OSHA 29 CFR 1910.95 is one of the most compliance-documentation-intensive standards in OSHA’s general industry portfolio, but its documentation obligations are frequently confused with posting requirements. The standard does not require a hearing-conservation-specific poster to be displayed in the workplace. What it requires are records, written notifications, and training — not wall postings. According to CDC/NIOSH, approximately 22 million U.S. workers face hazardous noise annually, all of whose employers have documentation obligations that are distinct from general OSHA posting requirements.
What OSHA Actually Requires vs. What Employers Often Assume
The confusion between posting requirements and documentation requirements is common in HCP compliance. Here is what each category actually requires:
| Obligation Type | 1910.95 Requirement | Posting? |
|---|---|---|
| Noise monitoring results | Workers must be notified of monitoring results that affect their HCP status | No — written notification to affected workers |
| STS determination | Written notification to worker within 21 days of STS confirmation | No — written notification to individual worker |
| HCP training | Annual training required for all enrolled workers | No — training records maintained |
| OSHA poster | 29 CFR 1903.2 requires “Job Safety and Health” poster at workplace | Yes — general OSHA poster only |
| OSHA 300 log | Must be posted Feb 1–Apr 30 annually (1904.32) | Yes — 300A summary form posted, not 300 log itself |
The OSHA “Job Safety and Health — It’s the Law” poster (OSHA 3165) is required under 29 CFR 1903.2 at all workplaces covered by federal OSHA. This is separate from 1910.95 requirements. State Plan states have their own equivalent posters. Failure to post this poster is a separate citation basis from any 1910.95 violations.
The Written Notification Requirements That Matter
While 1910.95 does not require wall postings, its written notification and communication requirements are specific and auditable:
- Noise monitoring results: Workers must be notified of the results of noise monitoring performed under 1910.95(d) when they may be exposed at or above the action level. This is typically accomplished by providing monitoring data at the time of enrollment in the HCP and when monitoring results change.
- STS notification: Written notification to the individual worker within 21 days of an STS determination. Maintain copies of all notifications in the HCP file.
- Audiometric results: Workers must be provided with the results of their audiometric tests.
The OSHA 300A Summary of Work-Related Injuries and Illnesses must be posted in a conspicuous location from February 1 through April 30 each year. If any work-related hearing loss cases were recorded on the 300 log during the prior calendar year, they will appear in the 300A totals. This is not an HCP posting requirement — it is a separate recordkeeping requirement under 29 CFR 1904.32.
Frequently Asked Questions
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