration audiograms |
| 6 | Access to Information | Employees receive results and can access records on request | N/A |
Interactive Program Flow Diagram
The diagram below shows how OSHA 1910.95's six elements connect in a compliant program. Click any element to see what OSHA inspectors look for in that area.
Click any element in the diagram to see what OSHA inspectors look for during an audit. The amber dashed arrow shows the STS trigger pathway. Source: OSHA 1910.95.
Element 1: Noise Monitoring
Noise monitoring under 1910.95(d) must identify every employee whose exposure may equal or exceed 85 dBA TWA. OSHA permits area monitoring and personal dosimetry. Personal dosimetry is preferred where workers move through different noise zones, because area monitoring may underestimate individual exposure.
Monitoring must be repeated whenever a change in production, process, equipment, or controls may increase noise exposures to the action level. This re-monitoring obligation is frequently missed and frequently cited. See OSHA noise re-monitoring requirements for the full trigger list.
For a deeper look at how NIOSH and OSHA calculate noise dose differently (using different exchange rates), see NIOSH vs. OSHA Exposure Limits. For facilities with intermittent or impulse noise, see impulse and impact noise requirements.
Element 2: Audiometric Testing
OSHA 1910.95(g) requires a baseline audiogram within 6 months of first exposure at or above the action level, and an annual audiogram every 12 months thereafter. Audiograms must test 500, 1000, 2000, 3000, 4000, and 6000 Hz in each ear. The testing environment must meet ANSI S3.1 maximum permissible ambient noise levels. For a complete breakdown of every audiometric testing requirement, see audiometric testing for employers: complete OSHA guide.
A standard threshold shift (STS) is a 10 dB or greater average change in hearing at 2,000, 3,000, and 4,000 Hz in either ear relative to the baseline. An STS triggers: employee notification within 21 days, HPD refitting, retraining, re-evaluation of noise controls, and potential OSHA 300 log entry under 29 CFR 1904.10. Age correction (Appendix F) is permissible when determining if an STS is work-related but may not be used to avoid the notification requirement.
OSHA 1910.95(g)(3) requires audiometric testing programs to be supervised by a licensed or certified audiologist, otolaryngologist, or other physician — the Professional Supervisor. The supervisor must review all audiograms exhibiting STS and make all medical referral determinations.
Element 3: Hearing Protection Devices
Under 1910.95(i), employers must provide a variety of hearing protection devices at no cost. Availability alone does not ensure use — a 2021 NIOSH study found 53% of noise-exposed workers do not consistently wear hearing protection. The variety requirement is real: a single style of foam earplug does not satisfy it.
HPD use is mandatory (not optional) for: (1) any employee whose exposure exceeds the 90 dBA PEL, (2) any employee who experienced an STS, and (3) any new employee awaiting a baseline audiogram. Many employers misread this as applying only above the PEL.
For a full breakdown of HPD types, NRR deration, and Soundtrace's REAT-based fit testing system, see HPD fit testing: the complete employer guide.
Element 4: Employee Training
1910.95(k) requires annual training for every enrolled employee. Training must cover three specific topics: the effects of noise on hearing, the purpose and proper use of HPDs (including fitting and care), and the purpose of audiometric testing and how to interpret results. Training must be updated whenever there are changes to the noise control program or HPD offerings.
For the full training content requirements and how to document compliance, see OSHA 1910.95(k) annual training requirements.
Element 5: Recordkeeping
Under 1910.95(m): noise exposure records must be kept for 2 years; audiometric test records for the duration of employment (most occupational health attorneys recommend 30 years beyond termination given latency of workers' compensation claims); OSHA 300 log entries for recordable STS cases for 5 years.
Each audiometric test record must contain: employee name and job classification, audiogram date, examiner name and credentials, date of last audiometer calibration, the employee's most recent noise exposure assessment, and background sound pressure levels in the test room. See OSHA 300 log hearing loss recordkeeping rules.
OSHA requires audiometric records be kept for the duration of employment. However, occupational hearing loss workers' compensation claims regularly surface 10, 20, or 30 years after exposure ends. Paper records held by a mobile van vendor may be unavailable when you need them. Cloud-based retention with a documented chain of custody is the only reliable long-term solution.
Element 6: Access to Information
Under 1910.95(m)(4), records must be made available to employees, former employees, their designated representatives, and OSHA within 15 working days of a request. Paper-based records held by mobile van vendors routinely fail this requirement when the vendor relationship ends — and OSHA does not accept "we no longer have the records" as a defense. See audiometric records security: HIPAA & SOC 2 compliance.
Interactive HCP Self-Audit Checklist
Check off each element your program currently has in place. The score updates as you go — use this to identify which elements need attention before an OSHA inspection.
This checklist reflects OSHA 1910.95 requirements as of April 2026. Each unchecked item is a potential citation. Every item checked but not documented is the same as not checked — inspectors ask for records, not verbal confirmation.
Frequently Asked Questions
A hearing conservation program (HCP) is a coordinated set of employer-administered measures required by OSHA 29 CFR 1910.95 to prevent occupational noise-induced hearing loss. It must include six elements: noise monitoring, audiometric testing, hearing protection devices at no cost, annual employee training, recordkeeping, and access to information. The program is mandatory for any general industry employer with workers exposed at or above 85 dBA as an 8-hour TWA.
OSHA 29 CFR 1910.95 requires six elements: noise monitoring to identify enrolled employees, audiometric testing including baseline and annual audiograms, hearing protection devices at no cost in a variety of styles, annual employee training, recordkeeping for noise measurements and audiograms, and access to information including employee notification of results and record access within 15 days.
The six required elements are: (1) noise monitoring to identify all employees at or above the 85 dBA action level; (2) audiometric testing including baseline and annual audiograms with STS detection; (3) hearing protection devices provided at no cost in a variety of styles; (4) annual employee training on noise effects, HPD use, and audiometric testing; (5) recordkeeping with noise records retained 2 years and audiometric records for duration of employment; and (6) access to information with records available to employees and OSHA within 15 working days.
The action level is 85 dBA as an 8-hour TWA. This threshold triggers the full hearing conservation program under 1910.95(c). It is separate from the PEL (90 dBA TWA), which triggers additional engineering control obligations. The program starts at 85 — not 90.
OSHA 1910.95(i) requires employers to provide a variety of suitable hearing protection devices at no cost. HPD use is mandatory (not merely available) for workers whose exposure exceeds the 90 dBA PEL, any worker who has experienced an STS, and new employees awaiting a baseline audiogram. A single style of earplug does not satisfy the variety requirement.
A baseline audiogram must be established within 6 months of first exposure at or above 85 dBA TWA. Annual audiograms are required every 12 months thereafter. If a mobile van is used, the baseline may be extended to 12 months with employees wearing HPDs in the interim.
An STS is a change in hearing of 10 dB or more averaged at 2,000, 3,000, and 4,000 Hz in either ear, relative to the baseline audiogram. An STS triggers employee notification within 21 days, HPD refitting, retraining, re-evaluation of engineering controls, and evaluation for potential OSHA 300 log recording.
Noise exposure records: 2 years. Audiometric test records: duration of employment. OSHA 300 log entries for recordable STS: 5 years. Records must be accessible to employees, former employees, and OSHA within 15 working days of a request.
No. OSHA 29 CFR 1910.95 applies to general industry. Construction noise is governed by 29 CFR 1926.52, and federal agencies follow 29 CFR 1960.70. DoD civilian employees have additional requirements under DoDI 6055.12. Mining is governed by MSHA 30 CFR Part 62.
OSHA 1910.95(g)(3) requires audiometric testing programs to be supervised by a licensed or certified audiologist, otolaryngologist, or other physician. The supervisor reviews and interprets audiograms and makes all STS determinations and medical referral decisions.
Running a Hearing Conservation Program Across Multiple Sites?
Most EHS teams are managing audiogram records, STS flags, and OSHA logs in spreadsheets — which means one missed entry becomes an audit liability. Soundtrace automates the entire program: employee tracking, audiometric test results, STS analysis, and audit-ready reporting, all in one place.
See How Soundtrace Works →Ready to build a fully compliant hearing conservation program?
Soundtrace replaces paper logs, mobile van scheduling, and spreadsheet STS tracking with one digital platform — built for OSHA 1910.95 and supervised by a licensed audiologist.
Get a Free Quote Book a demo →- Audiometric Testing for Employers: Complete OSHA 1910.95 Guide
- OSHA Noise Monitoring Requirements: Complete Guide
- Standard Threshold Shift: Definition, Calculation & Action Steps
- NIOSH vs. OSHA Noise Exposure Limits Compared
- OSHA 300 Log Hearing Loss Recordkeeping Rules
- HPD Fit Testing: The Complete Employer Guide
- Audiometric Testing for Employers: Complete Guide
- OSHA Hearing Conservation Violations & Penalties