What Information Must Be Included in the Records for a Hearing Conservation Program?

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 — what you must capture, where to find it in the standard, and why each field matters.

Soundtrace captures all required OSHA 1910.95(m) record fields automatically during audiometric testing — eliminating incomplete records before they become citation risk.

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 — the standard does not allow partial records:

• Employee name and job classification: Full name and the job title or classification that places the employee in the noise-exposed category
• Date of the audiogram: The date the test was conducted (not the date results were reviewed or signed)
• Examiner’s name: The name of the person who administered the test; must be a licensed or certified audiometric technician, occupational hearing conservationist, audiologist, or physician
• Date of the audiometer’s most recent acoustic calibration: The date of the last exhaustive calibration by a qualified instrument specialist — 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: The ambient noise levels in the testing environment, 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 links the audiometric record to the noise monitoring program and 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 of employees monitored and their names or identifiers
• Instruments used (make, model, serial number)
• Calibration records for the instruments used
• Individual employee exposure results (TWA and dose percentage)
• 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

OSHA 1910.95(h) establishes two calibration requirements, each with its own documentation:

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 on that audiometer since the last passing check must be flagged for re-evaluation.

▶ Bottom line: Daily biological calibration logs are among the most frequently missing records during OSHA inspections. A calibration log that shows no entries is treated as evidence that calibration was not performed — making all results from that audiometer potentially challengeable.

Required content: STS documentation

When a Standard Threshold Shift 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 under Appendix F, and the resulting corrected shift
• Date employee was notified (must be within 21 days of determination)
• Follow-up actions: HPD re-evaluation, referral to audiologist or physician, or determination that no referral was necessary with rationale
• OSHA 300 log recordability determination with supporting rationale
• 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 and treated as evidence that training did or did not occur. 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 used
• Employee signature or electronic acknowledgment

Hearing protection selection and fit records should document: which HPD was assigned or selected for each noise-exposed employee, the NRR of the assigned device, whether NRR was de-rated for actual attenuation, and any fit test or PAR results if quantitative fit testing was conducted.

▶ Bottom line: Training records have no explicit retention period under 1910.95 — but their absence is treated as evidence training did not occur. Retain them for the duration of employment plus 3 years as protection against late-filed claims and enforcement actions.

Frequently asked questions