When OSHA announces a Regional Emphasis Program for occupational noise, employers in targeted industries should treat it as notice that proactively scheduled inspections are coming. Under OSHA 1910.95, citations found during programmed REP inspections carry the same penalty structure as complaint-triggered inspections. According to CDC/NIOSH, approximately 22 million U.S. workers face hazardous noise annually, justifying OSHA's sustained enforcement focus.
OSHA Region 3 Mid-Atlantic Noise REP
OSHA Region 3 (Pennsylvania, Delaware, Maryland, Virginia, West Virginia, DC) has renewed its Regional Emphasis Program for occupational noise in manufacturing. The program targets employers in industries with documented high NIHL rates and significant 1910.95 citation history. Employers in the region in wood products, paper, metals, and food processing should treat the REP announcement as a preparedness trigger.
What Inspectors Check Under a Noise REP
REP inspections follow the standard 1910.95 protocol: noise monitoring records, audiometric test records for all enrolled workers, training documentation, HPD availability and adequacy records, and walkthrough observation of HPD use. The inspector arrives without a specific complaint — they check the entire program systematically.
| Inspection Area | What Inspectors Look For | Common Citations |
|---|---|---|
| Audiometric records | Current annual audiogram for every enrolled worker within 12-month window | 1910.95(g)(5)/(g)(6) — late baselines/annuals |
| Noise monitoring | Current survey for all work areas; re-monitoring after process changes | 1910.95(d) — inadequate monitoring |
| Training records | Annual training documentation for all enrolled workers | 1910.95(k) — missing training |
| HPD availability | Variety available; documentation of distribution | 1910.95(i) — inadequate HPD program |
Preparing Before an Inspector Arrives
The preparation checklist: confirm all enrolled workers have current audiograms within their individual 12-month windows, verify noise monitoring is current, confirm training records are complete for the past 2 years, ensure HPD variety is available and attenuation is documented, and confirm audiometric records can be produced within 15 working days. Address any gaps before the REP period peaks. See: most common OSHA hearing conservation citations 2026.
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