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OSHA 1904.10

Occupational hearing loss recording

Subpart C

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 1904.10(a), when must I record an employee's occupational hearing loss on the OSHA 300 Log?

You must record a hearing loss on the OSHA 300 Log when an employee's audiogram shows a work-related Standard Threshold Shift (STS) in one or both ears and the employee's total hearing level in the same ear(s) is 25 decibels (dB) or more above audiometric zero (averaged at 2000, 3000, and 4000 Hz). See Recording criteria in 1904.10(b) and the basic requirement in 1904.10(a).

Under 1904.10(b)(1), what is a Standard Threshold Shift (STS)?

A Standard Threshold Shift (STS) is an average change in hearing threshold of 10 dB or more at 2000, 3000, and 4000 Hz in one or both ears compared to the employee's baseline audiogram. This definition comes from the occupational noise standard at 29 CFR 1910.95(g)(10)(i) and is summarized in 1904.10(b)(1).

Under 1904.10(b)(2)(i), which baseline audiogram do I compare to determine if an STS has occurred?

You compare an employee's current audiogram to that employee's baseline audiogram; if the employee already has a previously recorded hearing loss, you compare the current audiogram to the employee's revised baseline that reflects the prior recordable case. See 1904.10(b)(2)(i) and 1904.10(b)(1).

Under 1904.10(b)(2)(ii) and (b)(3), how do I determine whether an employee's total hearing level is 25 dB or more?

You determine the employee's total hearing level by averaging the hearing levels at 2000, 3000, and 4000 Hz on the employee's current audiogram and comparing that average to audiometric zero; if the average is 25 dB or more above audiometric zero in the same ear(s) as the STS, the case is recordable. See 1904.10(b)(2)(ii) and 1904.10(b)(3).

Under 1904.10(b)(3), may I use age adjustment when evaluating whether an STS has occurred?

Yes—you may age-adjust the employee's current audiogram results when determining whether an STS has occurred by using Tables F-1 or F-2 in appendix F of the noise standard [29 CFR 1910.95]. However, you may not use age adjustment when deciding whether the employee's total hearing level is 25 dB or more above audiometric zero. See 1904.10(b)(3) and 1910.95.

Under 1904.10(b)(4), if I plan to retest an employee's hearing, do I have to record the case immediately?

No—not if you retest within 30 days and the retest does not confirm a recordable STS: you are not required to record the case. If the retest confirms the recordable STS, you must record the hearing loss within seven calendar days of the retest. If later testing shows the STS is not persistent, you may erase or line-out the recorded entry. See 1904.10(b)(4).

Under 1904.10(b)(5) and 1904.5, are there special recordkeeping rules for determining whether a hearing loss is work-related?

No—there are no special rules specific to hearing loss; you must apply the general work-relatedness rules in [1904.5] to determine whether the hearing loss is work-related. If an event or exposure in the work environment caused, contributed to, or significantly aggravated the hearing loss, consider the case work-related. See 1904.10(b)(5) and 1904.5.

Under 1904.10(b)(6), if a physician or licensed health care professional finds the hearing loss not work-related, must I still record it?

No—if a physician or other licensed health care professional determines, applying the rules in [1904.5], that the hearing loss is not work-related or that occupational noise did not significantly aggravate it, you are not required to record the case on the OSHA 300 Log. See 1904.10(b)(6) and 1904.5.

Under 1904.10(b)(7), how do I mark a recordable hearing loss on the OSHA 300 Log?

When you enter a recordable hearing loss on the OSHA 300 Log, check the column for hearing loss on the 300 Log to indicate the case involves a hearing loss. See 1904.10(b)(7).

Under 1910.95(g)(10)(i), how do I calculate whether an STS has occurred using audiogram numbers?

You calculate an STS by comparing the average hearing thresholds at 2000, 3000, and 4000 Hz on the current audiogram to the same average on the baseline audiogram; an increase (worsening) of 10 dB or more in that averaged value in one or both ears is an STS. See 1910.95(g)(10)(i) and 1904.10(b)(1).

Under 1904.10, can a hearing loss be recordable if the STS is in only one ear?

Yes—an STS in one ear can make the case recordable if that same ear's average hearing level at 2000, 3000, and 4000 Hz is 25 dB or more above audiometric zero. The rule counts STS in one or both ears and requires the 25-dB threshold in the same ear(s). See 1904.10(b).

Under 1904.10(b)(3), may I use the age-adjustment tables from appendix F of 1910.95 when determining the 25-dB total hearing level?

No—you may use Tables F-1 or F-2 in appendix F of [1910.95] to age-adjust the current audiogram when determining whether an STS has occurred, but you may not use age adjustment to determine whether the employee's total hearing level is 25 dB or more above audiometric zero. See 1904.10(b)(3) and 1910.95.

Under 1904.10(b)(4), what happens if subsequent audiometric testing shows the STS is not persistent after I recorded the case?

If later audiometric testing performed under the 1910.95 noise standard shows the STS is not persistent, you may erase or line-out the previously recorded OSHA 300 Log entry for that hearing loss. See 1904.10(b)(4).

Under 1904.10(b)(2), what does “total hearing level” mean for recordkeeping purposes?

For recordkeeping, the employee's "total hearing level" is the average hearing level at 2000, 3000, and 4000 Hz on the current audiogram compared to audiometric zero; that averaged value is used to determine whether the hearing level is 25 dB or more. See 1904.10(b)(2)(ii) and 1904.10(b)(3).

Under 1904.10(b)(2)(i), how is a 'revised baseline' created when an employee previously had a recordable hearing loss?

A revised baseline is the audiogram that reflects the employee's previous recordable hearing loss case and is used as the comparison audiogram for future STS determinations—i.e., if the employee already has a recordable loss, compare the current audiogram to the revised baseline rather than the original baseline. See 1904.10(b)(2)(i).

Under the recordkeeping rules, can electronic or software-generated forms replace OSHA Form 300 and Form 300A?

Yes—software-generated or electronic forms can be used as substitutes for OSHA Form 300 and Form 300A so long as they meet the equivalent-form requirements in the recordkeeping rules and can produce equivalent forms for access and inspection. See the OSHA interpretation Software-generated OSHA recordkeeping forms and general recordkeeping 1904.

Under 1904.5 and the motor vehicle fatality interpretation, how do I decide if a hearing loss discovered while an employee was traveling is work-related?

Apply the general work-relatedness rules in [1904.5]: a condition is work-related if an event or exposure in the work environment caused, contributed to, or significantly aggravated it; travel-status rules (including the "home away from home" exception) can affect that determination. See 1904.5 and the OSHA interpretation on travel-status work-relatedness in the motor vehicle fatality letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-12 for practical examples of how travel affects work-related determinations.

Under 1904.10(b), can I record a hearing loss when the STS and the 25-dB level are in different ears?

No—you only record the case if the STS and the 25-dB total hearing level occur in the same ear(s); both conditions must exist in the same ear(s) for the case to be recordable. See 1904.10(b).

Under 1904.10(b)(4), what is the time frame for retesting to avoid an immediate recordable entry?

If you retest the employee's hearing within 30 days of the first test and the retest does not confirm a recordable STS, you do not have to record the case; if the retest confirms an STS, you must record the case within seven calendar days of that retest. See 1904.10(b)(4).

Under 1910.95 and 1904.10, which frequencies are used to evaluate both STS and the 25-dB total hearing level?

The evaluation for both STS and the total hearing level uses the hearing thresholds at 2000, 3000, and 4000 Hz—STS is based on a 10 dB average change at these frequencies and the 25-dB total hearing level is the average at these same frequencies compared to audiometric zero. See 1910.95(g)(10)(i) and 1904.10(b)(3).

Under 1904.10, if an employee's current audiogram is age-adjusted for STS but the 25-dB threshold is not met without the adjustment, is the case recordable?

No—the age adjustment may be used only to determine whether an STS has occurred; you cannot use age adjustment when deciding whether the employee's total hearing level is 25 dB or more above audiometric zero, so if the unadjusted current audiogram average is less than 25 dB the case is not recordable even if age-adjusted values show an STS. See 1904.10(b)(3) and 1910.95.

Under 1904.10(b), what should I do if a hearing loss case is found to be non-work-related after I recorded it because of a physician's evaluation?

If a physician or other licensed health care professional, applying the rules in [1904.5], determines the hearing loss is not work-related, you are not required to consider the case work-related or keep it recorded as work-related; follow the physician's determination consistent with 1904.10(b)(6) and 1904.5.