OSHA Recordkeeping Requirements and How Soundtrace Ensures Compliance

OSHA 1910.95(m) sets specific recordkeeping requirements for every element of the hearing conservation program — and the retention periods vary by record type. Noise exposure records must be kept for 2 years. Audiometric records must be kept for the duration of employment. Both must be available to employees, former employees, and OSHA upon request. This guide covers exactly what must be kept, for how long, in what format, and what OSHA inspectors look for when they review your records.

Soundtrace manages all OSHA 1910.95(m) recordkeeping requirements in a single HIPAA-compliant platform — noise monitoring data, audiometric records, STS documentation, and training completion records — with employee access portals and audit-ready export at any time.

Noise exposure monitoring records

OSHA 1910.95(m)(1) requires employers to retain noise exposure measurement records for at least 2 years. Each record must include:

• Date of measurement
• Work area or operation monitored
• Sampling method (personal dosimetry or area monitoring)
• Number of employees monitored and their names or identifiers
• Instruments used (make, model, serial number)
• Calibration records for instruments used
• Individual employee exposure results (TWA and dose percentage)
• HCP enrollment determination resulting from the monitoring data

▶ Bottom line: Noise monitoring records that contain only summary data without individual employee exposure determinations do not satisfy the recordkeeping requirement. Each enrolled employee needs an individual exposure record that forms the basis for their program enrollment.

Audiometric testing records

OSHA 1910.95(m)(2) requires audiometric records to be retained for the duration of the employee’s employment. Each record must include:

• Employee name and job classification
• Date of the audiogram
• Examiner’s name
• Date of last audiometer calibration
• Employee’s most recent noise exposure assessment (TWA)
• Test results (threshold levels at each test frequency, each ear)

The baseline audiogram must be retained in full — it is the permanent reference point for all future STS calculations. The complete audiometric history (baseline + every annual) must be maintained, not just the most recent test.

▶ Bottom line: Retaining only the most recent annual audiogram is a recordkeeping violation. The entire audiometric history for every enrolled employee must be preserved for the duration of their employment.

Training and HPD records

While OSHA 1910.95 does not specify a retention period for training records, they are subject to OSHA’s general inspection authority and are routinely requested during hearing conservation inspections. Best practice is to retain training records for the duration of employment plus 3 years. Training records should document: employee name, date of training, topics covered, trainer name or platform used, and employee signature or electronic acknowledgment.

Hearing protection selection records — documentation that specific HPDs were evaluated for adequacy at each employee’s exposure level — should also be maintained. These records support the employer’s defense in workers’ compensation proceedings and OSHA enforcement actions.

▶ Bottom line: Training records are not explicitly required to be retained under 1910.95, but their absence during an inspection is treated as evidence that training did not occur. Retain them as if they were required.

STS documentation

When an STS is identified, the following must be documented: the date the STS was identified, the audiograms used in the determination (baseline and triggering annual), the STS calculation results (dB shift at 2k/3k/4k Hz, each ear), the date of employee notification (must be within 21 days), the follow-up actions taken (HPD re-evaluation, referral, age correction determination), and the OSHA 300 log recordability determination with supporting rationale.

▶ Bottom line: STS documentation must demonstrate a complete workflow — detection, calculation, notification, follow-up, and recordability determination. Missing any element exposes the employer to citations under 1910.95(g)(8).

Employee access rights

OSHA 1910.95(l) gives employees, former employees, and their designated representatives the right to access monitoring results and audiometric test records. The employer must provide access within 15 working days of a written request. Records must be provided in a format that the employee can understand.

▶ Bottom line: The 15-working-day access window is a hard deadline. A late or denied response is a standalone citable violation under 1910.1020, independent of any other citations the inspection may produce.

Digital vs. paper recordkeeping

OSHA does not require digital records — paper systems are technically compliant. But paper-based hearing conservation recordkeeping has structural failure modes at scale: records get misfiled or lost during facility moves and staff transitions, STS calculations require manual comparison of paper audiograms that is frequently skipped, and producing a complete audiometric history during an OSHA inspection is operationally difficult. Digital platforms with automated STS calculation, individual testing due-date tracking, and on-demand record export eliminate all of these failure modes.

▶ Bottom line: Paper records can satisfy the letter of 1910.95(m) on the day they are created. Digital records satisfy it on every day of the retention period — accessible, undamaged, and available for the access requests, STS calculations, and litigation discoveries that may occur at any point during that window.

Frequently asked questions