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OSHA interpretation · 1991-12-17

Baseline to use when measuring occupational related hearing loss for OSHA recordkeeping purposes.

← 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 17, 1991 Mr. James C. Busche Corporate Safety Engineer Caterpillar Inc. 100 NE Adams Street Peoria, Illinois 61629 Dear Mr. Busche: Thank you for your letter of November 5 detailing your concerns of which baseline to use when measuring occupational related hearing loss for OSHA recordkeeping purposes. An August 27 memorandum was issued to clarify the OSHA enforcement policy outlined in the June 4 memorandum regarding the recording of hearing loss on the OSHA Form 200. It stated that the "original baseline" must be used when measuring for a 25 dB threshold shift for occupational related hearing loss. Your decision to utilize the audiogram that was established as a baseline after the issuance of the Hearing Conservation Standard in 1983 is consistent with our definition of "original baseline" for recordkeeping purposes. Once a 25 dB threshold shift from this baseline is identified and recorded on the OSHA Form 200, that audiogram becomes the reference audiogram to which subsequent audiograms are compared. An additional 25 dB shift from the new reference audiogram would result in the recording of a new case on the OSHA Form 200. Many companies have been recording 10 dB Standard Threshold Shifts (STS's) on the OSHA Form 200. These companies are in full compliance with the enforcement policy contained in the June 4 and August 27 memoranda. If you choose to record STS's, your computer program may be used to meet the requirements of both the Hearing Conservation Amendment (29 CFR 1910.95) and the recordkeeping requirements for the OSHA Form 200 (29 CFR 1904). 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, please contact my staff in the Division of Recordkeeping at (202) 523-1463. Sincerely, Stephen A. Newell Acting Director Office of Statistics

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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