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OSHA interpretation · 1991-12-16

OSHA 200 log and hearing loss.

← All interpretations§ 1904

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.

December 16, 1991 Mr. Melvin W. Johnson Vice President Lamson & Sessions 25701 Science Park Drive Cleveland, Ohio 44122 Dear Mr. Johnson: Thank you for your letter of October 15, to the Occupational Safety and Health Administration (OSHA), concerning the recording of hearing loss on the OSHA Form 200. On June 4 and August 27, 1991, two memoranda were issued to the OSHA Regional Administrators outlining the Federal policy for uniformly enforcing the recording of work related hearing loss on the OSHA Form 200. The memoranda provide an OSHA enforcement policy related to an existing regulation (29 CFR 1904) and its supplementary guidelines. For this reason the rulemaking procedures under the Administrative Procedures Act were not appropriate. Enclosed are copies of these memoranda detailing the criteria for the OSHA enforcement policy regarding the recording of occupational hearing loss. Please be aware that the employee's "original baseline" referred to in the August 27 memorandum is defined as the baseline audiogram established in accordance with the hearing conservation amendment promulgated March 8, 1983. We are presently working on a "hearing loss fact sheet" that will clearly outline the issues associated with recording hearing loss on the OSHA Form 200. When it is completed, we will be sure to forward you a copy. If you have any questions concerning the information enclosed, please contact the OSHA Office of Statistics at Area Code (202) 523-1463. 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

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