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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.
OSHA 1910.95(m) requires employers to maintain two categories of hearing conservation records:
▶ Bottom line: Two categories, two retention periods, one compliance obligation. Both must be maintained in a way that allows retrieval on request from OSHA inspectors or employees.
| Record Type | Minimum Retention Period | OSHA Reference |
|---|---|---|
| Noise exposure measurements | 2 years | 1910.95(m)(1) |
| Audiometric test records (baseline + all annuals) | Duration of employment | 1910.95(m)(2) |
| Audiometer calibration records | Duration of use of the audiometer | Appendix E |
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.
▶ Bottom line: Noise monitoring records have a 2-year shelf life. Audiometric records are permanent — they must be on file for every year of every enrolled employee’s tenure.
Under OSHA 1910.95(m)(2), each audiometric test record must include:
▶ Bottom line: A record that contains only threshold results without the required administrative fields is incomplete under 1910.95(m)(2) and may be challenged during inspection or litigation.
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.
▶ Bottom line: The 15-working-day response deadline is a hard requirement. Denying or delaying access is an independently citable violation under 1910.1020.
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.
OSHA does not require paper records. Digital records are fully compliant provided they are retrievable, accurate, and accessible to employees upon request.
Lost records are a recordkeeping violation. The employee needs a new baseline audiogram since STS cannot be calculated without the reference record. Document the circumstances and conduct a new baseline as soon as possible.
OSHA 1910.95(m)(2) requires retention for the duration of employment — not just while the employee is in a noise-exposed role. For long-tenured workers this can mean 30–40 years of records per employee.
Yes. Under OSHA 1910.95(l), employees must be given access within 15 working days of a written request. This right extends to former employees.
Records must transfer to any successor employer. If no successor exists, NIOSH must be notified at least 3 months before closure for disposition instructions.
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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