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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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. Melvin W. Johnson
Vice President
Lamson & Sessions
25701 Science Park Drive
Cleveland, Ohio 44122

Dear Mr. Johnson:

Thank you for your letter of October 15, to the Occupational Safety and Health Administration (OSHA), concerning the recording of hearing loss on the OSHA Form 200.

On June 4 and August 27, 1991, two memoranda were issued to the OSHA Regional Administrators outlining the Federal policy for uniformly enforcing the recording of work related hearing loss on the OSHA Form 200. The memoranda provide an OSHA enforcement policy related to an existing regulation (29 CFR 1904) and its supplementary guidelines. For this reason the rulemaking procedures under the Administrative Procedures Act were not appropriate.

Enclosed are copies of these memoranda detailing the criteria for the OSHA enforcement policy regarding the recording of occupational hearing loss. Please be aware that the employee's "original baseline" referred to in the August 27 memorandum is defined as the baseline audiogram established in accordance with the hearing conservation amendment promulgated March 8, 1983.

We are presently working on a "hearing loss fact sheet" that will clearly outline the issues associated with recording hearing loss on the OSHA Form 200. When it is completed, we will be sure to forward you a copy.

If you have any questions concerning the information enclosed, please contact the OSHA Office of Statistics at Area Code (202) 523-1463.


Gerard F. Scannell
Assistant Secretary