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Thirty-day retest window for hearing-loss records

Summary An audiology provider asked whether a later hearing test could reverse a former OSHA Form 200 hearing-loss entry. OSHA said a retest had to occur within 30 calendar days to replace the initial audiogram; after that, the recorded case could not be lined out even if the shift was not permanent. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-04-08-1
Date issued
April 8, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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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OSHA labels this an archive document and warns that it may no longer represent current policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 8, 1994

Ms. Mary McDaniel, M.S., CCC-A
V.P. - Coordinator of Services
Washington Audiology Services, Inc.
[Recipient address omitted]
Dear Ms. McDaniel:

Thank you for your letter dated March 18, requesting an interpretation on the proper recording of hearing loss on the OSHA Form 200. Your letter was forwarded to the OSHA Office of Statistics by the Directorate of Compliance. The Division of Recordkeeping Requirements is responsible for the maintenance of the injury and illness recordkeeping system nationwide.

As outlined in the September 4, 1991 letter to Paul Williams of General Dynamics, the retest audiogram must be completed within 30 calendar days of the initial test to be used as a substitute for the initial audiogram. If the retest is given after thirty days, the recorded case may not be lined out even if the audiogram shows that the shift was not permanent. This retest time limit was established to be consistent with the requirements of the Occupational Noise Exposure standard.

Please be aware, however, that the criteria for recording hearing loss on the OSHA Log has no effect on employers obligations under the Occupational Noise Exposure standard (29 CFR Part 1910.95).

I hope you find this information useful. If you have any further questions, please contact us at Area Code: (202) 219-6463.

Sincerely,
Robert Whitmore
Chief
Division of Recordkeeping Requirements

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