Historical OSHA 200 log criteria for hearing shifts

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 14, 1991

Ms. Cynthia H. Drollinger
President
HCI, Inc.
[Recipient address omitted]

Dear Ms. Drollinger,

Thank you for your letter of August 16 concerning the recording of Standard Threshold Shifts (STS) on the OSHA 200 log. The 25 dB shift criteria represents a long standing Federal enforcement position. It establishes the level of work-related hearing loss that must be recorded on the OSHA 200 log. However, we do encourage the recording of lower dB shifts. Please be aware that this criteria in no way affects the 29 CFR 1910.95 requirements. All requirements in that regulation are still in full force and effect. The following answers address the questions in the same order as presented in your letter:

a. Yes. The 10 dB criteria for STS in 29 CFR 1910.95 does not require entry on the OSHA 200 log. Recording and reporting of occupational injuries and illnesses is controlled by 29 CFR 1904.

b. An annual audiogram may be substituted for a baseline audiogram when, in the judgment of the audiologist, otolaryngologist or physician who is evaluating the audiogram: 1) The standard threshold shift revealed by the audiogram is persistent; or 2) The hearing threshold shown in the annual audiogram indicates significant improvement over the baseline audiogram. Otherwise, decisions on revising audiogram baselines must continue to be based on events of standard threshold shifts (STSs) as defined at 29 CFR 1910.95(g)(10).

c. The 25 dB criteria is a Federal enforcement criteria. The State Plan States may adopt this criteria or enforce the recording of lower work-related shifts. It is their option.

1. There is no reference to this criteria in OSHA documents. The 25 dB criteria is based on guidance found in the American Medical Associations Guide to the Evaluation of Permanent Impairment. This threshold criteria was chosen because it is widely accepted as a meaningful loss of hearing and is well documented.

2. The measurement of the 25 dB shift should begin from the employees original baseline.

3. The revised baselines should not be used to track the new 25 dB shift. The original baseline should be used.

4. A 25 dB shift from revised baselines for persistent 10 dB shifts would be rather unusual. However we are requiring that the original baseline be used for the measurements, not the revised baselines.

5. Yes, therefore we are using the original baseline to make the measurements.

6. The 25 dB shift criteria has no impact at all on the 29 CFR 1910.95 requirements. All requirements in that regulation still apply.

The 25 dB shift has no new impact on the recordability of shifts for employees who are exposed to less than 85 dB time-weighted average. As in the past, work-relationship must first be determined. If the work environment caused, aggravated, or contributed to the 25 dB shift, then the case must be recorded.

Let me assure you that the 10 dB STS recordability criteria will be examined carefully during the regulatory revision we have begun for 29 CFR 1904. A revised set of supplementary instructions to the OSHA 200 and 101 forms will also be included. As mentioned earlier, the 25 dB criteria is an already existing OSHA enforcement position on recording work-related hearing loss.

If you have any questions, please contact my Office of Statistics at (202) 523-1463.

Sincerely,
Gerard F. Scannell
Assistant Secretary

[The requester’s August 16 letter reproduced on the OSHA page is omitted here.]