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OSHA’s hearing test requirements aren’t complicated, but they have more moving parts than most summaries capture. Who needs testing, how soon, how often, who reviews the results, what triggers action, and how long records must be kept — this guide covers every requirement under 29 CFR 1910.95(g) in a single reference.
Soundtrace automates the entire OSHA audiometric testing workflow — baseline scheduling, annual retesting, STS detection, professional supervisor review, employee notification, and 30-year records retention — without a sound booth.
OSHA 1910.95(g)(1) requires that audiometric testing be made available to all employees whose noise exposures equal or exceed the action level of 85 dBA as an 8-hour time-weighted average. This determination is made through noise exposure monitoring — the assessment that precedes enrollment.
The standard uses the phrase “make available” which includes both providing the testing and doing so at no cost to the employee. Employees must be offered the audiogram — they cannot be required to pay for it, schedule it themselves, or travel to off-site testing on their own time without compensation.
There is no industry exemption: the 1910.95 hearing conservation standard applies to all general industry employers with action-level exposures. Agricultural, construction, and maritime workers have separate or partially separate coverage, but the core audiometric testing requirements are similar.
▶ Bottom line: Every employee with measured exposure at or above 85 dBA TWA must be offered audiometric testing at no cost to them. The cost is an employer obligation, not a shared expense or employee benefit.
The baseline audiogram is the most important audiogram in the surveillance program — it establishes the reference point against which all subsequent changes are measured. OSHA’s requirements for baseline audiograms:
Timing: Must be established within 6 months of first qualifying noise exposure. Exception: if mobile van testing is the only method available to the employer, the baseline must be established within 1 year. During the interval between first exposure and baseline establishment, the employer must make hearing protectors available.
Quiet period: The employee must have been away from workplace noise (and ideally all significant noise) for at least 14 hours before the baseline audiogram. This requirement ensures that temporary threshold shift has resolved and that the baseline reflects stable, resting thresholds rather than an acute post-exposure dip. Hearing protectors may be used as a substitute for the quiet period, though the 14-hour removal is strongly preferred for baseline accuracy.
Baseline revision: The professional supervisor may replace (revise) the baseline with a later audiogram if: the later audiogram shows significant improvement compared to the original baseline, or if an STS is confirmed as persistent and represents a permanent shift. Revised baselines reset the comparison point for future STS calculations. The decision to revise is a clinical judgment made by the professional supervisor, not an automatic process.
▶ Bottom line: An inaccurate baseline — obtained without the 14-hour quiet period or from an employee experiencing temporary threshold shift — compromises every subsequent STS calculation for that employee’s entire tenure. The baseline is worth getting right.
OSHA 1910.95(g)(6) requires an annual audiogram for every enrolled employee. “Annual” means within 12 calendar months of the previous audiogram — it does not mean once per calendar year applied uniformly. Key requirements:
The 12-month window runs from each individual’s previous test date, not from a common program anniversary. A large employer with 500 enrolled employees will typically have tests distributed throughout the calendar year. Systems that track individual test anniversary dates — rather than scheduling all employees for a single annual testing event — avoid the situation where employees who joined late in the cycle go 14+ months between tests.
A Standard Threshold Shift is a change in hearing threshold, relative to the baseline audiogram, of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. When an annual audiogram shows an apparent STS, the following obligations are triggered:
Optional retest within 30 days: The employer may administer an additional audiogram within 30 days of the annual audiogram showing the STS. If the retest does not confirm the STS, the apparent STS does not need to be used for recording and notification purposes. If the retest confirms the STS, the confirmed STS triggers all subsequent obligations.
Professional supervisor review: The audiogram showing an STS must be reviewed by the professional supervisor before final determination and notification. The supervisor may determine that the STS is related to something other than occupational noise — medication, illness, non-occupational exposure — and make appropriate referrals.
Age correction option: The employer may apply OSHA Appendix F age correction values to the audiogram before STS determination. If the age-corrected shift is less than 10 dB, the adjusted STS may not trigger the recordability criteria (though the 1910.95 follow-up obligations may still apply based on uncorrected results depending on program policy).
▶ Bottom line: The STS determination is a two-step process: audiometric measurement by a technician, followed by clinical review and determination by the professional supervisor. The supervisor’s determination, not the raw threshold numbers, triggers the notification clock.
OSHA 1910.95(g)(8)(ii) requires that when a confirmed STS is found, the employer must notify the employee in writing within 21 days of the determination. The notification must inform the employee of the STS finding. Additional requirements triggered by a confirmed STS:
OSHA 1910.95(g)(1) and (g)(7) establish the professional supervisor requirement: audiometric testing must be “administered” within the oversight of a licensed or certified audiologist, otolaryngologist, or other physician. The supervisor is responsible for:
A CAOHC-certified OHC can conduct the audiometric tests — place the headphones, administer tones, record thresholds. But OHC certification does not authorize the technician to make clinical determinations about STS findings, baseline revisions, or referral decisions. Programs without an actively involved licensed audiologist or physician as professional supervisor are not compliant regardless of technician qualifications.
OSHA Appendix D specifies maximum permissible ambient noise levels in audiometric test rooms. The ambient noise in the test environment must not exceed levels that would cause more than 2 dB of threshold shift at the lowest tested frequencies under standard audiometric conditions.
Traditional sound booths achieve these ambient noise levels through acoustic isolation. Modern digital programs achieve equivalent results using circumaural headsets with validated high-attenuation properties (such as the RadioEar DD65V2) combined with real-time ambient noise monitoring that confirms the attenuation achieved exceeds the Appendix D criteria at each test frequency. When ambient noise during a specific test event exceeds the criteria for a given frequency, that frequency result must be flagged as potentially invalid.
OSHA requires audiometric testing instruments to meet ANSI S3.6-1969 specifications. Calibration requirements include:
Calibration records must be retained as part of the audiometric testing record — OSHA 1910.95(m)(2)(vi) specifically requires that audiometric test records include “the date of the last acoustic or exhaustive calibration of the audiometer.”
OSHA 1910.95(m)(2) requires that audiometric test records be maintained for the duration of the affected employee’s employment plus 30 years. Records must include:
Records must be made available to employees, former employees, and their authorized representatives. They must also be accessible to OSHA compliance officers during inspections and must be transferred to successor employers upon business sale or closure.
The employer pays for all aspects of the audiometric testing program. This includes the audiometric test itself, the professional supervisor’s review fees, any required follow-up testing (such as the 30-day retest after an apparent STS), and the records management system. OSHA’s interpretation of “make available” in 1910.95(g)(1) is that audiometric testing must be provided at no cost to the employee as a condition of employment in a qualifying noise-exposed role.
Tests must be offered during normal working hours wherever feasible — an employer who schedules audiometric testing only outside of work hours without appropriate compensation creates a practical barrier that OSHA may view as failing the “make available” standard.
Soundtrace handles every 1910.95(g) requirement — baseline scheduling, annual retesting, STS detection, professional supervisor review, employee notification, and 30-year records retention — without a sound booth.
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