Immediate audiogram retests after a threshold shift

August 14, 2003

Ms. Joan E. Piosa, R.N.
PPL
[Recipient address omitted]

Dear Ms. Piosa:

Thank you for your July 9, 2003 letter regarding the Occupational Safety and Health Administration's (OSHA) Occupational Noise Standard. You specifically had questions about the retest requirements for audiograms. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Scenario: While testing an employee for his annual hearing test in a mobile van, a 10 dB shift is discovered. The person administering the test takes off the earphones, reinstructs the employee, repositions the earphones and does an immediate retest.

Question: Is this considered a retest? Do we then have only seven (7) days to record it on the OSHA Log or would we still have 30 days to do a confirmation retest?

Response: Paragraph (g)(7)(ii) of the standard, 29 CFR 1910.95, allows employers to retest employees if their annual audiogram shows that an employee may have suffered a standard threshold shift. If the retest is obtained within 30 days, the results of the retest may be considered as the annual audiogram.

While testing an employee a second time could be considered a retest, the standard does not state that only one retest may be given. Immediate retesting may be useful to eliminate errors in testing such as improperly positioned earphones or lack of instruction. If this retest still shows a threshold shift, the fact that it was done does not preclude the employer from determining if other factors, such as allergies or recent noise exposure, may be causing a temporary shift. Another retest may be performed to eliminate these factors as well. If another retest, performed within the 30 days, reveals that the threshold shift was not persistent, these results may be substituted for the annual audiogram. If the retest reveals the shift was indeed persistent and the other recording criteria are met, the hearing loss must be recorded on the OSHA 300 [Log] within 7 days of the retest.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs