OSHA’s occupational noise exposure standard at 29 CFR 1910.95 requires employers to implement a hearing conservation program when employee noise exposures equal or exceed an 8-hour time-weighted average (TWA) of 85 decibels (the action level). The hearing conservation program includes noise monitoring, audiometric testing, hearing protector provision and use, employee training, and recordkeeping. Occupational hearing loss is one of the most common work-related conditions, affecting workers across manufacturing, construction, mining, oil and gas, transportation, and military sectors. A program-level audit evaluates whether your hearing conservation program effectively identifies noise-exposed workers, provides timely audiometric testing, ensures adequate hearing protection, trains employees annually, and maintains required records.
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Download Checklist (.docx)Regulatory Requirements
29 CFR 1910.95 — Occupational Noise Exposure
The OSHA noise standard establishes a permissible exposure limit (PEL) of 90 dBA TWA and an action level of 85 dBA TWA. When exposures reach or exceed the action level, a hearing conservation program is required including noise monitoring, audiometric testing (baseline within 6 months, annual thereafter), hearing protector provision, annual employee training, and recordkeeping. When exposures reach or exceed the PEL, feasible engineering and administrative controls must be implemented and hearing protectors are mandatory.
29 CFR 1926.52 — Occupational Noise Exposure (Construction)
The construction noise standard establishes the same 90 dBA TWA PEL as general industry but does not include a hearing conservation amendment with the same detailed program requirements. However, OSHA has issued guidance encouraging construction employers to implement hearing conservation programs similar to those required under 1910.95, and many construction employers voluntarily adopt 1910.95 program elements.
NIOSH Criteria for a Recommended Standard: Occupational Noise Exposure
NIOSH recommends a recommended exposure limit (REL) of 85 dBA TWA (more protective than OSHA’s PEL of 90 dBA). NIOSH also recommends using a 3 dB exchange rate rather than OSHA’s 5 dB exchange rate. Many organizations adopt NIOSH recommendations as best practices in addition to meeting OSHA requirements. NIOSH also provides guidance on hearing protector selection and noise control engineering.
Noise Monitoring Program
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Noise exposure monitoring | A noise monitoring program has been implemented per 1910.95(d). Initial monitoring has been conducted to identify all employees whose exposures equal or exceed 85 dBA TWA. Monitoring is repeated when changes in production, process, equipment, or controls may result in increased noise exposures. All continuous, intermittent, and impulsive sound levels from 80 to 130 dBA are integrated into measurements using slow response. |
| Monitoring methods and instruments | Noise monitoring is conducted using properly calibrated instruments: sound level meters meeting ANSI S1.4 Type 2 specifications or noise dosimeters meeting ANSI S1.25. Instruments are calibrated per manufacturer specifications. A 5 dB exchange rate (OSHA requirement) is used for compliance monitoring. Personal dosimetry is used for employees with variable noise exposures throughout the shift. |
| Employee notification and observation | Each employee exposed at or above 85 dBA TWA is notified of monitoring results per 1910.95(e). Affected employees or their representatives are provided the opportunity to observe noise measurements per 1910.95(f). Notification is documented. |
Audiometric Testing Program
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Baseline audiogram | A valid baseline audiogram is established within 6 months of each employee’s first exposure at or above the action level per 1910.95(g)(5). If mobile testing services are used, the baseline may be obtained within one year, but the employee must wear hearing protectors for the interim 6 months. Employees are instructed to avoid high noise exposure for at least 14 hours prior to baseline testing. Hearing protectors may be used as a substitute for the 14-hour quiet period. |
| Annual audiometric testing | Annual audiograms are obtained for all employees in the hearing conservation program per 1910.95(g)(6). Each annual audiogram is compared to the employee’s baseline audiogram to determine if a Standard Threshold Shift (STS) has occurred. An STS is an average shift of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. |
| Audiometric testing administration | Audiometric tests are performed by a licensed/certified audiologist, otolaryngologist, physician, or a trained technician under the supervision of such professionals per 1910.95(g)(3). Audiometers meet ANSI S3.6 specifications. Audiometers are checked with biological calibration before daily use and receive annual acoustic calibration and calibration every two years per manufacturer specifications. Test rooms meet ANSI S3.1 background noise requirements per Appendix D. |
| Standard threshold shift management | When an STS is identified, the employee is notified in writing within 21 days per 1910.95(g)(8). Unless a physician determines the STS is not work-related, employees not using hearing protectors are fitted and required to use them, employees already using protectors are refitted and provided more effective options if needed, and the employee is referred for clinical evaluation if indicated. The employer may adjust the annual audiogram for age (presbycusis) using OSHA’s Appendix F tables. |
| Baseline revision | The audiologist, otolaryngologist, or physician reviewing audiograms determines whether the baseline audiogram should be revised when a persistent STS is confirmed per 1910.95(g)(9). An improved annual audiogram may be substituted for the baseline when the improvement is persistent. Baseline revisions are documented. |
Hearing Protection
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Hearing protector availability | Hearing protectors are made available at no cost to all employees exposed at or above 85 dBA TWA per 1910.95(i). A variety of suitable hearing protectors are available for employee selection. Replacement protectors are available as needed. Protectors are available to all employees in the hearing conservation program, not just those above the PEL. |
| Mandatory use requirements | Hearing protectors are required for employees exposed at or above 90 dBA TWA (the PEL) and for employees exposed at or above 85 dBA TWA who have experienced a Standard Threshold Shift per 1910.95(i)(2). Hearing protector use is enforced through supervision and the disciplinary process. |
| Attenuation adequacy | Hearing protectors are evaluated for adequacy of attenuation per 1910.95(j). Protectors must reduce employee exposure to at least 90 dBA (at or below the PEL), or to 85 dBA for employees who have experienced an STS. Noise Reduction Rating (NRR) is used to verify adequate attenuation using OSHA’s derating method. If attenuation is found inadequate, more effective protectors are provided. |
| Fitting, use, and care | Employees are trained on proper fitting, use, and care of hearing protectors per 1910.95(i)(4). Initial fitting is supervised to ensure proper insertion/placement and adequate seal. Employees demonstrate proper use. Regular observation confirms proper wear. Damaged or worn protectors are replaced. |
Training and Communication
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Annual training program | Training is provided annually to each employee in the hearing conservation program per 1910.95(k). Training covers: the effects of noise on hearing, the purpose and procedures of audiometric testing, the purpose of hearing protectors along with advantages, disadvantages, and attenuation of various types, and instructions on selection, fitting, use, and care. Training content is updated when changes in equipment or work processes occur. |
| Access to information | Copies of 29 CFR 1910.95 are made available to affected employees and a copy is posted in the workplace per 1910.95(l). Informational materials provided by OSHA are made available to affected employees. Employees have access to their own audiometric test results. |
Recordkeeping and Program Review
| Audit Item | Expected Finding / What to Evaluate |
|---|---|
| Noise exposure records | Noise exposure measurement records are maintained for at least two years per 1910.95(m)(3). Records include the equipment used for measurement and calibration documentation. |
| Audiometric test records | Audiometric test records are maintained for the duration of each employee’s employment per 1910.95(m)(2). Records include: employee name, job classification, date of audiogram, examiner name, date of last audiometer calibration, most recent noise exposure assessment, and background sound levels in the audiometric test room. |
| Program effectiveness review | The overall hearing conservation program is reviewed periodically to evaluate effectiveness. Review considers: STS rates and trends, hearing protector utilization rates, noise exposure trends, audiometric testing compliance rates, and training completion. Areas of concern drive engineering controls evaluation, protector upgrade, or enhanced training. Comparison with industry benchmarks informs program improvement. |
Corrective Actions
Common Issues and Responses
- No noise monitoring: Conduct an initial noise survey of all work areas and tasks where noise may approach or exceed the action level. Use calibrated instruments and qualified personnel. Identify all employees for inclusion in the hearing conservation program. Document results and notify affected employees.
- Overdue audiometric testing: Schedule audiometric testing immediately for all employees who are overdue. Prioritize employees who have never had a baseline audiogram. Ensure testing is performed by qualified personnel with calibrated equipment in an appropriate test environment.
- Inadequate hearing protectors: Evaluate the NRR of current hearing protectors against actual noise exposures using OSHA derating methods. Provide higher-attenuation protectors where needed. Offer multiple types for employee choice. Ensure proper fitting through supervised fitting sessions.
- Missing annual training: Schedule hearing conservation training immediately for all program participants. Cover all required topics (noise effects, audiometric testing, hearing protector selection/use/care). Document attendance and content. Establish an annual training calendar.
- STS without follow-up: Review all audiograms with identified STS. Notify affected employees in writing. Ensure hearing protector refitting or upgrade. Refer for clinical evaluation where indicated. Evaluate need for baseline revision. Investigate noise sources for additional engineering controls.
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Inspections
Noise monitoring documentation, hearing protector fit verification, and audiometric testing tracking.
Training
Annual hearing conservation training tracking with content management and attendance documentation.
Compliance Calendar
Schedule audiometric testing cycles, noise monitoring, audiometer calibrations, and training deadlines.
Reporting and Analytics
STS rate trending, hearing protector utilization analysis, and program effectiveness dashboards.
Document Management
Centralized storage for audiograms, noise surveys, calibration records, and training documentation.
Incident Management
Track noise-related incidents, STS events, and hearing loss claims with root cause analysis.
