Ezel / Labor Guidance / US
Back to Federal guidance

Retest timing for occupational hearing loss logs

Summary An employer asked what date to enter for a recordable hearing loss and when a retest could remove the entry. OSHA said to use the initial test date and allowed removal if a retest within 30 calendar days was nonrecordable; a later annual test could not replace that retest. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-06-12-0
Date issued
June 12, 1995
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Loss
Source
View the official document

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 12, 1995

Ms. Monica Verros, R.N., C.O.H.N.
Occupational Health Advisor, Mail Drop 14A
IBP, Inc.
[Recipient address omitted]
Dear Ms. Verros:

Thank you for your letter dated April 14, requesting an interpretation regarding the proper recording procedures for cases involving occupational hearing loss. If an audiogram shows a hearing loss that is recordable on the OSHA Form 200, the date 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, the original entry may be lined out. A retest audiogram may not be substituted for an initial audiogram unless it is obtained within thirty calendar days of the date of the initial audiogram. The 1993 annual test in your example may not be used to line out the 1992 case.

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

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

Related guidance

Permanently labeled locks for electrical lockout Opinion Letter · August 17, 2026 Helmet selection for lateral head-impact hazards Opinion Letter · August 17, 2026 Asbestos precautions when restoring drywall after flood damage Opinion Letter · May 7, 2026 Enforcement policy for recording and reporting COVID-19 cases Guidance · March 31, 2026

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace