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Hearing-loss recording policy and baseline definition

Summary A manufacturer asked about OSHA's hearing-loss recording memoranda and whether the policy required rulemaking. OSHA said the memoranda addressed enforcement of an existing rule, and defined the original baseline by the audiogram established under the 1983 hearing-conservation amendment. OSHA archives the letter and warns that it may no longer reflect current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-12-16-2
Date issued
December 16, 1991
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
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
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 16, 1991

Mr. Melvin W. Johnson
Vice President
Lamson & Sessions
[Recipient address omitted]
Dear Mr. Johnson:

Thank you for your letter of October 15, to the Occupational Safety and Health Administration (OSHA), concerning the recording of hearing loss on the OSHA Form 200.

On June 4 and August 27, 1991, two memoranda were issued to the OSHA Regional Administrators outlining the Federal policy for uniformly enforcing the recording of work related hearing loss on the OSHA Form 200. The memoranda provide an OSHA enforcement policy related to an existing regulation (29 CFR 1904) and its supplementary guidelines. For this reason the rulemaking procedures under the Administrative Procedures Act were not appropriate.

Enclosed are copies of these memoranda detailing the criteria for the OSHA enforcement policy regarding the recording of occupational hearing loss. Please be aware that the employee's "original baseline" referred to in the August 27 memorandum is defined as the baseline audiogram established in accordance with the hearing conservation amendment promulgated March 8, 1983.

We are presently working on a "hearing loss fact sheet" that will clearly outline the issues associated with recording hearing loss on the OSHA Form 200. When it is completed, we will be sure to forward you a copy.

If you have any questions concerning the information enclosed, please contact the OSHA Office of Statistics at Area Code (202) 523-1463.

Sincerely,
Gerard F. Scannell
Assistant Secretary

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