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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 16, 1991

Mr. Lawrence K. Thebo, M.Sc., CIG, CSP
641 Parkridge Lane
Coraopolis, Pennsylvania 15108

Dear Mr. Thebo:

Thank you for your letter of October 22 expressing your views on the recording of occupational hearing loss on the OSHA 200 Log and Summary of Occupational Injuries and Illnesses. The June 4 and August 27 memoranda you refer to were issued to provide a consistent and fair enforcement policy to the Occupational Safety and Health Administration (OSHA) field offices regarding the recording of occupational hearing loss.

The issue of recording audiometric test results on the Log has been debated for several years. Although the issue has been discussed on many occasions, comprehensive guidance has never been issued regarding the recording of abnormal audiometric results. In the absence of complete guidance, many companies have decided to record average 10 dB or greater Standard Threshold Shifts (as defined in 29 CFR Part 1910.95). OSHA does not want to discourage these companies from continuing this practice. Companies who adopt this practice may use a single set of records and baseline audiograms to meet the requirements of the Occupational Noise Exposure standard and the recordkeeping requirements for the OSHA 200 Log.

The 25 dB criteria is a modification of guidance found in the American Medical Association's Guides to the Evaluation of Permanent Impairment. This 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 shift in hearing should only be recorded once on the OSHA 200 Log, in the year in which the shift was first detected. Subsequent audiograms reflecting the same shift would not constitute a recordable case. When the results of an audiogram are recorded, that audiogram is the reference or baseline audiogram for future comparisons. We are presently working on a "hearing loss fact sheet" that will clearly outline the issues associated with recording hearing loss on the OSHA 200 Log. When it is completed, we will be sure to forward you a copy.

The entire OSHA recordkeeping system is currently being revised. 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 clear guidance on the recording of occupational hearing loss.

By dealing with this matter 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 loss professionals, such as yourself, will have to offer at that time. Until this formal rulemaking is completed, I do not expect any revision of the citation policy set forth in the June 4 and August 27 memoranda.

I hope this information will adequately answer your questions about the minimum recordkeeping requirements for occupational hearing loss. If you have further questions please contact the OSHA Office of Statistics at (202) 523-1463.


Gerard F. Scannell
Assistant Secretary