OSHA Hearing Conservation: the 1910.95 Compliance Checklist

1. Noise monitoring — know who is in the program

The program starts with exposure monitoring. When information indicates any employee may be exposed at or above the 85 dBA action level, you must develop and implement a monitoring program that identifies every employee for inclusion. Monitoring must be repeated when changes in production, process, or equipment could increase exposures.

• ✓ Identify every employee at or above 85 dBA (8-hour TWA)
• ✓ Re-monitor after process or equipment changes
• ✓ Notify each monitored employee of the results
• ✓ Allow employees or their representatives to observe monitoring

2. Baseline audiogram — within 6 months of first exposure

Every employee in the program needs a baseline audiogram within 6 months of their first exposure at or above the action level. (If you use a mobile test van, the standard extends this to one year — but requires hearing protection after the first 6 months until the baseline is done.) Employees should avoid workplace noise for at least 14 hours before the baseline test.

The baseline is the reference every future audiogram is compared against — get it early and get it clean.

3. Annual audiogram — every year, no gaps

After the baseline, each covered employee needs a new audiogram at least annually. This is where most programs quietly fall out of compliance: a missed year is a violation you cannot retroactively fix, and it leaves you blind to hearing shifts you were required to catch.

On-site testing during the shift is how high-coverage programs stay complete — no scheduling employees to drive to a clinic, no stragglers.

4. Standard threshold shift (STS) — the part with deadlines

Each annual audiogram must be compared to the baseline to check for a standard threshold shift: an average change of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. When an STS shows up, the clock starts:

• ✓ Employee must be notified in writing within 21 days of the determination
• ✓ Employees not already using hearing protectors must be fitted, trained, and required to use them
• ✓ A retest within 30 days may be substituted for the annual audiogram if you choose
• ✓ An audiologist, otolaryngologist, or physician must review problem audiograms and determine whether referral is needed
• ✓ If the shift is persistent, the annual audiogram may be revised to become the new baseline — a determination for the reviewing professional, not the file clerk

5. Hearing protection — provided, fitted, and enforced

Hearing protectors must be made available at no cost to every employee exposed at or above the action level, and their use is mandatory for anyone exposed at or above the 90 dBA permissible exposure limit, anyone who hasn't had a baseline yet, and anyone who has had an STS. Employees must be given a suitable selection and trained in fitting, use, and care. The protectors must attenuate exposure to acceptable levels — which means someone has to actually evaluate attenuation, not just hand out foam plugs.

6. Annual training — every year, three required topics

Everyone in the program must be trained annually on: the effects of noise on hearing; the purpose, advantages, disadvantages, and attenuation of hearing protector types (plus selection, fitting, use, and care); and the purpose and procedures of audiometric testing.

7. Records — what an auditor asks for first

Exposure measurement records must be retained for two years; audiometric test records for the duration of the affected employee's employment. Audiometric records must include the employee's name and job classification, the date, the examiner, the date of the last acoustic or exhaustive calibration of the audiometer, and the employee's most recent noise exposure assessment.

That calibration date requirement is why your audiometer's annual calibration certificate is part of your hearing conservation file, not just the instrument's paperwork.