Back to Federal guidance

Standard threshold shifts for workers with severe hearing loss

Summary A system designer asked how to identify a standard threshold shift for a worker with a very poor baseline audiogram. OSHA said the 10 dB average change at 2,000, 3,000, and 4,000 Hz applies regardless of baseline thresholds, and that an audiometer with sufficient output and a qualified clinical evaluator may be needed for severe loss. The guidance matters to employers administering hearing-conservation programs.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-11-17
Date issued
November 17, 1989
Status
Active
Status last verified October 10, 2026

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

November 17, 1989

Mr. Stephen Gee
System Designer
Formerly Environmental Health Associates
[Recipient address omitted]
Dear Mr. Gee:

This is in response to your letter of October 12, 1989, addressed to MaryAnn Garrahan, concerning the identification of a standard threshold shift (STS) in hearing ability for individuals with a very poor sense of hearing.

An STS is defined at 29 CFR 1910.95(g)(10) in the occupational noise exposure standard as "... a change in hearing threshold relative to the baseline audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear." This definition applies regardless of the hearing threshold values in the baseline audiogram. Therefore, if, for example, an employee's baseline audiogram showed hearing thresholds of -10 dB at all three frequencies and the employee's first annual audiogram showed hearing thresholds of O dB at all three frequencies, the employee has had a change in hearing threshold of an average of 10 dB relative to the baseline audiogram and has suffered an STS.

In the case of an employee whose baseline audiogram shows hearing thresholds of 90 dB at all three test frequencies, the determination of an STS would have to be done with an audiometer having an output of at least 100 db at all three frequencies. Only persons qualified to do clinical audiological evaluations should make such determinations.

I appreciate the opportunity to clarify this matter for you. If you require more information please do not hesitate to contact me.

Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace