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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 12, 1992

Mr. George R. Cook
Health & Hygiene, Inc.
420 Gallimore Dairy Road
Greensboro, North Carolina 27409

Dear Mr. Cook:

I am responding to your letter of May 28 which was transferred to my office from the Directorate of Compliance. My Division of Recordkeeping Requirements is responsible for administering the OSHA injury and illness recordkeeping system nationwide.

After reviewing your letter and discussing your phone conversations with Jim Maddux, I believe I understand your concerns as they relate to the relationship between the potential requirement to record Standard Threshold Shifts (STS) on the OSHA 200 Log and the quality of hearing conservation programs provided by employers.

In summarizing those concerns, you have observed that many employers do not utilize the optional provisions of the occupational noise exposure standard (29 CFR 1910.95) including the correction of audiograms for presbycusis and the revision of baselines. As a result, many of these employers perform follow- up procedures (refitting of hearing protection devices, retraining of workers, etc.) more frequently than the minimum amount required by the standard. You further state your belief that if employers are required to record STS instances on the log they will attempt to minimize the number of recorded cases by fully utilizing the presbycusis and baseline revision options. Thus, you feel that this could result in less effective hearing conservation programs.

At the present time, Federal OSHA enforcement policy requires the recording of 25 dB STS cases on the injury and illness records. As you know, we are drafting a proposal to revise the entire injury and illness recordkeeping system. As soon as possible, a Notice of Proposed Rulemaking will be published in the Federal Register soliciting comments from interested parties. I encourage you to provide formal comments at that time.

Thank you for your comments and insight concerning the recordkeeping requirements. If you have further questions or comments please contact my staff at (202) 523-1463.


Stephen A. Newell
Acting Director
Office of Statistics