Job13

OSHA interpretation · 1991-02-06

Recording of occupational hearing loss on OSHA Form 200

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

February 6, 1991 Mr. James D. Banach President National Hearing Conservation Association Suite 200 900 Des Moines Street Des Moines, Iowa 50309 Dear Mr. Banach: Thank you for your letter of December 14, 1990, regarding the recording of hearing loss on OSHA Form 200. Your letter stated that you believe the Occupational Safety and Health Administration (OSHA) should issue a clearly-defined criterion for recording occupational hearing loss at the earliest possible time. Your contacts with various OSHA Regional Offices have resulted in differing responses concerning enforcement of the level at which hearing loss must be recorded. You recently became aware that OSHA issued a draft document on March 23, 1990, that provided guidelines for enforcing the recording of occupational hearing loss on OSHA Form 200. You related that you have some concerns about specific items in the draft document. You also commented that it would be useful to employers and hearing conservation professionals alike if consistency in enforcement policy could be established. We agree that a clearly defined criterion for recording occupational hearing loss is needed and that consistency in enforcement policy is essential. We are preparing a final field directive that will serve these purposes. We will take your comments into consideration during this process. As soon as the directive is finalized, we will provide you with a copy. We appreciate your comments on this important issue. Sincerely, Gerard F. Scannell Assistant Secretary

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

Deciding a case of your own?

The free recordability check works through Part 1904 in the order the regulation sets out and quotes the provision behind every step.

Check a case — free

Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.