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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

December 6, 1991

The Honorable Herbert Kohl
United States Senate
Washington, D.C. 20510

Dear Senator Kohl:

Thank you for your letter of October 18 and for the opportunity to address the concerns of your constituent, Mr. Richard J. LaRonge, regarding OSHA regulations relating to occupational hearing loss. We hope this letter will clarify what is required under these regulations, and what affect the stated policy of the enclosed June 4 and August 27 memoranda has on these regulations.

The hearing conservation amendment, 29 CFR 1910.95, has not been changed in any way. All duties and responsibilities under this OSHA standard remain in full force and effect.

Title 29 of the Code of Federal Regulations, Part 1904, "Recording and Reporting Occupational Injuries and Illnesses," regulates the determination of when hearing loss must be recorded on the OSHA Form 200. OSHA's official interpretations of Part 1904 are contained in the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses, 1986.

The June 4 and August 27 memoranda were issued to the OSHA Regional Administrators outlining a uniform Federal enforcement policy regarding the recording of work-related hearing loss on the OSHA Form 200. Employers must record a work-related average loss of 25 dB in either ear at 2000, 3000, and 4000 Hz. The loss must be measured from the employee's original baseline established under the hearing conservation amendment of 1983.

We understand Mr. LaRonge's confusion over the requirements of the two separate regulations. Both require the collection of similar information for different purposes and may be easily confused. He states that 1910.95 requires entries on the OSHA 200. This is incorrect. He is also mistaken about OSHA inspection and citation policy. We believe that Mr. LaRonge may best be helped if he contacts the OSHA Office of Statistics directly at Area Code (202) 523-1463 to discuss the requirements of 29 CFR Parts 1904 and 1910.95.

We at OSHA feel that the protection of the health and welfare of the American worker is central to our congressional mandate. We know that both your constituent and you share our concerns and commitments. Occupational safety and health statistical information is necessary for both OSHA and employers to recognize and act upon hazards that exist in the workplace.


Gerard F. Scannell
Assistant Secretary