OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 16, 1984

Ms. Joyce Hall
Memorial Hospital of Union County
600 London Avenue
Marysville, Ohio 43040

Dear Ms. Hall:

As requested in your telephone conversation with Ms. Deborah Feldman of the Occupational Safety and Health Administration's (OSHA) Directorate of Health Standard Programs. I am writing to provide you with an official interpretation concerning the Hearing Conservation Amendment. Specifically, you requested an official response with regard to training and audiometric testing.

OSHA approves the use of a film to meet the training requirements of the amendment as long as the supervisor is present to address employee questions, the material is updated appropriately, and the training is offered annually. It is not necessary at the viewing of the film to provide a display of hearing protectors and to individually fit and train each employee about the use of hearing protectors at the time the hearing protector is fitted on the employee.

With regard to audiometric testing, the standard requires the employer to establish a valid audiogram. The professional in charge of the program should review audiograms where thresholds are questionable and use his/her professional judgement ot determine whether there is a need for further testing.

I hope that this information will be helpful to you. If you have further questions, please do not hesitate to contact us.


John Miles
Director, Field Operations