Industry News (OSHA, ASA, etc.)
Industry News (OSHA, ASA, etc.)
March 17, 2023

Why OSHA Hearing Loss Numbers Miss the Real Problem

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Why OSHA Hearing Loss Numbers Miss the Real Problem

Short answer: OSHA hearing loss statistics track paperwork thresholds, not actual hearing decline. As a result, most occupational hearing loss goes undetected until it becomes permanent and expensive.

From 2022 to 2024, the average number of hearing loss cases reported to OSHA has hovered around 11,000 to 12,000 per year. 2025 data is still pending.

Hearing Loss Injuries by Year per OSHA Reported Data

That number looks stable. It also has very little correlation to what is actually happening to hearing health in the American workforce.

The problem is not that hearing loss is rare.
The problem is that the way we measure it hides the damage.

Why OSHA Hearing Loss Data Is Misleading

Answer: OSHA recordable hearing loss relies on changes from a baseline audiogram, which resets when employees change jobs. In a high-turnover workforce, this masks cumulative hearing damage.

OSHA hearing loss is recorded only when an employee experiences a Standard Threshold Shift compared to their baseline audiogram. That system assumes long-term employment and stable baselines.

That assumption no longer matches reality.

In high-turnover industries, which now describes most of the U.S. economy, workers frequently receive a new baseline every few years. They often arrive with hearing that is already slightly degraded. Their hearing declines further, but not enough to trigger a recordable shift. Then they move to a new job, get a new baseline, and the cycle repeats.

By the time they retire, they have no OSHA hearing loss injuries on record. Yet their hearing has gone from normal to poor.

As Matt Reinhold, COO of Soundtrace, puts it,
“Baseline resets don’t mean hearing is protected. They just reset the scoreboard.”

Does OSHA Compliance Prevent Hearing Loss?

Answer: No. OSHA compliance ensures documentation, not prevention.

The standard approach to hearing conservation today is simple. Conduct annual hearing tests. Review STSs. File the records. Revisit the program next year.

That process satisfies regulatory requirements, but it does little to prevent long-term hearing damage.

Most programs are built to detect problems late, not early. They focus on large threshold shifts that qualify as recordable events, not gradual decline that compounds year after year.

“By the time hearing loss shows up as an STS, the damage is already done,” Reinhold says. “We are measuring failure, not risk.”

What Happens Medically When Hearing Loss Is Ignored?

Answer: Untreated hearing loss increases healthcare costs, cognitive decline risk, and long-term disability.

Hearing loss is not just a safety issue. It is a medical issue with well-documented downstream effects.

Multiple Johns Hopkins studies have shown that individuals with hearing loss generate 46 percent higher employer healthcare costs over a ten-year period. This is not limited to severe hearing loss. Mild hearing loss alone is associated with increased medical utilization.

Another Johns Hopkins study found that mild to moderate hearing loss increases the risk of dementia by three to five times. This level of hearing loss often goes unnoticed and unaddressed in traditional hearing conservation programs.

Later in life, hearing aids routinely cost thousands of dollars out of pocket. Many workers delay treatment because their decline was gradual, normalized, and never framed as an injury.

From a medical perspective, hearing loss behaves like a chronic condition. It progresses quietly, worsens over time, and becomes far more expensive when intervention is delayed.

Why Occupational Hearing Loss Is Likely Underreported

Answer: Hearing damage accumulates gradually, but reporting systems only capture binary events.

Noise exposure is continuous. Hearing decline is incremental. OSHA reporting is not.

When hearing loss is measured only against a moving baseline, most decline never becomes visible. OSHA numbers reflect administrative thresholds, not physiological reality.

As Reinhold explains,
“We have built a system that is very good at proving compliance and very bad at protecting hearing.”

What Hearing Loss Prevention Actually Requires

Answer: Prevention requires early detection, trend analysis, and ongoing monitoring rather than annual snapshots.

True prevention looks very different from annual testing alone. It means identifying hearing changes before they become recordable. It means tracking trends over time rather than waiting for a single threshold event. It means connecting hearing data to exposure and behavior, not just filing reports.

Most importantly, it means acknowledging that compliance is the starting point, not the goal.

Workers and companies are paying the long-term price for programs designed around minimum requirements. Higher healthcare costs. Increased cognitive risk. Lost quality of life. All while official injury numbers stay artificially low.

At Soundtrace, we are pushing for a higher standard. One that treats hearing loss as a preventable medical condition, not just a compliance metric.

Because the absence of recordables does not mean hearing is being preserved. It just means we are not looking closely enough.

Frequently Asked Questions

How many occupational hearing loss cases are reported to OSHA each year?

Between 2022 and 2024, OSHA recorded approximately 11,000 to 12,000 hearing loss cases annually. Experts widely believe this number significantly underrepresents actual hearing decline.

Why does job turnover affect hearing loss reporting?

Each time an employee starts a new job, a new hearing baseline is established. This resets the comparison point and hides cumulative hearing damage across jobs.

Is mild hearing loss a medical concern?

Yes. Johns Hopkins research shows that even mild hearing loss is associated with higher healthcare costs and a significantly increased risk of dementia.

Does passing an annual hearing test mean hearing is protected?

No. Annual tests can miss gradual decline. Many workers lose hearing slowly without triggering a recordable threshold shift.

What is the difference between compliance and prevention?

Compliance focuses on meeting regulatory requirements. Prevention focuses on reducing exposure, detecting early changes, and preserving hearing long before damage becomes permanent.

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