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 https://www.osha.gov.
February 14, 1994
Ms. Julie Ridgely, 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. Ridgely:
Thank you for your letter dated January 27, requesting an interpretation regarding the proper recording of hearing loss on the OSHA Log 200.
As you know, a June 4, 1991 memorandum was issued to clarify Federal OSHA's enforcement policy regarding the recording of hearing loss on the OSHA Log 200. Please be aware that there are several States with their own approved OSH plans which require 10 dB Standard Threshold Shifts be recorded on the OSHA Log.
OSHA encourages companies to record work related 10 dB Standard Threshold Shifts on their OSHA Log. Companies who adopt this practice need only use a single set of records and baseline audiograms to meet the requirements of both the Occupational Noise Exposure standard and the injury and illness recordkeeping regulations.
The interpretation as outlined in your letter is correct. For OSHA injury and illness recordkeeping purposes, once an employee experiences a recordable shift in hearing (25 dB or greater) the audiogram showing the recordable shift would become the employee's new reference audiogram for future recordability comparisons. An additional case need not be recorded until the employee experiences a further cumulative 25 dB shift from the new reference audiogram.
I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements