Knowing when to conduct hearing tests

The regulation for occupational noise exposure requires employers to conduct hearing tests if employees are exposed to noise levels at or above 85 decibels on an 8-hour time-weighted average. This seemingly simple requirement raises a lot of questions, however, such as how long the employee may be exposed to that noise level before testing is required, and how soon new hires (or newly exposed employees) must be tested.

One day of exposure

In a Letter of Interpretation dated February 13, 2004, OSHA said one day of exposure to noise levels at or above 85 decibels on an 8-hour time-weighted average would mean the employee is covered by the hearing conservation program.

According to the letter, all employees exposed to such noise levels must be included in a hearing conservation program. This includes employees with only occasional exposures, such as employees who visit a particular facility only a few times per year, but are exposed at that level during those visits.

During an inspection, OSHA will review employer records to determine if all covered employees have been included in the hearing conservation program.

Test within 6 months

According to 29 CFR 1910.95(g)(5)(i), the employer must establish a baseline audiogram within six months of an employee's first exposure at or above the action level. This first hearing test provides the foundation for comparing subsequent audiograms.

The requirement to test within six months obviously applies to newly hired employees, but also applies to other employees whose job assignments have changed in a way that results in their first exposure (remember, that means even one day) at or above the action level. Keep in mind that changes in equipment may also affect which employees are exposed.

Annual testing and retesting

Covered employees must then be tested annually, and the results compared to the employee’s baseline audiogram. If a standard threshold shift has occurred, the regulation lists a number of follow-up procedures that the employer must take. However, the employer may retest within 30 days and consider the results of the retest as the annual audiogram.

Among other follow-up procedures, if a standard threshold shift occurred and the employee is already using hearing protection, the employee must be refitted and retrained in the hearing protection. If necessary, the employee must be provided with hearing protection that offers greater attenuation.