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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 27, 1994

Mr. Mark R. Downing
Hall-Buck Marine, Inc.
Post office Box 83838
Portland, Oregon 97283-0838

Dear Mr. Downing:

Thank you for your letter dated May 16, requesting clarification on the proper recording of hearing loss cases on the OSHA 200 log. You letter was forwarded to the OSHA Office of Statistics by the Seattle Regional Office. The Division of Recordkeeping Requirements is responsible for the maintenance of the injury and illness recordkeeping system nationwide.

As explained in the enclosed June 4, 1991 memorandum, for federal enforcement purposes, a company will be cited for not recording a work related cumulative shift in hearing of an average of 25 dB or more at 2000, 3000, and 4000 Hz in either ear. The employee's initial 25 dB shift is to be measured from his or her original baseline. The original baseline is the baseline first established as a result of the Noise Standard. This could be a 1983 audiogram under the hearing conservation amendment, a pre- 1983 audiogram grandfathered in under the hearing conservation amendment, or a pre-employment audiogram given to an employee hired after 1983. Once an employee experiences a recordable shift in hearing (25 dB or greater) the audiogram showing the recordable shift would become the employee's new reference audiogram for future recordability comparisons. An additional case need not be recorded until the employee experiences a further cumulative 25 dB shift from the new reference audiogram. If a worker is exposed to noise levels in excess of an 85 dB 8- hour time-weighted average, as found in the hearing conservation standard, any hearing loss is presumed to be work related.

A company that records a Standard Threshold Shift (STS) (defined as 10 dB or higher) would be in complete compliance with the injury and illness recordkeeping requirements.

When entering recordable occupational illnesses on the OSHA Log, the date of initial diagnosis or recognition of the illness is used. The date of the audiogram which reveals the recordable shift in hearing should be used to satisfy this criteria (e.g., if a 1990 audiogram shows a recordable shift in hearing, the case should be entered on the 1990 OSHA Log). If the employee's hearing loss resulted from an instantaneous event or exposure and is evaluated as an injury, enter the actual date of the work incident which resulted in the injury (see section A on page 9 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses).

If a recordable injury or illness is discovered within 5 years after an employee retires (i.e., the maintenance and retention period of the records), the case should be recorded in the year of occurrence if the date of injury or onset of illness can be identified. If not, the case should be recorded in the retiree's last year of employment (see Q&A E-5 on page 23 of the Guidelines).

When a case involves an employee who has had multiple employers, the employer responsible for administering the audiogram which revealed a recordable shift in hearing must enter the case into the company's OSHA records. This holds true if workplace exposure contributed to any part of the loss of hearing. The entire shift in hearing need not be attributable to that specific company to be considered a recordable case.

We understand the issue outlined in your letter concerning the misleading picture that the "bottom line numbers" of the Log can portray. It is our position that all of the information contained on the form must be reviewed together with company safety and health programs to get a true picture of the safety and health environment of the firm. The OSHA Log is intended to be used as a surveillance tool and not as a "report card".

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


Bob Whitmore
Division of Recordkeeping Requirements