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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 24, 1991

Charlotte Lewengrub, RN, MN
Health Services Coordinator
Scientific Atlanta, Inc.
4366 Park Drive
Norcross, Georgia 30093

Dear Mrs. Lewengrub:

This is in further response to your letter of September 28, to the Occupational Safety and Health Administration (OSHA), regarding the recording of hearing loss on the OSHA 200 Log and Summary of Occupational Injuries and Illnesses.

Please be aware that the employee's "original baseline" referred to in the August 27 memorandum is defined as the baseline audiogram that was established for compliance with the Hearing Conservation Amendment (29 CFR 1910.95), promulgated March 8, 1983. Using this definition, your company will not be penalized for having a longer history of performing audiograms than other companies.

A particular 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 then becomes the reference audiogram for future comparisons.

In the absence of detailed guidance, 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 this practice. Companies who adopt this practice may use a single set of records and baseline audiograms to meet the requirements of the Hearing Conservation Amendment and the recordkeeping requirements for the OSHA 200 Log.

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 specific 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 health care 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.

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


Gerard F. Scannell
Assistant Secretary