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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 26, 1992

Mr. James J. Hamulav
Kimball & Curry, P.C.
Suite 1600
2600 North Central Avenue
Phoenix, Arizona 85004

Dear Mr. Hamula:

I am responding to your letter dated February 18 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. Please excuse the lengthy delay in our response.

The June 4 memorandum describes OSHA's interim policy of issuing citations for violations of 29 CFR Part 1904 when employers fail to record occupational hearing loss on the OSHA Log and Summary of Occupational Injuries and Illnesses (Form 200). Employers are still expected to comply with all of the provisions of the Hearing Conservation Amendment (29 CFR Part 1910.95).

Many companies have been recording Standard Threshold Shifts (STS) of 10 dB or greater (as defined in the Hearing Conservation Amendment (HCA)) on their OSHA Logs. If these companies continue to do so, they will be in complete compliance with the injury and illness recordkeeping requirements and enforcement policy. OSHA does not want to discourage your client companies from continuing this practice. If they continue to record 10 dB shifts on their OSHA Form 200, they should revise the baselines using the HCA provisions to avoid recording the same STS more than once.

If your clients choose to record 25 dB shifts on the OSHA Form 200, the initial shift must be measured from the employee's "original baseline". The "original baseline" is the baseline audiogram first established as a result of the RCA. This could be a 1983 audiogram under the RCA, a pre-1983 audiogram grandfathered in under the RCA, or a pre-employment audiogram given to an employee hired after 1983.

When a 25 dB shift occurs and the case is recorded on the OSHA Log, that audiogram will then become the new reference baseline for future measurements. Another recordable case would not be logged until the employee suffers a 25 dB shift from the new reference baseline.

I hope you find this information useful. If you have any further questions please contact my staff at (202) 523-1463.


Acting Director
Office of Statistics