Standard Interpretations - Table of Contents
• Standard Number: 1910.95; 1910.95(g)(9)

November 30, 2006

Mr. Steve Cofer
TK Group Incorporated
Stewart Square Suite 250
308 West State St.
Rockford, IL 61101

Dear Mr. Cofer:

Thank you for your March 7, 2006 letter regarding audiograms and the requirements of the Occupational Noise Exposure standard, 29 CFR 1910.95. 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. Your paraphrased statements, questions and OSHA's replies are provided below.

In your letter you stated that your company has been asked to provide hearing testing and professional assistance for a client whose previous vendor is no longer in business. The baseline audiograms reported by the previous vendor were not in the 5-dB steps used by modern audiometers, and the annual audiograms' results were reported as the difference in hearing since the previous annual audiogram rather than the actual readings. You also questioned the accuracy of some of the test results and ask if it can be resolved by performing all new baselines.

The old baselines must continue to be used. All audiograms are considered medical records and are required to be retained for the employee's length of employment. In addition, the noise standard does not allow an annual audiogram to be substituted for a baseline unless the annual audiogram shows a persistent threshold shift or the annual audiogram indicates significant improvement over the baseline. If your software does not allow for numbers other than the 5-dB steps, then it should be done manually. We agree that these audiograms may be a little more difficult to include into the employee's hearing threshold history. We also feel that data of this nature also ind