Audiometric Testing Monitors an Employee’s Hearing: What HR Needs to Know for Federal Compliance
If you’re searching for how audiometric testing monitors an employees hearing, you’re likely trying to confirm when annual hearing tests are required, what OSHA expects, and how to run a compliant industrial hearing screening process. This guide explains the federal rules, who must be tested, and the practical steps HR and safety teams can take to meet hearing conservation program requirements—without overcomplicating implementation.
For broader federal compliance context, SwiftSDS also maintains an employment legislation list covering major workplace requirements that often overlap with safety program administration.
The Federal Rule Behind Industrial Hearing Tests (OSHA Hearing Conservation)
The primary federal compliance requirement for hearing monitoring is OSHA’s Occupational Noise Exposure standard, 29 CFR 1910.95. Under this rule, employers must implement a Hearing Conservation Program (HCP) when employee noise exposures meet or exceed OSHA’s action level.
Key thresholds that trigger hearing conservation program requirements
- Action Level (AL): 85 dBA as an 8-hour time-weighted average (TWA)
When exposures are at or above this level, the employer must implement an HCP, including audiometric testing, training, and hearing protectors. - Permissible Exposure Limit (PEL): 90 dBA (8-hour TWA)
Above this level, additional controls are required, and employers must reduce exposure (engineering/administrative controls where feasible).
In practice, industrial hearing screening is the ongoing measurement (baseline + annual tests) that helps determine whether employees are losing hearing over time and whether your controls and hearing protection practices are working.
Who Is Required to Have an Annual Hearing Test?
A common HR question is: who is required to have an annual hearing test? Under 29 CFR 1910.95, employers must provide audiometric testing at no cost to employees who are exposed at or above the 85 dBA 8-hour TWA action level.
Employees typically included
- Production and manufacturing workers operating loud equipment
- Maintenance staff working around compressors, pneumatic tools, or high-noise mechanical systems
- Warehouse workers exposed to sustained equipment noise (depending on measured levels)
- Construction-like operations inside general industry settings (note: construction has additional considerations under OSHA construction standards, but many employers still implement audiometric programs similarly)
Employees typically excluded (unless exposures meet the action level)
- Office employees with no noise exposure
- Workers whose noise exposure measurements (dosimetry/area sampling) show < 85 dBA TWA
Actionable step: Don’t guess. Use noise monitoring data (personal dosimetry preferred) to identify who must be enrolled.
How Audiometric Testing Monitors an Employee’s Hearing (What the Test Actually Does)
An industrial hearing test (audiometric test) measures hearing thresholds at specific frequencies. OSHA’s goal is not only to test, but to use results to detect early signs of occupational hearing loss.
Baseline audiogram
OSHA requires a baseline audiogram for each enrolled employee:
- Conducted within 6 months of first exposure at or above the action level
- If you use a mobile test van, you may have up to 1 year, but you must provide hearing protection in the meantime (per OSHA allowances in the standard)
Annual audiograms (ongoing monitoring)
After baseline, employers must provide annual testing to:
- Track changes from baseline
- Confirm whether hearing protection and noise controls are effective
- Identify follow-up actions needed (refitting protectors, retraining, medical referral)
Standard Threshold Shift (STS)
OSHA uses the concept of an STS—generally a significant change in hearing compared to baseline. When an STS is identified, the employer must take specific steps, such as notifying the employee and addressing hearing protection effectiveness (requirements are detailed within 29 CFR 1910.95).
Actionable step: Ensure your testing vendor provides clear STS flags and employer next-step recommendations in their reporting package.
Building a Compliant Hearing Conservation Program (HCP)
Audiometric testing is only one piece of OSHA compliance. If you’re meeting the action level, OSHA expects a program that includes multiple components.
1) Noise exposure monitoring
- Conduct initial monitoring to determine who is at/above 85 dBA TWA
- Repeat monitoring when changes in production, equipment, or processes may increase exposures
2) Hearing protection devices (HPDs)
- Provide appropriate hearing protection for affected employees
- Ensure proper fit, training, and availability
- Evaluate attenuation adequacy (NRR-based estimates, fit testing if you use it)
3) Audiometric testing program
To keep your industrial hearing test process compliant:
- Use calibrated equipment and an appropriate test environment (often managed by your vendor)
- Maintain baseline and annual audiograms
- Ensure professional review/interpretation by qualified personnel as required by the standard
4) Training and education
OSHA requires annual training for employees in the HCP. Training typically covers:
- The effects of noise on hearing
- The purpose and use of hearing protectors
- The purpose of audiometric testing and how results are used
5) Recordkeeping
You must retain:
- Noise exposure measurement records
- Audiometric test records (including the employee’s baseline and annuals)
Practical HR tip: Assign a single program owner (HR, EHS, or a joint owner) responsible for enrollment lists, annual scheduling, and documenting corrective actions after STS findings.
Implementation Checklist for HR and Business Owners (Actionable Steps)
Use this condensed checklist to operationalize compliance:
- Confirm exposure levels
Use dosimetry to identify who meets the 85 dBA TWA action level. - Create an enrolled employee list
This becomes your “who is required to have an annual hearing test” roster. - Schedule baseline and annual audiograms
Ensure new enrollees receive baseline audiograms on time. - Set a follow-up protocol for STS
Include employee notification, HPD refit/retraining, and re-test timing where appropriate. - Coordinate with broader compliance communications
Hearing conservation sits alongside other employee-rights communications. Many employers manage these in a centralized compliance library alongside notices like Employee Rights Under the Fair Labor Standards Act (Wage and Hour Division, U.S. Department of Labor).
To help HR teams keep workplace rights resources organized, SwiftSDS also summarizes core protections in 5 rights of workers.
Location-Specific Considerations (Multi-State and Public Sector Notes)
Federal OSHA rules apply to most private employers, but state plans and certain public sector workplaces can have additional requirements.
- If you operate in Massachusetts public employment settings, you may also need to track Massachusetts-specific safety posting obligations such as Massachusetts Workplace Safety and Health Protection for Public Employees (MA Department of Labor Standards).
- Massachusetts employers often maintain multiple required postings (wage & hour, discrimination, safety). For example, Fair Employment in Massachusetts (Massachusetts Commission Against Discrimination) is commonly part of the compliance set.
When noise exposure intersects with disability or accommodation issues (for example, hearing loss accommodation requests), HR should also be familiar with ADA administration resources, including ADA HR requirements and practical ADA forms for employers.
Common Compliance Pitfalls (and How to Avoid Them)
Enrolling the wrong employees (or missing the right ones)
Relying on job titles instead of measured exposures is a frequent problem. Use current noise monitoring and revisit after operational changes.
Treating audiometric testing as “optional wellness”
OSHA audiograms are a compliance program element once the action level is met. Make sure your policy frames the industrial hearing screening as required for enrolled employees.
No documented response to STS
Testing alone isn’t enough. Your documentation should show what you did after an STS—refit HPDs, retrain, review noise controls, and ensure required notifications occurred.
FAQ: Audiometric Testing and Annual Hearing Tests
Does audiometric testing monitor an employee’s hearing even if they wear hearing protection?
Yes. The point of audiometric monitoring is to track hearing over time and detect shifts that may indicate that hearing protection fit, use, or noise controls aren’t sufficient—even when HPDs are provided.
Who is required to have an annual hearing test under OSHA?
Employees exposed to 85 dBA or higher (8-hour TWA) must be included in a hearing conservation program and provided baseline and annual audiometric testing under 29 CFR 1910.95.
What records should HR keep for an industrial hearing test program?
Maintain noise exposure measurement records and audiometric test records (baseline, annual results, and related documentation). Also keep evidence of training and any follow-up actions taken after a flagged hearing threshold shift.
Keeping audiometric testing organized is easiest when it’s treated as a repeatable compliance workflow—identify covered employees, test on schedule, document follow-up actions, and align the program with your broader federal and state labor compliance library. For additional federal-law context that often overlaps with HR compliance planning, see SwiftSDS’s employment legislation list.