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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 19, 1995

Ms. Susan Cooper
Mergerson Senior Vice President
Impact Health Services, Inc.
920 Main Street
Suite 700
Kansas City, Missouri 64105

Dear Ms. Mergerson:

Thank you for your letter dated April 21, 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 Programs. The Division of Recordkeeping Requirements is responsible for the maintenance of the injury and illness recordkeeping system nationwide.

As outlined in the September 11, 1991 letter to Steven Cofer, 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 or any subsequent audiogram 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.

If medical evidence shows that a shift is not work related, the shift should not be recorded on the OSHA 200 Log. If a worker is exposed to noise levels in excess of an 85 dB 8-hour time-weighted average, as found in the Noise Standard, any hearing loss is presumed to be work related. This presumption may be rebutted only with medical evidence that shows the entire shift in hearing was caused by non-occupational factors. A physician's written opinion stating that the loss was not caused, contributed to, or aggravated by the work environment is required.

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