Historical OSHA 200 hearing-loss retest timing

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 4, 1991
Mr. Paul V. Williams
Health and Safety Specialist
General Dynamics
Land Systems Division
[Recipient address omitted]

Dear Mr. Williams:

This is in response to your letter requesting clarification of some issues related to a Standard Threshold Shift (STS) in hearing level. Before we answer your questions we wish to inform you that the Occupational Safety and Health Administration (OSHA) is currently not enforcing the recording of hearing loss on OSHA Form 200 unless the shift from the original baseline audiogram at frequencies 2,000, 3,000, and 4,000 Hz averages 25 dB or greater in either ear.

1. If an audiogram shows a hearing loss that is recordable on OSHA Form 200, the date must be entered in column (B) is the date the employee was tested. If a retest performed within 30 calendar days of the initial test shows the hearing loss is not recordable on OSHA Form 200, the original entry may be deleted by drawing a line through it.

2. A retest audiogram may not be substituted for an initial audiogram unless it is obtained within thirty calendar days of the date of initial audiogram regardless of the fact that an outside evaluating concern is used.

3. The thirty day retest time limit was adopted to enable employees to learn about their state of hearing as soon as practicable.

We appreciate the opportunity to clarify these matters for you.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

[The requester’s June 4 letter reproduced on the OSHA page is omitted here.]