OSHA Audiometric Testing Requirements and Penalties

OSHA audiometric testing requirements apply to general industry employers whenever a worker’s 8-hour time-weighted average noise exposure reaches 85 decibels (dBA). At that point, 29 CFR 1910.95 obligates you to give the worker a baseline hearing test within six months, retest annually, use specific equipment and qualified personnel, and follow a defined response when hearing worsens. The rules cover who can administer the test, what frequencies must be measured, how the audiometer is calibrated, how quiet the test room must be, and what to do when an annual audiogram shows a shift from baseline.

One boundary to know up front: these testing requirements sit inside the general industry standard. Construction employers operate under 29 CFR 1926.52, which triggers a hearing conservation program only above 90 dBA and does not spell out baseline audiograms, annual retests, or the technical testing requirements described below.¹ If you work in construction, audiometric testing is something you can adopt voluntarily, not something the standard prescribes in detail.

What Triggers Audiometric Testing

Testing obligations begin at the action level: an 8-hour TWA of 85 dBA. That is a lower threshold than the permissible exposure limit of 90 dBA, and it is the number that matters for hearing conservation. Reaching 85 dBA triggers noise monitoring, audiometric testing, hearing protector availability, training, and recordkeeping.²

Exposure is measured without any credit for hearing protection. The environmental noise level determines who needs testing, not what the worker’s ears actually receive through earplugs or muffs.²

Whenever information suggests exposures could hit the action level, the employer must run a monitoring program to identify affected workers and must repeat that monitoring after any change in production, process, equipment, or controls that could push more employees over the line. Each affected employee must be told the monitoring results.³

The Baseline Audiogram

Every worker exposed at or above 85 dBA needs a baseline audiogram. It is the reference point against which every future test is compared, so its accuracy shapes the entire program.

The baseline must be completed within six months of the employee’s first exposure at or above the action level. Employers that rely on mobile test vans get up to one year, but if the baseline is delayed beyond six months, the employee must wear hearing protection during the entire interim period.²

The test itself must be preceded by at least 14 hours without workplace noise exposure. Otherwise a temporary shift from that day’s shift work can inflate the baseline and hide real damage later. Wearing hearing protectors during the 14 hours counts, so you do not need to send workers home early the day before.⁴

Annual Audiograms

Once the baseline exists, the employer must obtain a new audiogram at least once every year for each employee still exposed at or above 85 dBA.² The annual test is compared against the baseline to look for a standard threshold shift.

OSHA does not require an exit audiogram when a worker leaves. Some employers do one anyway to document ending hearing status.

Technical Requirements for a Valid Test

OSHA is prescriptive about what counts as a valid audiogram. Each test must be a pure-tone, air-conduction threshold examination, run separately for each ear, at a minimum of six frequencies: 500, 1000, 2000, 3000, 4000, and 6000 Hz.³

Who Can Administer the Test

Tests can be performed by a licensed audiologist, an otolaryngologist, another physician, or a technician. A technician must either be certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC) or have demonstrated competence in administering the tests, and must work under the responsibility of an audiologist, otolaryngologist, or physician. The supervising professional does not have to be physically present but is accountable for the quality of the program.⁵

Audiometer Calibration

Audiometers must meet ANSI S3.6-1969, and calibration happens on three schedules:

A daily functional check before use, with someone of known stable hearing thresholds, and a listening check for distortion. Any deviation of 10 dB or more triggers an immediate acoustic calibration.
Acoustic calibration at least annually, checking output against reference levels at each test frequency.
Exhaustive calibration at least every two years, following ANSI S3.6-1969 procedures.

These layered checks catch drift before it corrupts a worker’s baseline or annual result.²

Test Room Background Noise

The test space itself has to be quiet enough that background sound does not mask the tones. Appendix D of 1910.95 sets the ceilings. At key octave-band center frequencies, the maximum allowable sound pressure levels are 40 dB at 500 Hz, 40 dB at 1000 Hz, 47 dB at 2000 Hz, 57 dB at 4000 Hz, and 62 dB at 8000 Hz.³ A booth placed on a noisy production floor without adequate isolation can push background levels past these limits and invalidate the results.

When an Annual Test Shows a Standard Threshold Shift

A standard threshold shift, or STS, is an average worsening of 10 dB or more at 2000, 3000, and 4000 Hz in either ear, measured against the baseline audiogram.² Catching an STS is the operational purpose of annual testing.

Optional Age Correction

Some hearing loss comes from aging rather than noise. Employers may apply an age correction using the tables in Appendix F, subtracting the expected age-related change between baseline and current age from the measured shift. Separate tables cover males and females. Age correction is optional.³

The 30-Day Confirmatory Retest

When an annual audiogram appears to show an STS, the employer may retest the employee within 30 days. If the retest does not confirm the shift, it can be used as the annual audiogram and the follow-up obligations do not apply. Congestion and same-day noise exposure can produce false shifts, so the retest is a real safety valve, but the 30-day window is tight if you rely on scheduled mobile testing.²

Required Follow-Up Once an STS Is Confirmed

Once an STS is confirmed, the employer must notify the employee in writing within 21 days of the determination.³ Unless a physician determines the shift is unrelated to occupational noise, the employer must also:

Fit and train employees who were not previously using hearing protectors, and require them to wear the protection going forward.
Refit employees who already use hearing protectors, and provide more effective protection if needed to bring exposure to 85 dBA or below.
Refer the worker for further audiological or medical evaluation when additional testing is warranted or an ear condition is suspected.

The employer may also revise the baseline. If a shift proves persistent, the current audiogram can replace the original baseline going forward. A revision can also occur when an annual test shows significant improvement.²

Recording Hearing Loss on the OSHA 300 Log

An STS under the hearing conservation standard and a recordable hearing loss under OSHA injury and illness recordkeeping are separate calls. A case belongs on the OSHA 300 Log only when both conditions are met: the employee has a work-related STS (10 dB average shift at 2000, 3000, and 4000 Hz), and the overall hearing level in the affected ear is 25 dB or more above audiometric zero, averaged across those same frequencies.⁶ No age adjustment is applied to the 25 dB calculation.

If a 30-day retest does not confirm the STS, the case does not have to be recorded. If the retest confirms it, the employer has seven calendar days from the retest to enter it on the log. A physician or licensed health care professional can also determine that the loss is not work-related, in which case recording is not required.⁶

Records You Have To Keep

Audiometric test records must be retained for the duration of each affected employee’s employment. Noise exposure monitoring records must be kept for at least two years.²

Each audiometric record must include the employee’s name and job classification, the date of the audiogram, the examiner’s name, and the date of the audiometer’s last calibration. Records must be made available on request to the employee, former employees, designated representatives, and OSHA.²

Under the access-to-records standard, an employer that cannot provide requested records within 15 working days must explain the delay and give the earliest date the records will be available.⁷ If the business closes, hearing conservation records transfer to the successor employer, who inherits the retention obligation for the remaining period.

Penalties

OSHA inspectors regularly cite hearing conservation failures, and the common triggers are missed noise monitoring, missing baseline or annual audiograms, and untrained workers. Each is a separate potential violation.

As of the January 2025 penalty adjustment, the maximums are:

Serious or other-than-serious violation: up to $16,550 per violation.
Willful or repeated violation: up to $165,514 per violation.
Failure to abate: up to $16,550 per day past the abatement deadline.

OSHA adjusts these amounts annually for inflation, so the 2026 figures may be slightly higher once the next adjustment is published.⁸ Because the standard contains many distinct duties, one inspection can produce citations across monitoring, testing, follow-up, and recordkeeping, and the totals add up quickly.

1
Occupational Safety and Health Administration. 29 CFR 1926.52 – Occupational Noise Exposure
2
Occupational Safety and Health Administration. 29 CFR 1910.95 – Occupational Noise Exposure
3
eCFR. 29 CFR 1910.95 – Occupational Noise Exposure
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Occupational Safety and Health Administration. Clarification of OSHA’s Requirement for Quiet Time Before Audiometric Testing
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Occupational Safety and Health Administration. Occupational Noise Exposure Training Requirements for Technicians
6
Occupational Safety and Health Administration. 29 CFR 1904.10 – Recording Criteria for Cases Involving Occupational Hearing Loss
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Occupational Safety and Health Administration. 29 CFR 1910.1020 – Access to Employee Exposure and Medical Records
8
Occupational Safety and Health Administration. OSHA Penalties