OSHA Hearing Test Requirements: The Complete Compliance Reference for Employers

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.

Who Is Required to Receive Hearing Tests

OSHA 1910.95(g)(1) requires audiometric testing for all employees whose noise exposures equal or exceed the action level of 85 dBA TWA. The standard requires employers to make testing available at no cost to employees — including during normal working hours wherever feasible.

▶ Bottom line: Every employee with measured exposure at or above 85 dBA TWA must be offered audiometric testing at no cost to them.

Baseline Audiogram Requirements

Must be established within 6 months of first qualifying noise exposure (12 months if mobile van is the only available method). The employee must have 14 hours free from workplace noise before the test. The professional supervisor may revise the baseline if a later audiogram shows significant improvement, or if an STS is confirmed as persistent.

▶ Bottom line: An inaccurate baseline compromises every subsequent STS calculation for that employee’s entire tenure. The baseline is worth getting right.

Annual Audiogram Requirements

OSHA 1910.95(g)(6) requires an annual audiogram for every enrolled employee — within 12 calendar months of the previous audiogram, not once per calendar year applied uniformly. Each annual audiogram must be compared to the baseline to detect STSs. If an apparent STS is found, a retest may be conducted within 30 days to confirm the finding.

Standard Threshold Shift: The Trigger for Required Action

An STS is a change in hearing threshold, relative to baseline, of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. When found, the employer may administer a retest within 30 days to confirm. If confirmed, the professional supervisor reviews for clinical determination, age correction may be applied under Appendix F, and all follow-up obligations are triggered.

▶ Bottom line: The STS determination requires clinical review by the professional supervisor. The supervisor’s determination, not the raw numbers, triggers the notification clock.

Notification Requirements After an STS

When a confirmed STS is found, the employer must notify the employee in writing within 21 days of the determination. The employee must be refitted with hearing protectors offering greater attenuation if the current protection is determined inadequate. The STS must be evaluated for OSHA 300 recordability under 29 CFR 1904.10.

Professional Supervisor Requirements

A licensed or certified audiologist, otolaryngologist, or physician must serve as professional supervisor. The supervisor reviews audiograms for STS determination, makes baseline revision decisions, determines work-relatedness of STSs, identifies patterns requiring medical referral, and provides clinical oversight of the program. A CAOHC-certified OHC can conduct tests but cannot make clinical determinations — programs without an actively involved licensed supervisor are not compliant.

Test Environment Requirements

OSHA Appendix D specifies maximum permissible ambient noise levels in audiometric test rooms. Traditional sound booths achieve these through acoustic isolation. Modern digital programs use circumaural headsets with validated high-attenuation properties and real-time ambient noise monitoring to meet equivalent criteria without a booth.

Equipment Calibration Requirements

Audiometric testing instruments must meet ANSI S3.6-1969 specifications. Required: acoustic calibration at least annually; exhaustive calibration at least every 2 years or after repair; daily listening check before each testing day. Calibration records must be retained as part of the audiometric record.

Records Retention Requirements

OSHA 1910.95(m)(2) requires audiometric test records for the duration of employment plus 30 years. Records must include: employee name and job classification; date of audiogram; examiner’s name; date of last audiometer calibration; employee’s most recent noise exposure measurement; and background sound pressure levels in the test room. Records must be accessible to employees, OSHA compliance officers, and must be transferred to successor employers upon business sale.

Who Pays for Hearing Tests

The employer pays for all aspects of the audiometric testing program. Testing must be offered at no cost to employees as a condition of employment in a qualifying noise-exposed role. Tests must be offered during normal working hours wherever feasible.