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 https://www.osha.gov.

January 23, 1995

Lawrence A. Cooke, C.I.H.
Manager of OH & S
Alcan Aluminum Corporation Post
Office Box 6977 Cleveland, Ohio 44101-1977

Dear Mr. Cooke:

This is in response to your letter of July 13, 1994, concerning the hearing conservation program in one of your companies.

You inquired whether an employer is required to meet the follow-up procedures at 29 CFR 1910.95(g)(8) of the Occupational Noise Exposure Standard when an employee with a history of off-the-job noise exposure, but who is exposed at work to noise below an 8-hour time-weighted average of 85 dBA, is voluntarily provided an audiogram and found to have a standard threshold shift of hearing.

The follow-up procedures at 29 CFR 1910.95(g)(8) do not apply to employees exposed at work to noise below an 8-hour time-weighted average (TWA) of 85 dBA. However, the company must comply with standard 29 CFR 1910.1020, Access To Employee Exposure and Medical Records. That standard requires that the audiogram be preserved and maintained, specifies the rights of access to the audiogram, and specifies employee information that must be provided.

You also asked whether the employer must record the shift on the OSHA Form 200 if the shift is high enough to meet the recordability requirements.

If, in a licensed physician's opinion, all of the employee's hearing loss was due to off-the-job exposures, the case need not be recorded. If, however, it is determined that the work environment is likely to have contributed to the employee's hearing loss, the case must be recorded.

Since the workplace noise exposure is below an 8-hour TWA of 85 dBA, the hearing shift is not presumed to be work-related. However, it is not necessary for an employee to be exposed above an 8-hour TWA of noise of 85 dBA to experience work-related hearing loss. Work relationship is established under the OSHA recordkeeping system when an injury or illness results from an event or exposure in the work environment. If it seems likely that an event or exposure in the work environment either caused or contributed to the case, the case is considered work related. It is sufficient for an exposure to only be a contributing and/or aggravating factor to establish work relationship for OSHA recordkeeping purposes (please refer to Q&A C-7 on page 34 and Q&A B-17 on page 32 of the brochure, Occupational Injuries and Illnesses).

Your second scenario concerns the case of an employee with a history of high off-the-job noise exposure who has worked for ten years without receiving an annual audiometric test. His/her noise exposure in the plant has been documented to have always been below 85 dBA TWA. The employee was given a baseline audiogram as part of an employment medical examination. Each year the employee refused an audiometric test that was offered as part of a non-required hearing conservation program. The eleventh year the employee accepted the audiometric test and it indicates that there has been a change from the baseline that is greater than the OSHA recordability requirement. You asked if the employee's hearing shift must be recorded on OSHA Form 200.

The answer to this question is the same as the answer to your previous question on recording information on OSHA Form 200.

[This document was edited on 3/5/2004 to strike information that no longer reflects current OSHA policy. Please see the revised Injury and Illness Recordkeeping Standard, 1904 on OSHA's
Recordkeeping Page.]

Finally, you asked if an employer can force an employee to take annual audiometric tests as part of their proactive approach to control occupational or nonoccupational hearing loss.

OSHA's Noise standard requires only that audiometric testing be made available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85 dBA. On the other hand, the standard does not prohibit an employer from having a company rule that employees submit to audiometric testing. You should be aware, however, that the Americans With Disabilities Act (ADA) places certain limitations on employer required medical examinations. Among other things, such examinations must be shown to be job related and consistent with business necessity. For guidance on the requirements of the ADA, you may want to contact the Equal Employment Opportunity Commission (EEOC).

We appreciate the opportunity to clarify these matters for you. Should you require additional information, please contact the [Office of Health Enforcement at (202) 693-2190].


John B. Miles, Jr., Director
[Directorate of Enforcement Programs]

[Correction 3/5/2004]


July 13, 1994

John Miles
Director Occupational Safety and Health Administration
Directorate of Compliance Programs
200 Constitution Avenue N.W.
Washington, DC 20210

Mr. Miles,

For the purpose of accurately reporting occupational hearing loss on the OSHA 200 form and notifying employees of standard threshold shifts, Alcan Aluminum Corporation is respectfully requesting answers to the following questions:

Scenario #1

One of our companies has a very proactive hearing conservation program, which provides annual audiometric testing, annual training and education, hearing protection, etc. to all of its employees regardless of occupational noise exposure. Our company feels that by providing this service, we can reduce hearing loss due to the workplace and off-the-job exposures. Recently, an employee, who has a history of off-the-job high noise exposure and greater than 81 dBA 8hr TWA exposure at work, shows a standard threshold shift on the 1994 audiogram. From our investigation, we feel this individual's hearing loss did not result from exposure at work. The employee admits to off-the-job exposure to noise from firearms, woodworking hobbies, and woodcutting activities. According to OSHA standard 1910.95(g), this individual would not have to be included in the hearing conservation program, nor would the company be responsible for providing any audiometric test. Our questions are:

1. In instances, where:


  • documented personal monitoring indicates levels below 85 dBA (triggering level for the OSHA Hearing Conservation Program),

  • there is a history of off-the-job noise exposure,

  • and a non-required audiogram indicates a standard threshold shift,

Is the employer required to meet the "follow-up procedures" as outlined in 1910.95(g)(8)?

2. In the same scenario above, if the employee's audiogram indicates a shift high enough to meet OSHA recordability requirements, is the employer required to put the case on OSHA 200 form if the workplace exposure is below the 85 dBA 8hr TWA?

Scenario #2

An employee is given a baseline audiogram as part of an employment medical examination. He/she works in the plant for ten years with documented noise exposures below 85 dBA TWA. Each year, the employee is offered but refuses an audiogram as part of a proactive, non-required hearing conservation program. On the eleventh year, the employee accepts the audiometric tests which indicates that there has been change from the baseline that is greater than the OSHA recordability requirement. There is also a history of high off-the-job noise exposure.

1. Is the employer required to record this on the OSHA 200 form?

2. Can an employer force an employee to take an annual audiometric tests as part of their proactive approach to control occupational or non-occupational hearing loss?

Your prompt reply will be greatly appreciated. If you should have any questions, please feel free to contact me at 216-523-6804.


Lawrence A. Cooke, CIH
Manager of OH&S Alcan Aluminum Corporation