Hearing Conservation

The Damage You Don't Feel Until It's Done

CFR reference: 29 CFR 1910.95

Hearing conservation program requirements. Noise monitoring, audiometric testing, hearing protection.

What this is

Noise-induced hearing loss is permanent and cumulative. OSHA's hearing conservation standard (29 CFR 1910.95) requires a full program when employees are exposed to noise at or above 85 dBA over an 8-hour shift. That includes noise monitoring, audiometric testing, hearing protection, training, and recordkeeping. Most small manufacturing and warehouse operations exceed 85 dBA in at least one area — presses, grinders, saws, pneumatic tools, packaging lines — but have no program in place.

What gets missed

No noise monitoring ever conducted
Hearing protection available but not enforced or fitted
No audiometric testing program for exposed employees
Training on noise hazards never documented
Standard threshold shift detected but no follow-up action taken

What OSHA checks

Noise monitoring to identify employees exposed at or above 85 dBA (8-hour TWA)
Audiometric testing program for all exposed employees
Hearing protection provided and available at 85 dBA, required at 90 dBA
Employee training on noise hazards and hearing protection
Recordkeeping — noise exposure records and audiograms maintained

What I see on the floor

I walk through shops where I have to raise my voice to be heard from three feet away — that's roughly 85-90 dBA. Nobody has measured it. Foam earplugs are in a box on the wall but half the operators aren't wearing them. There's no audiometric testing, no baseline hearing tests, and no training records. The noise has been there for years. The hearing loss has been building the whole time. By the time someone notices, the damage is irreversible.

Field checklist

Noise monitoring conducted and documented (identify all areas at or above 85 dBA)
Baseline audiogram completed for all exposed employees within 6 months of hire
Annual audiometric testing conducted and compared to baseline
Hearing protection provided at 85 dBA, required and enforced at 90 dBA
Employees trained annually on noise hazards and proper use of hearing protection
Training documented with dates and attendees
Noise exposure and audiometric records maintained per OSHA requirements
Standard threshold shifts identified and follow-up actions documented

Frequently asked questions

At what noise level does OSHA require a hearing conservation program?

OSHA requires a hearing conservation program when employees are exposed to noise at or above 85 decibels (dBA) averaged over an 8-hour work shift (the Action Level). At 90 dBA, feasible engineering or administrative controls and mandatory hearing protection are required under 29 CFR 1910.95.

Do small manufacturers need audiometric testing?

Yes. If any employee is exposed to noise at or above the 85 dBA Action Level, the employer must provide baseline and annual audiometric testing at no cost. Results must be compared year over year to detect standard threshold shifts.

What counts as an OSHA noise violation in a small shop?

The most common citations include failure to conduct noise monitoring, no audiometric testing program, hearing protection not provided or not enforced, and missing training records. OSHA can cite any of these independently.

Field Note by Vince Lawrence — GigLine Safety & Compliance — Kernersville, NC — (336) 329-8899