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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

April 8, 1994

Ms. Mary McDaniel, M.S., CCC-A
V.P. - Coordinator of Services
Washington Audiology Services, Inc.
6987 Perimeter Road South
Suite 100
Seattle, Washington 98108-3840

Dear Ms. McDaniel:

Thank you for your letter dated March 18, requesting an interpretation on the proper recording of hearing loss on the OSHA Form 200. Your letter was forwarded to the OSHA Office of Statistics by the Directorate of Compliance. The Division of Recordkeeping Requirements is responsible for the maintenance of the injury and illness recordkeeping system nationwide.

As outlined in the September 4, 1991 letter to Paul Williams of General Dynamics, the retest audiogram must be completed within 30 calendar days of the initial test to be used as a substitute for the initial audiogram. If the retest is given after thirty days, the recorded case may not be lined out even if the audiogram shows that the shift was not permanent. This retest time limit was established to be consistent with the requirements of the Occupational Noise Exposure standard.

Please be aware, however, that the criteria for recording hearing loss on the OSHA Log has no effect on employers obligations under the Occupational Noise Exposure standard (29 CFR Part 1910.95).

I hope you find this information useful. If you have any further questions, please contact us at Area Code: (202) 219-6463.


Robert Whitmore
Division of Recordkeeping Requirements