OSHA 1910.95(m) specifies exactly what information each type of hearing conservation record must contain. Audiometric records that are missing required fields are incomplete under the standard and may be challenged during inspections or workers’ compensation proceedings. This guide lists every required data element for each record type.
Soundtrace captures all required OSHA 1910.95(m) record fields automatically during audiometric testing — eliminating incomplete records before they become citation risk.
OSHA requires six specific data elements in each audiometric test record. A file containing only threshold results without the required administrative fields — examiner name, calibration date, noise exposure measurement — is technically incomplete and citable under 1910.95(m)(2).
Required content: audiometric test records
OSHA 1910.95(m)(2)(ii) specifies six required data elements for each audiometric test record. All six must be present:
- Employee name and job classification
- Date of the audiogram — the date the test was conducted (not the date results were reviewed)
- Examiner’s name — must be a licensed or certified audiometric technician, OHC, audiologist, or physician
- Date of the audiometer’s most recent acoustic calibration — date of the last exhaustive calibration, not the daily biological check
- Employee’s most recent noise exposure measurement — the TWA from the most recent noise monitoring assessment for this employee
- Background sound pressure levels in the audiometric test room — required to verify the test room meets OSHA’s maximum background level requirements
▶ Bottom line: The most commonly missing field is the employee’s most recent noise exposure measurement. This field is required to be present in the audiometric record itself, not just in a separate monitoring file.
Required content: noise exposure monitoring records
OSHA 1910.95(m)(1) requires noise exposure measurement records to be retained for at least 2 years. These records must document: date of measurement; work area or operation monitored; sampling method (personal dosimetry or area monitoring); number and names of employees monitored; instruments used (make, model, serial number); calibration records for the instruments used; individual employee exposure results (TWA and dose percentage); and HCP enrollment determination resulting from the monitoring data.
▶ Bottom line: Noise monitoring records that summarize area results without individual employee exposure determinations do not satisfy the standard. The record must be traceable to each enrolled employee’s individual exposure assessment.
Required content: audiometer calibration records
| Calibration Type | Frequency | Required Documentation | Retention |
|---|---|---|---|
| Daily biological calibration check | Before each day of testing | Log entry: date, checker name, reference audiogram thresholds, pass/fail result | 2 years |
| Exhaustive acoustic calibration | Annual (or when daily check fails) | Calibration certificate from qualified audiological instrument specialist; frequency-by-frequency results | 2 years |
If the daily biological check reveals results outside ±5 dB of the reference person’s known thresholds, the audiometer must be taken out of service. Any employee tests conducted since the last passing check must be flagged for re-evaluation. Daily calibration logs are among the most frequently missing records during OSHA inspections.
Required content: STS documentation
When an STS is identified, OSHA 1910.95(g)(8) requires documentation of the complete follow-up workflow. At minimum, STS records must capture: date STS was identified and by whom; the baseline and annual audiograms used in the determination; STS calculation results (average shift at 2000, 3000, and 4000 Hz, each ear); whether age correction was applied and the resulting corrected shift; date employee was notified (must be within 21 days of determination); follow-up actions taken; OSHA 300 log recordability determination with supporting rationale; and retest result if a retest was conducted within 30 days.
▶ Bottom line: An STS file that documents detection but not notification date and follow-up actions is incomplete. OSHA’s 21-day notification window is a hard deadline, and missing it is a separate citable element from the STS detection itself.
Best practice: training and HPD records
While OSHA 1910.95 does not specify a minimum retention period for training records, they are routinely requested during inspections. Best practice training records include: employee name; date of training; training topics covered (aligned with 1910.95(k) content requirements); trainer name or training platform; employee signature or electronic acknowledgment. Retain training records for the duration of employment plus 3 years.
▶ Bottom line: Training records have no explicit retention period under 1910.95 — but their absence is treated as evidence training did not occur.
Frequently asked questions
Every required field. Captured automatically. Always audit-ready.
Soundtrace captures all six OSHA 1910.95(m)(2)(ii) audiometric record fields at the point of testing, links calibration records to each test, and stores everything in a searchable digital platform.
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