Hearing loss is one of the most common occupational health conditions in the United States, yet many employers struggle to understand when it must be officially recorded. OSHA (Occupational Safety and Health Administration) requires certain cases of workplace-related hearing loss to be logged on the OSHA 300 form, but the rules involve specific thresholds and work-relatedness criteria.
Understanding these requirements matters not just for compliance, but also for protecting employees’ long-term health. By breaking down the criteria step by step, employers, safety stewards, and workers can better navigate when hearing loss is recordable and what that means for workplace safety.
Key Takeaways
- A case is recordable when hearing loss meets the Standard Threshold Shift (STS) definition and reaches OSHA’s decibel criteria.
- Employers must evaluate whether the hearing loss is work-related, not just present.
- Proper conservation programs, audiograms, and documentation reduce compliance risks.
Understanding OSHA’s Recordkeeping Requirements
OSHA’s recordkeeping rules exist to help monitor workplace health and safety trends. By requiring employers to log certain injuries and illnesses, OSHA can better identify risks that are widespread and take steps to reduce them. Hearing loss has its own category because it is one of the most common long-term occupational health problems, particularly in industries such as manufacturing, construction, mining, and aviation.
The OSHA 300 Log is the main tool for tracking these cases. Employers must document any recordable incidents of work-related hearing loss, along with other injuries and illnesses. This log is not only reviewed internally, but can also be inspected by OSHA or used in safety audits. Consistent and accurate recordkeeping helps employers spot trends in their workplace, identify whether their hearing conservation programs are effective, and avoid regulatory penalties.
What Is a Standard Threshold Shift (STS)?
A Standard Threshold Shift (STS) is a technical term, but it describes a simple idea: a measurable decline in an employee’s hearing ability. OSHA defines STS as an average shift of 10 decibels (dB) or more at 2000, 3000, and 4000 hertz (Hz) in one or both ears when compared to the employee’s baseline audiogram.
Audiograms are the hearing tests used to track a person’s hearing over time. Every employee exposed to hazardous noise should have a baseline test when they begin work, and yearly tests after that. By comparing these results, employers can identify whether hearing has worsened. Even small shifts matter, since they often indicate early occupational damage.
OSHA allows adjustments for presbycusis, or age-related hearing loss, to ensure that natural changes that come with aging are not mistakenly counted as workplace-caused. This adjustment ensures recordable cases are tied to actual occupational exposure rather than unrelated factors.
Decibel Thresholds for Recordability
Not every STS automatically becomes recordable. For a case to be added to the OSHA 300 Log, it must meet two conditions. First, the employee must have experienced a work-related STS. Second, the overall hearing level in the affected ear must be 25 dB or more above audiometric zero when averaged at 2000, 3000, and 4000 Hz.
This requirement means that both a shift and a minimum level of hearing loss must be present. For example, an employee might show a 10 dB shift from their baseline test, but if their overall hearing level still averages below 25 dB, the case is not recordable. On the other hand, if the same shift pushes their hearing above the 25 dB mark, it becomes recordable.
By setting this dual requirement, OSHA ensures that only meaningful and significant cases are logged. This helps employers focus on cases where occupational exposure has a measurable impact on overall hearing health.
Determining Work-Relatedness
Even if an audiogram shows an STS and the decibel threshold is met, the case is only recordable if it is determined to be work-related. OSHA defines work-relatedness in §1904.5 as any injury or illness that is caused or significantly aggravated by the workplace environment. This means employers must carefully consider whether job-related noise was a contributing factor.
When making this determination, it is important to look at the full context. Employers should ask: What noise levels are typical in the employee’s work area? Were hearing protection devices issued, and if so, were they appropriate for the type of noise exposure? Did the employee use them consistently and correctly? Are there medical conditions, hobbies, or other off-the-job activities that could have contributed to the hearing loss?
For instance, if an employee works around 95 dB noise levels without adequate protection, the loss is likely to be considered work-related. However, if the employee is also a hunter or plays in a loud band, additional factors may need to be weighed. Importantly, OSHA guidance makes clear that the use of hearing protection does not by itself exclude a case from being recordable. Employers must consider whether workplace noise still contributed to the decline despite protective measures.
OSHA 300 Log Reporting Process
Deciding whether to record a case of hearing loss can feel overwhelming, but following a structured process helps ensure accuracy and compliance.
Employers should begin by reviewing the most recent audiogram. If there is an STS, they should then calculate whether the overall hearing level reaches 25 dB above baseline. If both conditions are met, the next step is to carefully evaluate whether workplace noise contributed to the loss. This means considering exposure levels, PPE usage, and any other relevant factors.
If the case meets all requirements, it must be added to the OSHA 300 Log under the hearing loss column. Employers should document their reasoning at each stage, since OSHA inspectors may ask to see not only the log itself but also how decisions were made. Thorough documentation demonstrates good faith and helps prevent disputes if a case is questioned later.
Preventing Recordable Hearing Loss Cases
While compliance is important, prevention is the most effective way to reduce risk. A strong hearing conservation program can significantly limit both the number of recordable cases and the long-term health impacts for employees.
Preventive strategies include engineering controls, which focus on reducing noise at the source. Examples include installing sound barriers, replacing outdated equipment with quieter models, or ensuring machinery is properly lubricated to minimize noise. When noise cannot be fully eliminated, administrative controls may help, such as rotating employees between tasks to reduce their time in high-noise areas or designating quiet zones where workers can take breaks from exposure.
Personal protective equipment (PPE) is another critical layer. Employers should not only provide appropriate earplugs or earmuffs, but also train employees on how to use them correctly. Many recordable cases occur simply because workers do not insert earplugs properly, or because they remove them too often during a shift. Training sessions and reminders can greatly improve compliance.
Finally, education plays a powerful role. Workers are more likely to protect their hearing when they understand both the immediate and long-term risks. Providing real-world examples, sharing statistics, and encouraging annual audiograms can make the dangers more tangible and encourage consistent use of protection.
Key Takeaways for Employers and Safety Stewards
Employers and safety representatives have a shared responsibility: to protect hearing health while ensuring compliance with OSHA rules. By clearly understanding the criteria for recordability, organizations can avoid fines, reduce risks, and promote safer workplaces.
The key is to remember three pillars: the definition of STS, the 25 dB threshold, and the requirement that hearing loss must be work-related. When combined with a strong prevention program, these guidelines provide a clear roadmap for maintaining both compliance and employee well-being.
Frequently Asked Questions
What is considered a recordable hearing loss case under OSHA?
A case is recordable when an employee has both a work-related Standard Threshold Shift (STS) and their hearing level reaches 25 dB or more above audiometric zero in the affected ear.
Does hearing protection use exempt a case from being recordable?
No. OSHA makes it clear that hearing protection alone does not rule out work-relatedness. Employers must still consider whether workplace noise contributed to the shift.
Can age-related hearing loss affect recordability?
Yes. Employers may adjust audiograms for presbycusis, or age-related hearing decline, which helps separate natural changes from workplace-related loss.
What are the penalties for not recording hearing loss cases?
Failure to record qualifying cases can lead to citations and fines during OSHA inspections. Documentation is essential for proving compliance and avoiding costly penalties.
How often should audiometric testing be done?
OSHA requires a baseline audiogram when employees are first exposed to hazardous noise, followed by annual tests. Regular testing helps identify early shifts in hearing and ensures proper monitoring.
