The Occupational Safety and Health Administration (OSHA) mandates Hearing Conservation Programs (HCP) when workers are exposed to 85 decibels or higher on an eight-hour time-weighted average (TWA). At 85 decibels, roughly the noise level of heavy traffic, workers must raise their voices to speak with someone just three feet away. When information indicates employee exposure may reach this level, employers must develop and implement a monitoring program.
HCPs strive to prevent initial occupational hearing loss and preserve remaining hearing through monitoring, testing, protection, training, and recordkeeping. Human resources (HR) coordinates compliance across these elements.
Certain industries face particularly high risk. Nearly one in four mining workers (23%) has hearing loss, along with 27% of utilities workers and 18% of manufacturing employees.
Audiometric Testing Requirements
Employers must establish an audiometric testing program for all employees whose exposure equals or exceeds 85 dBA-TWA, provided at no cost to employees. The program includes several key requirements:
- A baseline audiogram must be established within six months of an employee’s first exposure at or above the action level.
- Annual audiograms are required for each employee exposed to 85+ dBA-TWA.
- Tests must be performed by a licensed or certified audiologist, otolaryngologist, other physician, or certified technician.
- A standard threshold shift, defined as a change in hearing threshold of an average 10 dB or more at 2000, 3000, and 4000 Hz in either ear, triggers additional follow-up requirements.
HR schedules testing appointments, tracks compliance across the workforce, and ensures zero cost to employees.
Hearing Protection Provision and Selection
Employers must make hearing protectors available to all employees exposed to 85 dBA-TWA or greater at no cost, and employees must have the option of selecting from a variety of suitable protectors. Available types include foam plugs, earmuffs, and custom-molded earplugs.
Protection quality varies significantly. Improper insertion reduces foam plug effectiveness, while custom-molded earplugs offer superior fit compared to one-size-fits-all options. Fit testing verifies appropriate type selection and correct wear.
Employers must provide training in use and care, ensure proper initial fitting, and supervise correct use. HR tracks distribution, manages replacements, and maintains inventory.
Annual Training Obligations
Employers must provide annual training to each employee exposed to noise at or above 85 dBA-TWA. Required training content includes:
- The effects of noise on hearing
- The purpose of hearing protectors, including advantages, disadvantages, and attenuation of various types, plus instructions on selection, fitting, use, and care
- The purpose of audiometric testing and an explanation of test procedures
Beyond immediate hearing damage, workers should understand the associated health risks from hearing loss, including cognitive decline, heart problems, and even depression.
Recordkeeping and Employee Notification
Employers must maintain accurate records of all employee exposure measurements and retain all employee audiometric test records. Audiometric records must include the employee’s name and job classification, date of audiogram, examiner’s name, date of last calibration, and the employee’s most recent noise exposure assessment.
Retention periods differ by record type. Noise exposure measurement records must be kept for two years, while audiometric test records must be retained for the duration of employment.
Employers must notify each employee exposed to 85 dBA-TWA or higher of monitoring results and must provide all records upon request to employees, former employees, or designated representatives. Research shows workplaces with effective HCPs have higher productivity and lower absenteeism.
A Safer, Compliant Workplace Begins With HR
More than 22 million workers face potentially damaging noise levels annually, and the consequences are permanent, that is, hearing loss lasts a lifetime.
Through diligent coordination of monitoring, testing, protection, training, and recordkeeping, HR professionals play a critical role in both safeguarding employee health and maintaining OSHA compliance.
Dr. Sonia Penaroza is a Doctor of Audiology (Au.D.) and the owner of Golden Ears Audiology Lakeway, a premier audiology clinic in Lakeway, TX. Dr. Penaroza has been practicing audiology since 2020. She completed her doctorate at Northwestern University and her externship in Phoenix, AZ. In 2025, she took the leap and opened her own practice with the philosophy that every patient is her family member and will be treated as such.
SOURCES
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95
https://blogs.cdc.gov/niosh-science-blog/2021/02/05/protecting-worker-hearing/
https://ehs.yale.edu/sites/default/files/files/decibel-level-chart.pdf
https://www.audibel.com/preventative-care/how-to-prevent-hearing-loss-at-work/
