Back to Federal guidance

New hearing-loss baseline after recording a loss

Summary A company physician asked when a hearing-loss audiogram became the new reference point for OSHA's former Form 200. OSHA said a recordable loss became the baseline for future losses, and the first valid audiogram after rehire became the baseline for a returning employee. 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
1996-01-22
Date issued
January 22, 1996
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 12, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 22, 1996

Larry Catlett, M.D.
CIANBRO Corporation
[Recipient address omitted]
Dear Dr. Catlett:

This is in response to your letter of November 14, concerning the recording of hearing loss on the OSHA Form 200.

You stated you are unclear as to the position of the Occupational Safety and Health Administration (OSHA) on resetting the reference audiogram once a hearing loss that must be recorded on OSHA Form 200 has occurred. When a hearing loss occurs that must be recorded on OSHA Form 200, the audiogram indicating the hearing loss becomes the new baseline for determining whether future additional hearing loss by the individual must again be recorded on OSHA Form 200.

You asked about establishing an original baseline audiogram for an employee who returns to a company after leaving it. The first valid audiogram obtained from the employee after rehire becomes the original baseline audiogram that must be used as the reference for determining if hearing loss by the employee must be recorded on OSHA Form 200.

We appreciate the opportunity to clarify these matters for you. If you have further questions please do not hesitate to contact Gail Brinkerhoff of the Office of Health Compliance Assistance on (202) 219-8036.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]

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