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Historical baseline for logging hearing loss

Summary OSHA told its regional offices that under then-current OSHA 200 recordkeeping guidance, the original audiogram baseline should be used to calculate a recordable hearing shift. The memo also said employers still had to meet hearing-conservation duties under 1910.95. OSHA labels the memo archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-08-27-2
Date issued
August 27, 1991
Status
Archived by the agency
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Hearing Conservation
Source
View the official document

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The current status of this document is unclear
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 27, 1991

MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS

THRU: LEO CAREY, Director
Office of Field Programs

FROM: PATRICIA K. CLARK, Director
Directorate Of Compliance Programs

SUBJECT: Recording of Hearing Loss on OSHA Form 200

This memorandum provides guidance concerning the recording of hearing loss on the OSHA Form 200.
Several inquiries have been received regarding the need to specify a baseline for calculating hearing shifts that presently must be recorded on OSHA Form 200. Please be aware that the original baseline must be used for this purpose. A correction for presbycusis may be made when determining the recordability of the hearing shift.
Of course, aside from the present requirement for recording hearing loss on OSHA Form 200, employers must continue to comply with all aspects of 29 CFR 1910.95.

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