OSHA Hearing Conservation Program Requirements: The 6 Required Elements

What it requires: Employers must monitor noise exposures whenever information indicates employee exposures may equal or exceed the action level. Monitoring must be representative of each employee’s actual exposure — including all continuous, intermittent, and impulsive noise between 80 and 130 dB.

Method: Personal dosimetry (preferred for workers who move through multiple noise environments) or area monitoring combined with time-motion analysis. ANSI S1.25-compliant dosimeters required.

Re-monitoring triggers: Any significant change in production processes, equipment, or controls that may increase noise exposure levels requires a new noise survey.

Employee notification: Employees whose exposures are at or above the action level must be notified of their exposure results.

Baseline audiogram: Required within 6 months of first exposure at or above the action level. A 1-year exception applies for mobile testing programs if HPDs are worn from day one. Must be preceded by 14 hours free of hazardous noise exposure.

Annual audiogram: Required within 12 months of the prior test. Each employee’s 12-month cycle runs from their individual test date, not a facility-wide calendar date.

STS determination: Every annual audiogram must be compared to the baseline at 2,000, 3,000, and 4,000 Hz. A 10 dB or greater average shift triggers employer action within 21 days: written notification, HPD re-evaluation, and potential medical referral.

Cost: All audiometric testing must be provided at no cost to the employee.

Availability: Employers must make a variety of HPDs available at no cost. At minimum: foam earplugs, reusable plugs, and earmuffs.

Mandatory use: At or above the PEL (90 dBA TWA), HPD use is mandatory. Between 85 and 90 dBA, HPDs must be available but use is not yet mandatory.

Adequacy: The selected HPD must attenuate the employee’s exposure to at least 90 dBA or below. For employees who have experienced an STS, to 85 dBA or below.

Frequency: At least annually for all enrolled employees. New employees must be trained at the time of initial assignment to a noise-hazardous role.

Required topics: Effects of noise on hearing — Purpose, advantages, disadvantages, and attenuation of HPD types — Instructions on HPD selection, fitting, use, and care — Purpose and procedures of audiometric testing

Documentation: Training records must demonstrate completion date, content coverage, and employee acknowledgment. A sign-in sheet without curriculum documentation is insufficient.

Audiometric test records: Retained for the duration of employment. Each record must contain six required fields: (1) employee name and job classification; (2) date of audiogram; (3) examiner’s name; (4) date of last acoustic calibration of the audiometer; (5) employee’s most recent noise exposure assessment; (6) background sound pressure levels in the test room.

Noise exposure monitoring records: Retained for at least 2 years.

OSHA 300 Log: Work-related hearing loss resulting in a 25 dB or greater average shift above audiometric zero at 2k/3k/4k Hz is recordable. Retain for 5 years.

What employees can access: Their own audiometric test records; the results of any noise exposure monitoring in their work area; the OSHA 1910.95 standard and its appendices; and any other occupational exposure records under 29 CFR 1910.1020.

Response timeline: Employee requests for access to records must be fulfilled within 15 working days. Failure to provide records within this window is a separately citable violation under 1910.1020.