Standard Interpretations - Table of Contents
• Standard Number: 1910.95(c)

February 3, 1984

Mr. James M. Sitton
Occupational Safety and Health Services, Ltd.
5 Medical Blvd., Suite A
Hattiesburg, Mississippi 39401

Dear Mr. Sitton:

This will provide a correction to my letter to you of January 16, 1984, regarding the date by which employers must establish a valid baseline audiogram for their employees requiring them, when a mobile test van service is used.

I stated that, for such employers, the deadline date intended by the standard would be September 1, 1984. This is in error. The March 1, 1984, date given at 29 CFR 1910.95(p) for completing baseline audiograms applies to all employers, including those who require mobile test van services. A company would not have complied with this provision if it had merely contracted for the service by the March 1 date, and the baseline audiograms were completed after this deadline.

OSHA recognizes the practical limitations posed by the use of mobile test vans and the logistical problems that could arise. In the preamble to the hearing conservation amendment, published in the Federal Register on March 8, 1983, OSHA agreed "that companies using mobile testing services to satisfy their audiometric testing obligations...should be allowed one year to obtain baseline audiograms."

Thus, the interpretation given in the second paragraph of this letter applies to current employees of an employer who require baseline audiograms. For new employees, or employees newly exposed to noise at or above levels of 85 dBA, 8- hour, time-weighted average (the action level), an employer using a mobile test van service has one year from the date of an employee's first exposure to noise at or above the action level to establish a valid baseline audiogram. As required at 29 CFR 1910.95(g)(5)(ii), however, such employees must wear hearing protectors for any period exceeding six months after first exposure until the baseline audiogram is obtained.

I hope this inform