OSHA 1910.95(e): Employee Notification of Noise Monitoring Results

OSHA 1910.95 contains two distinct employee notification requirements that are frequently confused or conflated: the noise monitoring notification under 1910.95(e), and the standard threshold shift notification under 1910.95(g)(8). They address different information, carry different obligations, and involve different timelines. The 1910.95(e) notification requirement applies when noise monitoring is conducted — it obligates the employer to notify affected employees of the monitoring results and to provide access to monitoring records. This guide explains exactly what 1910.95(e) requires, who qualifies as an affected employee, what method of notification satisfies the standard, and what records the employer must maintain and make available.

Soundtrace documents noise monitoring results in the cloud portal, enabling employers to demonstrate that affected employees have access to their monitoring data as required by 1910.95(e) and 1910.95(m).

What Triggers the 1910.95(e) Requirement

The notification obligation under 1910.95(e) is triggered whenever the employer conducts noise monitoring under 1910.95(d). Monitoring is required when there is reason to believe that any employee’s exposure may equal or exceed the action level of 85 dBA TWA. Once monitoring is conducted, the employer must notify affected employees of the results and must make the records accessible to them.

This obligation applies to each monitoring event — not just the initial survey. If noise conditions change materially (new equipment, process changes, facility layout modifications), additional monitoring may be required, and each monitoring event triggers the notification obligation anew.

Who Qualifies as an Affected Employee

An affected employee under 1910.95(e) is any employee whose noise exposure measurement at or above the action level triggered the monitoring requirement or who was measured at or above 85 dBA TWA during monitoring. This category is broader than the HCP enrollment list — it includes any employee exposed at or above the action level, regardless of whether they currently wear hearing protection or whether they have already been enrolled in the HCP.

Practically, the notification obligation covers:

• All employees enrolled in the HCP (who are enrolled specifically because they are at or above the action level)
• Employees who were measured at or above the action level during a noise survey, even if they haven’t yet been formally enrolled
• Supervisors and engineers who regularly work in areas measured at or above the action level

Acceptable Notification Methods

OSHA does not prescribe a specific format for the 1910.95(e) notification. The standard permits notification by two methods:

• Individual written notification: A written document provided directly to each affected employee stating their measured noise exposure level and the date of measurement. This is the more documentable approach and provides clear evidence of compliance.
• Posting in a conspicuous location: Posting monitoring results in a location accessible to all affected employees — typically the work area where monitoring was conducted, a safety bulletin board, or a breakroom accessible to the affected workers. The posting must be accessible to all affected employees, not just those who happen to see it.

Employee Access to Monitoring Records

In addition to notifying employees of monitoring results, 1910.95(e) requires that employees have access to noise exposure measurement records. Under 29 CFR 1910.1020 (the general access to employee exposure and medical records standard), employees and their designated representatives have a right to access exposure records within 15 working days of a request. Noise monitoring records fall within this access right.

Access to records means that employees can request to view or receive copies of their monitoring records. The employer must respond within 15 working days of a written request and cannot charge unreasonable fees for providing copies.

Record Retention Requirements

OSHA 1910.95(m)(3) requires employers to retain noise exposure measurement records for at least 2 years. This is significantly shorter than the retention requirement for audiometric test records (employment duration plus 30 years), but still requires a systematic record management approach:

1910.95(e) vs. 1910.95(g)(8): Two Separate Requirements

These two notification requirements are frequently conflated but address entirely different obligations:

• 1910.95(e) applies when monitoring is conducted. It tells employees what their noise exposure level is. It involves posting or individual notice of monitoring results, and it applies even to employees who have not yet been enrolled in the HCP.
• 1910.95(g)(8) applies when an STS is confirmed by annual audiogram. It tells enrolled HCP participants that their hearing has changed. It requires written notification within 21 days of the STS determination. It applies only to enrolled HCP participants, not to all monitored employees.

▶ Bottom line: 1910.95(e) is about noise level results; 1910.95(g)(8) is about hearing change. Both require written communication to affected employees, but they are triggered by different events, apply to different populations, and serve entirely different protective purposes.

Frequently asked questions