OSHA is currently not enforcing the recording of hearing loss on OSHA Form 200 unless the shift from the original baseline audiogram at frequencies of 2,000, 3,000, and 4,000 Hz averages 25 dB or greater in either ear.

If an audiogram shows a hearing loss that is recordable on OSHA Form 200, the date that must be entered in column (B) is the date the employee was tested. If a retest performed within 30 calendar days of the initial test shows the hearing loss is not recordable on OSHA Form 200, the original entry may be deleted by drawing a line through it. OSHA adopted the 30-day retest time limit to provide employees a reasonable time to learn about the state of their hearing.

A particular shift in hearing should only be recorded once on the OSHA Form 200 Log, in the year in which the shift was first detected. Subsequent audiograms reflecting the same shift would not constitute a recordable case. When the results of an audiogram are recorded, that audiogram then becomes the reference audiogram for future comparisons.

Baseline audiogram revisions

Baseline audiograms may be revised when, in the judgment of the audiologist, otolaryngologist, or physician who is evaluating the audiogram, the hearing threshold shown in the annual audiogram indicates significant improvement over the baseline audiogram. When an employee has left a company and is then rehired some time later, the employer should establish a new baseline measurement upon the worker’s return to employment. An annual audiogram can be substituted for the baseline if the professional determines that the employee has experienced a persistent Standard Threshold Shift (STS).

Medical referrals

A professional reviewer determines if an employee needs a medical referral. Examples that might promote a referral are when an employee is unable to take a hearing test on a self-recording audiometer, does not respond reliably, or has visible irritation of the ear or pain in the ear canal that may be caused or aggravated by earplugs.

Employers must pay for any referrals intended to further identify the effects of occupational noise exposure or any detrimental effects from wearing hearing protectors. Medical conditions that are clearly not related to wearing hearing protectors, or an otoscopically abnormal eardrum due to an allergy or cold, are not the employer’s responsibility. Still, the employee must be informed of the need for examination or treatment.

All employees whose audiogram depicts an STS do not have to be referred to a licensed or certified audiologist, otolaryngologist, or other physician for evaluation. Based on guidelines established by the supervising professional, the technician decides which employees to refer to a professional.

Notification letters

Keeping a copy of the letter is not required, as long as the company keeps some other form of proof that the employee was notified of his standard threshold shift. A notification letter is not required if the employee has no hearing loss and no medical problems.

Voluntary audiograms

Follow-up procedures do not apply to employees exposed at work to noise below an 8-hour time-weighted average of 85 dBA. But you must comply with standard 29 CFR 1910.1020, Access To Employee Exposure and Medical Records. It requires you to preserve and maintain the audiogram, specifies the rights of access to the audiogram, and specifies employee information that must be provided.

OSHA’s noise standard requires that audiometric testing be made available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 dBA. On the other hand, the standard does not prohibit an employer from having a company rule that employees submit to audiometric testing. Be aware, though, that the Americans with Disabilities Act (ADA) places certain limitations on employer-required medical examinations. Such exams must be shown to be job-related and consistent with business necessity.

Off-the-job noise exposure

If all of an employee’s hearing loss is due to off-the-job exposures, in the opinion of a licensed physician, the case does not need to be recorded. If it’s determined that the work environment is likely to have contributed to the employee’s hearing loss, the case must be recorded.

It’s not necessary for an employee to be exposed to noise above an 8-hour TWA of 85 dBA to experience work-related hearing loss. If it seems likely that an event or exposure in the work environment either caused or contributed to the hearing loss, the case is considered work-related. It’s sufficient for an exposure to only be a contributing and/or aggravating factor to establish a work relationship for OSHA recordkeeping purposes.

Problem audiograms

Examples of problem audiograms are: Audiograms that show large differences in hearing thresholds between the two ears, audiograms that show unusual hearing loss configurations that are atypical of noise-induced hearing loss, and audiograms with thresholds that are not repeatable.

Valid audiograms

In general, a valid audiogram gives the appearance that the test was conducted correctly and the subject responded appropriately to the test signals.

In order for an audiogram to be valid, it must meet all the standard’s related requirements. The test must be conducted with a properly calibrated audiometer. The appropriate frequencies must be tested. Background noise levels must conform to the standard for audiometer test rooms. The audiometer must meet required equipment specifications.

Previous employer audiograms

When a business changes ownership, the previous employer must transfer audiometric test records to the new owner. Previous baseline audiograms must be assumed by the new owner, and these baselines may not be revised until the licensed or certified audiologist, otolaryngologist, or other physician determines that the employees have experienced a persistent shift of hearing that, when compared to these baselines, is equal to a standard threshold shift.