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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 http://www.osha.gov.
February 6, 1991
Mr. James D. Banach President
National Hearing Conservation Association
900 Des Moines Street
Des Moines, Iowa 50309
Dear Mr. Banach:
Thank you for your letter of December 14, 1990, regarding the recording of hearing loss on OSHA Form 200.
Your letter stated that you believe the Occupational Safety and Health Administration (OSHA) should issue a clearly-defined criterion for recording occupational hearing loss at the earliest possible time. Your contacts with various OSHA Regional Offices have resulted in differing responses concerning enforcement of the level at which hearing loss must be recorded. You recently became aware that OSHA issued a draft document on March 23, 1990, that provided guidelines for enforcing the recording of occupational hearing loss on OSHA Form 200. You related that you have some concerns about specific items in the draft document. You also commented that it would be useful to employers and hearing conservation professionals alike if consistency in enforcement policy could be established.
We agree that a clearly defined criterion for recording occupational hearing loss is needed and that consistency in enforcement policy is essential. We are preparing a final field directive that will serve these purposes. We will take your comments into consideration during this process. As soon as the directive is finalized, we will provide you with a copy.
We appreciate your comments on this important issue.
Gerard F. Scannell