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Updated March 2026 · 29 CFR 1910.95 · ~20 min read
An OSHA hearing conservation program is a written, site-specific set of policies and procedures that protects workers exposed to noise at or above 85 dBA as an 8-hour time-weighted average (TWA). Under 29 CFR 1910.95, general industry employers must implement all six required elements—noise monitoring, audiometric testing, hearing protection, training, recordkeeping, and access to information—whenever any employee’s noise exposure meets or exceeds the action level.
Soundtrace is a digital hearing conservation platform that replaces paper-based and mobile-van workflows with in-house audiometric testing, real-time noise monitoring, automated STS flagging, and cloud recordkeeping—fully aligned with OSHA 1910.95 and ANSI S3.6-2018.
29 CFR 1910.95(c) requires a hearing conservation program whenever any employee’s noise exposure equals or exceeds an 8-hour TWA of 85 dBA—the action level. This applies to general industry. Construction falls under 29 CFR 1926.52, which has a higher action level and fewer explicit program requirements. Mining is governed by MSHA rather than OSHA.
Industries where employees routinely hit the action level include manufacturing, automotive assembly, food processing, printing, paper and pulp, utilities, oil and gas, and warehousing with powered industrial trucks. If a noise survey shows any job classification at or above 85 dBA TWA, the entire hearing conservation program must be activated for those employees—not just for the noisiest workers.
| Threshold | Level | What It Triggers |
|---|---|---|
| Action Level (AL) | 85 dBA TWA | Full hearing conservation program required—all 6 elements |
| Permissible Exposure Limit (PEL) | 90 dBA TWA | Engineering/administrative controls required; HPD use becomes mandatory |
Many employers believe they only need a program if workers are at or above the PEL (90 dBA). Wrong—the program kicks in at 85 dBA TWA, 5 decibels lower. An employee on a press line for part of the day can hit the action level even if the area sound level meter reads 88 dBA. Always run the full cumulative dose calculation, not a spot check.
NIOSH recommends a more protective 85 dBA TWA PEL using a 3 dB exchange rate; OSHA uses a 5 dB exchange rate and a 90 dBA PEL. Learn more: NIOSH vs. OSHA noise standards compared.
Any employer with workers consistently exposed at or above 85 dBA TWA must implement a full, written hearing conservation program under 29 CFR 1910.95—no exceptions, no phase-in period.
OSHA 1910.95 specifies six elements every program must include. Failure to implement any single element is a citable violation. All six must run simultaneously—you cannot phase them in or swap one for another.
| # | 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 use 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 OSHA schedule | 2 yrs (noise) / employment duration (audiograms) |
| 6 | Access to Information | Employees receive results and can access records on request | N/A |
See also: The 6 Required Elements of an OSHA Hearing Conservation Program for a per-element compliance breakdown.
OSHA does not allow employers to substitute one element for another. All six must be in place simultaneously for any employee at or above the 85 dBA action level.
Noise monitoring determines which employees are covered by the hearing conservation program. Under 1910.95(d), employers must use either a sound level meter or a noise dosimeter to measure employee exposures. Monitoring must be repeated whenever a change in production, process, equipment, or controls may increase noise exposures to the action level.
OSHA requires instruments that integrate all continuous, intermittent, and impulsive noise from 80 to 130 dBA, using the A-weighted slow-response setting for sound level meters, or dosimeters meeting the criteria in Appendix A to 1910.95.
Conducting noise monitoring once and never repeating it. OSHA requires re-monitoring any time there is a change in production process, equipment, or controls that could push exposures toward the action level. New machinery, new shift schedules, and floor layout changes all trigger a new survey. A single survey from several years ago—with no follow-up—is a citation waiting to happen.
Step-by-step guides: Industrial Noise Monitoring: How to Measure Workplace Sound Levels and Workplace Noise Exposure Assessment.
Noise monitoring is not a one-time event. Any significant change to equipment, layout, or production schedules that could push workers toward 85 dBA requires a new survey and updated records.
Audiometric testing is the clinical core of the hearing conservation program. OSHA 1910.95(g) requires two types of audiograms: 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. The audiometer must meet ANSI S3.6 specifications, calibrated acoustically annually and biologically before each day of use.
An STS is a 10 dB or greater average shift in hearing at 2000, 3000, and 4000 Hz in either ear, compared to the baseline audiogram. A confirmed STS may be recordable on the OSHA 300 log. Employers must notify the employee within 21 days, refit or retrain on hearing protection, and consider referral to an audiologist. Full guide: Standard Threshold Shift: Definition, Calculation, and Action Steps.
Missing the 6-month baseline window. New hires exposed at or above the action level must receive a baseline audiogram within 6 months (or 1 year if a mobile van is used and the employee wears HPDs in the interim). Late baselines are one of the most frequently cited violations—especially at high-turnover facilities. Without a valid baseline, you cannot calculate an STS, which makes every annual audiogram compliance-worthless.
Key decisions: In-House vs. Mobile Van Testing · Digital vs. Paper-Based Systems · Complete Industrial Guide
Soundtrace’s audiometric testing platform enables boothless in-house testing with automatic STS flagging, ANSI-compliant audiometers, and cloud record storage.
In-house audiometric testing reduces per-employee cost, eliminates mobile van scheduling bottlenecks, and delivers real-time STS alerts rather than waiting for quarterly vendor reports.
Under 1910.95(i), employers must make a variety of hearing protection devices available to all employees at or above the action level—at no cost. Selection must consider attenuation, comfort, and suitability for the task. The NRR on HPD packaging is the starting point, but OSHA requires applying a de-rating factor for real-world fit variability. See: NRR Explained.
Fit testing: While 1910.95 does not currently mandate quantitative fit testing, OSHA’s updated guidance and NIOSH strongly encourage FAES testing to generate personal attenuation ratings (PARs). See: Why OSHA’s Latest Fit Testing Guidance Matters.
Providing only one style of hearing protection—typically a single foam earplug. OSHA requires a variety. Workers with small ear canals, facial hair, or tasks requiring frequent removal all need options. Stocking a single earplug violates 1910.95(i)(1) and statistically guarantees underprotection for a portion of your workforce.
Soundtrace’s fit testing feature generates PAR scores and stores results alongside audiogram records for a complete per-employee protection file.
A variety of HPD styles plus documented fit testing dramatically reduces underprotection—the leading cause of STS in otherwise-compliant programs.
1910.95(k) requires annual training for every enrolled employee covering: the effects of noise on hearing; the purpose, advantages, disadvantages, and attenuation of HPDs; instructions on HPD selection, fitting, use, and care; and the purpose and procedures of audiometric testing. Training must be provided at no cost, during working hours, and updated annually. New employees must be trained before or at first exposure.
Doing training but not documenting it per employee. A group sign-in sheet doesn’t prove a specific employee was trained—especially if your workforce has turned over. If you can’t prove training happened for a named individual, OSHA treats it as if it didn’t happen. Digital training with per-employee completion timestamps is the only reliable solution at scale.
Related: OSHA Training Requirements · What to Include in Annual Training
Soundtrace includes a built-in OSHA-compliant training module with per-employee completion records stored automatically.
Training records are the first thing an OSHA compliance officer requests in an inspection. Digital training with automated completion tracking closes the gap that paper sign-in sheets leave wide open.
OSHA 1910.95(m) specifies exact retention periods for all hearing conservation records:
| Record Type | Retention | Must Include |
|---|---|---|
| Noise exposure measurements | 2 years | Date, employee/area, instrument, results |
| Audiometric test records | Duration of employment | Name, job class, date, examiner, audiometer serial & calibration date, noise exposure assessment |
| Audiometric test room background levels | 2 years | Frequency-by-frequency SPL readings |
| OSHA 300 log (recordable STS) | 5 years | Standard 300 log fields |
Losing audiometric records when employees transfer between sites or leave the company. OSHA requires that records follow the employee. Without the baseline from a previous site, the new site cannot calculate an STS. Lost or destroyed records can constitute a separate recordkeeping violation on top of any substantive program deficiencies. Paper filing systems virtually guarantee this failure at multi-site employers.
See: Managing a Program Across Multiple Sites · OSHA Recordkeeping Requirements
Soundtrace’s cloud recordkeeping module stores all noise measurements, audiograms, calibration logs, and training records in one place with automatic retention flagging and export-ready audit packages.
Paper-based recordkeeping creates audit risk: files get lost during transfers, calibration logs go missing, and OSHA can cite missing records even when testing was actually performed.
Employees enrolled in a hearing conservation program have the right to access their own audiometric records on request. Employers must provide audiogram results and explain what they mean. OSHA’s access to employee exposure and medical records regulation (29 CFR 1910.1020) also applies: employees, designated representatives, and OSHA must be able to access records within a reasonable time. See: OSHA Hearing Conservation Recordkeeping.
Treating access as an afterthought. Failure to provide records on request is a separate citable violation from deficiencies in the records themselves. Employers who have the records but delay access—or who don’t notify employees of STS results within the required 21-day window—can be cited even if every other element of their program is otherwise solid.
Employee access to hearing conservation records is not optional. Failure to provide records on request is a separate citable violation from any deficiencies in the records themselves.
OSHA does not require a document labeled “Hearing Conservation Program,” but compliance officers expect a written set of documents that together demonstrate a complete, implemented program. A single written document is the most defensible approach. It should include:
Having a written program that no one follows. A written program that exists on paper but isn’t implemented is worse than no written program—it documents your awareness of the requirements alongside your failure to meet them. OSHA inspectors routinely cite employers whose written program says annual audiograms will be conducted but whose records show testing hasn’t happened in three years.
Full walkthroughs: How to Write a Hearing Conservation Program: Step-by-Step · How to Write a Hearing Conservation Program Policy
Auditors don’t grade you on what your written program says you will do—they grade you on what your records prove you actually did.
OSHA inspections targeting hearing conservation are triggered by employee complaints, referrals from other inspections, or programmed enforcement in high-noise industries. OSHA National and Regional Emphasis Programs frequently include noise as a priority hazard. See: OSHA Renews Regional Emphasis Program for Workplace Noise.
| Violation | Section | Root Cause |
|---|---|---|
| Failure to conduct monitoring | 1910.95(d) | No documented survey on file, or survey is outdated |
| Missing or late baseline audiogram | 1910.95(g)(5) | New hire tested outside the 6-month window |
| STS not identified or acted on | 1910.95(g)(8) | No STS review process; paper records never compared year-over-year |
| No training records | 1910.95(k) | Training done verbally but not documented per employee |
| Missing audiometric records | 1910.95(m)(2) | Records lost during employee transfer or termination |
| Only one HPD style offered | 1910.95(i)(1) | Single earplug type stocked; no alternatives available |
OSHA serious violation penalties in 2025 reach $16,550 per violation, with willful or repeated violations up to $165,514. Full breakdown: OSHA Hearing Conservation Violations: Penalties and Citations.
Inspection prep: What OSHA Inspectors Look For · Navigating OSHA Inspections: A Guide for Safety Managers
The single best defense in an OSHA hearing conservation inspection is a complete, time-stamped digital record trail—inspectors cannot cite what they cannot find evidence of missing.
| Approach | Typical Annual Cost / Employee | Key Trade-offs |
|---|---|---|
| Mobile van (outsourced) | $80–$150 | No equipment investment; scheduling disruption; delayed STS data |
| In-house (digital platform) | $30–$60 | Upfront equipment cost; faster STS detection; better recordkeeping control |
The ROI case extends beyond OSHA fines. Workers’ compensation claims for occupational hearing loss average $24,000 per claim. Proactive STS detection and early intervention reduces claim frequency. Related reading:
Employers switching from outsourced mobile van testing to in-house digital testing typically see 40–60% cost reduction per employee within the first year, with break-even reached in 12–18 months for sites with 50+ enrolled employees.
An OSHA hearing conservation program is a written, site-specific set of policies and procedures required under 29 CFR 1910.95 that protects workers from occupational noise-induced hearing loss. It must include six elements: noise monitoring, audiometric testing, hearing protection, training, recordkeeping, and access to information. The program is required whenever any employee's noise exposure equals or exceeds 85 dBA as an 8-hour TWA.
General industry employers must have a hearing conservation program under 29 CFR 1910.95 whenever any employee is exposed to noise at or above 85 dBA as an 8-hour TWA. Construction is covered by the less prescriptive 29 CFR 1926.52. Mining falls under MSHA rather than OSHA.
The six required elements are: (1) noise monitoring to identify exposed employees, (2) audiometric testing including baseline and annual audiograms, (3) hearing protection devices provided at no cost, (4) annual employee training, (5) recordkeeping for noise measurements and audiograms, and (6) access to information including employee notification of results.
OSHA's action level under 29 CFR 1910.95 is 85 dBA as an 8-hour TWA. When any employee's exposure reaches or exceeds this level, the full hearing conservation program must be implemented. The PEL is 90 dBA TWA, above which engineering controls are required and hearing protection becomes mandatory.
A baseline audiogram must be conducted within 6 months of an employee's first exposure at or above the 85 dBA action level. Annual audiograms are required every 12 months for all enrolled employees. A confirmed STS may require additional follow-up audiograms.
A standard threshold shift is a change in hearing threshold of 10 dB or more, averaged across 2000, 3000, and 4000 Hz in either ear, relative to the baseline. A confirmed STS may be recordable on the OSHA 300 log. The employer must notify the employee within 21 days, refit hearing protection, retrain on HPD use, and consider audiologist referral.
Noise exposure measurements must be kept for at least 2 years. Audiometric test records must be kept for the duration of each employee's employment. OSHA 300 log entries for recordable STS cases must be kept for 5 years. Records must include employee name, job classification, audiogram date, examiner name, audiometer serial number, calibration date, and most recent noise exposure assessment.
Not as a first line of defense above the PEL. Under 29 CFR 1910.95(b)(1), employers must use feasible engineering or administrative controls to reduce exposures to the PEL. Hearing protection is required as a supplement when controls cannot reduce noise to the PEL, and must be used by all employees above the PEL regardless of whether engineering controls are also in place.
Soundtrace replaces paper logs, mobile vans, and spreadsheet STS tracking with one digital platform—audiometric testing, fit testing, noise monitoring, training, and recordkeeping in one place.
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