Recordkeeping is not the most glamorous part of an OSHA hearing conservation program — but it is the part most likely to generate citations during an inspection. OSHA 1910.95(m) specifies exactly what records must be kept, how long they must be retained, and what access rights employees have to their own records. This guide covers every recordkeeping requirement in plain language.
Soundtrace automatically generates and stores all OSHA-required hearing conservation records — noise monitoring data, audiometric test results, STS determinations, and calibration logs — in a centralized digital system with built-in access controls and audit trails.
OSHA requires two types of hearing conservation records: noise exposure measurements (kept 2 years) and audiometric test records (kept for the duration of employment). Employees have the right to access their own records within 15 working days of a request.
What records must be kept
OSHA 1910.95(m) requires employers to maintain two categories of hearing conservation records: noise exposure measurement records and audiometric test records. Both categories have distinct content requirements, retention periods, and employee access rights.
Retention periods
| Record Type | Minimum Retention | OSHA Reference | Practical Note |
|---|---|---|---|
| Noise exposure measurements | 2 years | 1910.95(m)(1) | Each monitoring event has its own 2-year clock |
| Audiometric test records | Duration of employment | 1910.95(m)(2) | Baseline + every annual must be retained |
| Audiometer calibration records | Duration of audiometer use | Appendix E | Ties the test result to a validated instrument |
| Background noise level measurements | Duration of audiometer use | Appendix D | Required field in each audiometric record |
For a worker employed for 30 years, the employer must retain their audiometric records for all 30 years. Digital records management is the only sustainable approach at any meaningful workforce scale. Paper files do not scale to this obligation.
Required content for each audiometric record
Under OSHA 1910.95(m)(2), each audiometric test record must include all seven of the following fields. Records that omit any field are incomplete and may be challenged during inspection or WC litigation.
- Name and job classification of the employee
- Date of the audiogram
- Name and title of the person who conducted the test
- Date of the last acoustic calibration of the audiometer
- Employee’s most recent noise exposure measurement
- Background sound pressure levels in the audiometric test room
- Audiometric threshold results for each ear at each tested frequency (500, 1000, 2000, 3000, 4000, 6000 Hz)
▶ Bottom line: A record that contains only threshold results without the other required administrative fields is incomplete under 1910.95(m)(2) and may be challenged during inspection or litigation.
Employee access rights
OSHA 1910.95(l) and 29 CFR 1910.1020 together establish employees’ rights to access their hearing conservation records. An employee has the right to access their own audiometric test records within 15 working days of written request, access their noise exposure measurement records, and designate a representative to access records on their behalf.
This right extends to former employees. An employer who cannot produce records for a departed worker loses a key element of their defense in occupational hearing loss claims.
The 15-working-day response deadline is a hard requirement. Denying or delaying access is an independently citable violation under 1910.1020. Build a process now for handling employee record requests — including from former employees — before a request arrives during active litigation.
Record transfer and business closure
If an employer sells or transfers the business, OSHA requires that audiometric and noise monitoring records be transferred to the successor employer, who assumes the retention obligation. If no successor employer exists and the business is closing, the employer must notify NIOSH at least 3 months before closure for disposition instructions.
▶ Bottom line: Records obligations do not end when the business changes hands. Ensure record transfer is explicitly addressed in any acquisition or closure agreement.
Frequently asked questions
Every record, always audit-ready
Soundtrace stores all OSHA-required hearing conservation records digitally — audiograms, noise monitoring data, calibration logs, and STS determinations — with employee-level access controls and full audit trails.
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