Standard Interpretations - Table of Contents
• Standard Number: 1910.95

February 8, 2005

Ms. Cindy Bloyer
1600 Genessee
Suite 700
Examinetics, Inc.
Kansas City, MO 64102

Dear Ms. Bloyer;

Thank you for your letter of May 17, 2004 letter to the Occupational Safety and Health Administration (OSHA) regarding the requirements for baseline audiograms under the Occupational Noise standard, 29 CFR 1910.95. Your questions have been restated below, followed by OSHA's response. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Question 1: What is OSHA's position regarding audiometric baseline revisions in rehire situations?

Answer: As a general rule, the baseline audiogram that is first in time will provide the most accurate characterization of the employee's hearing acuity against which to compare subsequent hearing acuity. Therefore, in a rehire situation, if the employer still has the original baseline audiogram, that audiogram may be considered to be the baseline since in fact it was obtained within 6 months (or one year in the case of audiograms taken in a mobile test van) of the employee's first noise exposure. Subsequent audiograms would be compared to that audiogram; if a STS appears, then the subsequent audiogram would become the revised baseline. The standard only requires employers to keep the audiometric test records for their length of employment. If the previous audiograms were not retained, then the first valid audiogram obtained from the employee after rehire would become the baseline audiogram.

Question 2: If rehire baselines are allowed, is there a specific time window required between termination and rehire?

Answer: No, there is no specific time window. If the employer still has the baseline audiogram from the initial period of employment and it is a valid baseline, it may still serve as the baseline.

Question 3: Are employers allowed to establish their own policy regarding this issue?

Answer: Althou