Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

November 15, 1991

Mr. William K. Wolfe
Environmental Technology Corporation
Building J-3
11205 Alpharetta Highway
Roswell, Georgia 30076

Dear Mr. Wolfe:

Thank you for your letter of September 25 stating your views on the recordability of work-related hearing loss. We appreciate and consider carefully any input from hearing conservation experts such as yourself. In this letter I will attempt to answer your questions and address the issues you have raised.

The enforcement strategy described in the June 4 memo is not a change in policy. It is simply a formal statement of a policy that has been in effect since the publication of the Recordkeeping Guidelines for Occupational Injuries and Illnesses in 1986. The 25 dB criteria is a modification of guidance found in the American Medical Association's Guides to the Evaluation of Permanent Impairment. This threshold criteria was chosen because it is widely accepted as a meaningful loss of hearing, is well documented, and is legally defensible under the current regulations.

A work-related 25 dB average shift from the employee's original baseline at 2000, 3000, and 4000Hz in either ear must be recorded on the OSHA 200 log. The baseline would then be revised to zero. An entry for a new case would not be made on the log until there is an additional 25 dB shift from this revised baseline. However, many companies have decided to record average 10 dB Standard Threshold Shifts as defined in 29 CFR 1910.95. OSHA does not want to discourage these companies from continuing this practice. If companies choose to record work-related 10 dB shifts, they will need to maintain only one history per employee to comply with the hearing conservation amendment and the OSHA 200 recordability requirements.

We at OSHA commend companies that take the initiative in developing effective occupational safety and health programs. However, the fact that many companies have been involved in hearing conservation programs before they were legally required does not excuse them from current regulations. The employees original baseline i.e., the one that was on record in 1983, must be used in the measurement of work-related hearing loss.

As stated earlier, the 25 dB criteria represents a long standing federal enforcement position. The entire recordkeeping system is scheduled for revision in the near future. As soon as practicable, a Notice of Proposed Rulemaking (NPRM) concerning the recording of injuries and illnesses will be published in the Federal Register. This NPRM will propose multiple changes to the recordkeeping system, including guidance on the recording of many occupational injury and illness conditions.

By dealing with this and other recordkeeping issues in a formal regulatory context, OSHA will insure full public input during the decision making process. We are looking forward to any comments or suggestions that hearing conservation professionals, such as yourself, will have to offer at that time. Until this formal rulemaking is completed, do not expect any revision of the citation policy set forth in the June 4 memo.

I hope this letter will adequately answer your questions and concerns. If you have any further questions please contact my Office of Statistics at (202) 523-1463.


Gerard F. Scannell
Assistant Secretary