OSHA 1910.95 has required employers to maintain audiometric records for the duration of employment for affected employees since the standard's modern form was adopted. Despite that, recordkeeping remains one of the most consistently cited subparts of the noise standard year after year.
From our work with hundreds of employers, three patterns drive most of the gap: records held by audiometric vendors on contracts that don't match OSHA's retention horizon; missing or inaccessible historical baselines after a vendor switch; and standard threshold shift documentation that lives in spreadsheets rather than in a connected, defensible system of record.
Heading into 2026, employers reviewing their hearing-conservation programs should ask three questions of any audiometric testing arrangement: Who owns the records, where do they physically live, and how long are they retained after the contract ends? The answers determine whether the program is audit-ready or quietly accruing exposure.
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