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 http://www.osha.gov.
January 22, 1996
Larry Catlett, M.D.
Post Office Box 1000
Pittsfield, Maine 04967
Dear Dr. Catlett:
This is in response to your letter of November 14, concerning the recording of hearing loss on the OSHA Form 200.
You stated you are unclear as to the position of the Occupational Safety and Health Administration (OSHA) on resetting the reference audiogram once a hearing loss that must be recorded on OSHA Form 200 has occurred. When a hearing loss occurs that must be recorded on OSHA Form 200, the audiogram indicating the hearing loss becomes the new baseline for determining whether future additional hearing loss by the individual must again be recorded on OSHA Form 200.
You asked about establishing an original baseline audiogram for an employee who returns to a company after leaving it. The first valid audiogram obtained from the employee after rehire becomes the original baseline audiogram that must be used as the reference for determining if hearing loss by the employee must be recorded on OSHA Form 200.
We appreciate the opportunity to clarify these matters for you. If you have further questions please do not hesitate to contact Gail Brinkerhoff of the Office of Health Compliance Assistance on (202) 219-8036.
Ruth McCully, Director
Office of Health Compliance Assistance
November 14, 1995
Mr. John Miles
US Dept of Labor
Dept of Compliance
200 Constitution Ave N.W.
Room N 3468
Washington DC 20210
Dear Mr. Miles:
In June 1991 "Memorandum for Regional Administrators" from Patricia Clark, employers were required to record in their OSHA 200 log, work related shifts in hearing of an average of 25 dB or more from original baseline at 2000, 3000, and 4000 Hz. I remain unclear as to OSHA's position to resetting this OSHA 200 reference baseline (to that of the audiogram substantiating the persistent threshold loss of 25 or more dB) once a recordable event has occurred. Please state OSHA's position on this question.
As a separate question, please address the issue of rehires and "original" baselines. That is, if an employee leaves a particular employer who has maintained hearing conservation records on that employee, does or does not work elsewhere during his absence from that same employer, and, is subsequently rehired by same employer, does the audiogram performed at the date of rehire become the "original" OSHA 200 reference baseline as it would with a completely "new" employee?
Thank you for your attention to these questions.
Very truly yours,
Larry Catlett MD
CIANBRO CORPORATION/Pittsfield ME
The Health Center/Lewiston ME