OSHA requires employers to provide audiometric testing to workers exposed at or above the 85 dBA action level under 29 CFR 1910.95. These aren’t optional wellness screenings — they’re legally mandated, must be performed by qualified professionals, and the results must be retained for the duration of employment plus 30 years. Here’s exactly what the standard requires, what a baseline audiogram establishes, and what a standard threshold shift means for your program.
Soundtrace audiometric testing automates the full OSHA testing cycle — baseline and annual scheduling, STS detection and 21-day notification tracking, and 30-year cloud record retention — supervised by a licensed audiologist as part of a complete OSHA 1910.95 hearing conservation program.
Audiometric testing under 1910.95 is not a paperwork exercise. It exists to detect Standard Threshold Shifts early — before hearing loss becomes permanent, compensable, or recordable. A missed STS is a missed intervention opportunity, and a missed notification deadline is a direct citation risk.
The OSHA audiometric testing cycle has five required phases. Each phase has a specific regulatory citation, key deadline, and common compliance failure point.
The 21-day STS notification clock runs from the determination date (when the professional supervisor confirms the STS), not the audiogram date. Professional review delays directly create missed-deadline citation exposure.
Automate STS Tracking and OSHA Audiogram Recordkeeping
Soundtrace automatically flags standard threshold shifts, applies age correction calculations, generates the required employee notifications, and keeps every audiogram record audit-ready — across every facility in your program.
See How It Works →Who Must Be Tested
Any employee whose noise exposure equals or exceeds 85 dBA as an 8-hour TWA must be enrolled in the hearing conservation program and provided audiometric testing at no cost. Enrollment is determined by noise monitoring results under 1910.95(d) — not by job title, industry, or the employer’s estimate. Workers in the same facility may have different enrollment status depending on their specific area and duties.
The employer bears the cost of testing. Tests scheduled outside normal work hours must be compensated. An employee self-referring to an audiologist does not satisfy the employer’s obligation — the program must be employer-administered with documented results.
▶ Bottom line: If noise monitoring shows any worker’s 8-hour TWA at or above 85 dBA, that worker must be enrolled and tested. There is no partial enrollment.
The Baseline Audiogram
The baseline audiogram under 1910.95(g)(5) establishes the reference threshold against which all future annual audiograms are compared to detect hearing changes. A valid baseline requires:
- Administration within 6 months of the employee’s first exposure at or above the 85 dBA action level (12 months if mobile van is the only testing method, with HPD use during the gap)
- At least 14 hours of quiet before testing — no occupational noise above 80 dBA, no high-intensity recreational noise
- Testing on a calibrated audiometer meeting ANSI S3.6 specifications
- Test environment meeting ambient noise limits in OSHA Appendix D to 1910.95
- Administration by qualified personnel under 1910.95(g)(3)
Wearing hearing protection during the 14-hour quiet period does not satisfy the requirement. HPDs block air-conducted sound but do not prevent temporary threshold shift (TTS) from occurring in a noisy environment. A baseline conducted after unprotected noise exposure will be artificially elevated, making future STS detection harder and creating legal exposure if challenged. See: Baseline vs. Annual Audiogram.
▶ Bottom line: The baseline audiogram is the most important record in the entire HCP. Every STS determination, workers’ comp apportionment, and causation defense depends on its validity.
Annual Audiogram Requirements
Under 1910.95(g)(6), every enrolled employee must receive an annual audiogram within 12 months of their previous audiogram. Key requirements:
| Requirement | Detail |
|---|---|
| Frequency | Every 12 months — measured audiogram to audiogram, not calendar year |
| Frequencies tested | 500, 1000, 2000, 3000, 4000, and 6000 Hz in each ear |
| Cost | At no cost to the employee |
| Quiet period | Not required (unlike baseline), but recommended |
| Professional review | By audiologist or physician within 30 days (21 days if STS found) |
| Comparison | Each result compared to the baseline audiogram |
Standard Threshold Shift Obligations
A Standard Threshold Shift is an average change of 10 dB or more at 2,000, 3,000, and 4,000 Hz in either ear, compared to the baseline. When an STS is determined, the employer must complete a sequenced response:
- Written notification to the employee within 21 days of the STS determination date (not the audiogram date)
- HPD response: if not wearing HPD, fit and require use; if wearing HPD, refit and retrain, upgrade if current device is inadequate for measured TWA
- Optional 30-day retest: may negate the STS if results do not confirm; does not pause the 21-day notification clock
- OSHA 300 Log evaluation: if STS is confirmed and total hearing level ≥25 dB HL and work-related, record on 300 Log under 29 CFR 1904.10
- Baseline revision consideration: PS may revise baseline if STS is confirmed as permanent
The 21-day notification deadline runs from the determination date — the date the PS or audiologist confirms the STS — not the date of the audiogram. Delays in professional review directly create late-notification citation risk. The retest window does not pause the clock.
Who Can Conduct Audiometric Testing
Under 1910.95(g)(3), audiometric testing must be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC) or has demonstrated competence in administering audiometric tests. For microprocessor audiometers that automatically calculate results, OSHA has historically accepted operator demonstrated competence as meeting the technician standard — CAOHC certification is not explicitly required for automated testing systems.
A Professional Supervisor (a licensed audiologist or physician) must be designated to review audiograms, make STS determinations, and authorize referrals. The Professional Supervisor does not need to administer every test, but must be available for clinical review and sign off on flagged results.
Recordkeeping Requirements
Under 1910.95(m)(2), each audiometric test record must contain: the employee’s name and job classification; the date of the audiogram; the examiner’s name and title; the date of the audiometer’s last acoustic calibration; the employee’s most recent noise exposure assessment; and the background sound pressure levels in the audiometric test room. Records must be retained for the duration of employment. See: Audiometric Recordkeeping: Digital vs. Paper for why missing any of these required fields is a standalone citation.
The 5 Most Common Audiometric Testing Compliance Gaps
| # | Gap | Citation Reference |
|---|---|---|
| 1 | Baseline completed after the 6-month window without documented exception | 1910.95(g)(5)(i) |
| 2 | 14-hour quiet period not verified or documented before baseline testing | 1910.95(g)(5)(ii) |
| 3 | Annual audiogram completed more than 12 months after the prior audiogram | 1910.95(g)(6) |
| 4 | STS identified but employee not notified within 21 days of determination | 1910.95(g)(8)(i) |
| 5 | Audiometric record missing the employee’s most recent noise exposure assessment | 1910.95(m)(2)(i)(E) |
An STS occurs when a worker’s hearing in either ear shifts 10 dB or more (averaged across 2,000, 3,000, and 4,000 Hz) compared to their baseline audiogram. When an STS is recorded:
- The employer must notify the employee in writing within 21 days
- The employer must determine if the STS is work-related
- If work-related, it may need to be recorded on OSHA Form 300
- Hearing protector adequacy must be re-evaluated
- Retraining and refitting may be required
Age correction factors under Appendix F of 1910.95 can be applied to determine if the shift is attributable to occupational noise vs. natural aging.
Frequently Asked Questions
Any employee whose 8-hour TWA noise exposure equals or exceeds 85 dBA must be enrolled in the hearing conservation program and provided audiometric testing at no cost. Enrollment is determined by noise monitoring results — not job title or industry.
OSHA 1910.95(g)(5) requires a baseline audiogram within 6 months of first exposure at or above 85 dBA, preceded by 14 hours of quiet. Employers using mobile vans have 12 months but must provide HPD during the gap and document compliance.
A 10 dB or greater average change at 2,000, 3,000, and 4,000 Hz in either ear compared to the baseline audiogram. This triggers written employee notification within 21 days, HPD refitting or upgrade, retraining, and evaluation for OSHA 300 log recordability.
OSHA 1910.95(m)(2) requires retention for the duration of the employee’s employment. Most occupational health attorneys recommend 30 years beyond termination given the latency of occupational hearing loss claims.
Automate STS Tracking and OSHA Audiogram Recordkeeping
Soundtrace automatically flags standard threshold shifts, applies age correction calculations, generates the required employee notifications, and keeps every audiogram record audit-ready — across every facility in your program.
See How It Works →- OSHA Hearing Conservation Program: The Complete Guide
- Audiometric Testing for Employers: Complete OSHA 1910.95 Guide
- Standard Threshold Shift: Definition, Calculation & Action Steps
- Comparing Baseline and Annual Audiograms: OSHA Guide
- Audiometric Recordkeeping: Digital vs. Paper
- Workers’ Compensation for Occupational Hearing Loss: 50-State Guide