Preparing for Annual OSHA Hearing Conservation Requirements
Annual hearing conservation responsibilities can arrive quickly, especially for organizations managing multiple locations, changing work environments, or seasonal operations. Planning ahead can help employers complete required testing and training, maintain accurate records, and respond appropriately when an employee experiences a change in hearing.
A well-prepared program does more than support compliance. It can help identify hearing changes early, evaluate whether current protections are effective, and reinforce practices that protect employees throughout their careers.
Determine Who Must Be Included
Under OSHA’s general industry noise standard, employers must administer a continuing hearing conservation program when employee noise exposure equals or exceeds an eight-hour time-weighted average of 85 decibels, commonly called the action level.
Organizations should review their employee roster before each annual testing cycle. New employees, transfers, changes in responsibilities, longer shifts, new equipment, and modified work processes may affect who should be included. Noise exposure should also be reevaluated when workplace changes could increase exposure or make existing hearing protection inadequate.
Schedule Annual Audiometric Testing Early
After establishing a baseline audiogram, OSHA requires employers to obtain a new audiogram at least annually for each employee exposed at or above the action level. The annual audiogram must be compared with the employee’s baseline to determine whether a standard threshold shift, or STS, has occurred.
Scheduling early provides time to manage employee absences, incomplete tests, equipment needs, and follow-up requirements. Before testing begins, employers should confirm:
- Which employees require annual or baseline audiograms.
- Where and when testing will occur.
- Who will administer or oversee testing.
- Whether the equipment and testing environment meet applicable requirements.
- How results will be reviewed, stored, and communicated.
- What process will be followed when a potential threshold shift is identified.
If an annual audiogram indicates a possible STS, the employer may obtain a retest within 30 days and use the retest as the annual audiogram. Required follow-up and problem audiograms must be reviewed by an appropriate qualified professional. When an STS is determined, the affected employee generally must be notified in writing within 21 days.
Confirm That Equipment Is Ready
Audiometric equipment must be maintained and calibrated in accordance with OSHA requirements. Before testing begins, organizations should verify the calibration status of their equipment and confirm that required functional checks can be completed and documented.
Testing location can also affect scheduling. Traditional testing may require employees to travel to a clinic, mobile testing van, or dedicated sound booth, creating challenges for organizations with multiple shifts or distributed locations.
The Wireless Automated Hearing Test System, or WAHTS, combines a calibrated audiometer with high-attenuation earcups. It allows testing to be conducted outside a traditional sound booth, for example in a break room or quiet office. Paired with the audhere application, WAHTS can support automated group testing or individual testing.
By bringing testing closer to the workforce, organizations can reduce employee travel and time away from regular duties while gaining greater scheduling flexibility.
Review Hearing Protection
Employers must provide suitable hearing protection to employees exposed at or above the action level. Protection should be reevaluated when noise exposure increases, or an employee experiences an STS.
Before annual testing, organizations should assess whether employees are wearing their protection consistently and correctly, whether worn products need replacement, and whether the selected protection provides adequate attenuation for workplace exposure.
A hearing protector can provide substantially less protection than expected when it is worn incorrectly. Individual fit testing helps determine how much attenuation a particular employee receives from a specific protector.
WAHTS supports both audiometric testing and hearing protector fit testing. This allows employers to evaluate employees’ hearing while providing individualized information about the protection their earplugs provide. This valuable tool can help prevent permanent employee hearing loss before it appears on the annual audiogram.
Prepare Annual Employee Training
OSHA requires annual training for employees included in the hearing conservation program. Training should be updated to reflect changes in protective equipment and workplace processes.
Employees should receive information about:
- The effects of noise on hearing.
- The purpose and types of hearing protection.
- Proper protector selection, fitting, use, and care.
- The purpose of audiometric testing.
- What to expect during the testing process.
Training is most effective when connected to employees’ actual work. Facility-specific examples, demonstrations, and opportunities for questions can help employees understand how hearing conservation requirements apply to them.
Organize Records and Connect Existing Systems
OSHA requires employers to retain noise-exposure measurement records for two years and employee audiometric test records for the duration of the affected employee’s employment.
Before testing begins, confirm that previous audiograms are accessible and connected to the correct employee records. Employers should also have a defined process for reviewing results, notifying employees, coordinating retests, arranging professional evaluation, and documenting changes to hearing protection.
Manually transferring test results between systems can create additional administrative work and increase the risk of incomplete or inconsistent records. WAHTS integrates with occupational health and hearing data-management platforms such as Cority, Enterprise Health, and OccuSound Solutions.
These integrations allow WAHTS data to flow into the platforms organizations already use, helping streamline data capture, simplify reporting, and make results available within existing occupational health workflows. This connectivity can reduce duplicate data entry and support more efficient recordkeeping and program management.
Look Beyond the Annual Audiogram
Effective hearing conservation programs use annual audiograms, noise measurements, fit-testing data, and employee feedback to evaluate how well the entire program is working.
After the testing cycle, consider:
- Were all required employees tested on time?
- Were potential threshold shifts identified and addressed?
- Could employees properly fit their hearing protection?
- Are certain departments or jobs showing recurring concerns?
- Did scheduling, travel, space, or staffing cause delays?
- What should be improved before the next testing cycle?
Preparing early can make annual hearing conservation requirements more manageable and meaningful. WAHTS provides a portable solution for audiometric testing and hearing protector fit testing, helping organizations bring testing closer to employees at one facility or across multiple locations.
Preparing for your next annual hearing testing cycle? Contact WAHTS Hearing to learn how portable audiometric testing and hearing protector fit testing can support your hearing conservation program.
Occupational Safety and Health Administration. (n.d.). Occupational noise exposure, 29 C.F.R. § 1910.95. Electronic Code of Federal Regulations. Retrieved September 11, 2026, from https://www.ecfr.gov/current/title-29/section-1910.95