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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 12, 1995

Ms. Monica Verros, R.N., C.O.H.N.
Occupational Health Advisor, Mail Drop 14A
IBP, Inc.
IBP Avenue
Post Office Box 515
Dakota City, Nebraska 68731

Dear Ms. Verros:

Thank you for your letter dated April 14, requesting an interpretation regarding the proper recording procedures for cases involving occupational hearing loss. If an audiogram shows a hearing loss that is recordable on the OSHA Form 200, the date entered in Column (b) is the date the employee was tested. If a retest performed within 30 calendar days of the initial test shows the hearing loss is not recordable, the original entry may be lined out. A retest audiogram may not be substituted for an initial audiogram unless it is obtained within thirty calendar days of the date of the initial audiogram. The 1993 annual test in your example may not be used to line out the 1992 case.

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