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                                              OSHA Recordability 

 Lipin/Dietz Associates, Inc.

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  • Basic recording criterion: Employers must record work-related “Standard Threshold Shift”, or STS (an average change of 10 dB at 2000, 3000, and 4000 Hz in either ear, compared to baseline; age-adjustments allowed) provided that the employee’s average hearing level at the same frequencies in the same ear is 25 dB HL or greater (an average hearing level of 25 dB or more, regardless of employee’s age, i.e., no age adjustment allowed).

  • Baseline/reference audiogram: To determine whether a STS has occurred, the employer must compare the current hearing test results to the employee’s baseline audiogram. The baseline audiogram is the employee’s original audiogram or revised audiogram as defined under OSHA’s noise standard 29 CFR 1910.95.

  • Reconfirmation of STS: If the annual audiogram shows a STS, a hearing retest may be performed within 30 days. If the retest does not confirm the STS, then the case need not be recorded. However, if the retest confirms the STS, then the STS if work-related, must be recorded within 7 calendar days of retest. If a retest is not performed, then the case (again, if work-related) must be recorded within 37 days of test.

  • Results of subsequent testing: If later testing performed as part of the hearing conservation program indicates that the STS is not persistent, then the employer may erase or line-out the recorded entry.

  • Determination of work-relatedness: Work-relatedness must be determined according to specifications of section 1904.5 of the general recordkeeping rule. If an event/exposure in the workplace caused or contributed to the shift in hearing or “significantly aggravated” a previously existing hearing loss, then the STS is recordable.

  • Forms: OSHA has also updated its recordkeeping forms (now OSHA Form 300, 301 and 300A). Beginning January 1, 2004, employers will be required to record hearing loss cases in a separate column. In 2003, employers should record cases of occupational hearing loss as an “injury” (single event acoustic trauma) or “other illness” (long term noise exposure), as appropriate.
    Click here for OSHA's revised Form 300 Log of Work-Related Injuries and Illnesses.

  • State plans: Although state-run OSHA plans were allowed to continue utilizing more stringent enforcement criteria during 2002, all are required to adopt the final federal rule for hearing loss recordability, effective January 1, 2003.

  • Applicable industries: Certain industries are not covered under the general hearing conservation amendment 1910.95 (construction, agriculture, oil and gas drilling, etc.), but are included under 1904. If such employers choose to conduct audiometric testing programs, then the hearing loss recordability provisions of 1904.10 will apply.


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Last modified: October 28, 2015