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OSHA interpretation · 1995-06-12

The proper recording procedure for cases involving occupational hearing loss.

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.

June 12, 1995 Ms. Monica Verros, R.N., C.O.H.N. Occupational Health Advisor, Mail Drop 14A IBP, Inc. IBP Avenue Post Office Box 515 Dakota City, Nebraska 68731 Dear Ms. Verros: Thank you for your letter dated April 14, requesting an interpretation regarding the proper recording procedures for cases involving occupational hearing loss. If an audiogram shows a hearing loss that is recordable on the OSHA Form 200, the date entered in Column (b) is the date the employee was tested. If a retest performed within 30 calendar days of the initial test shows the hearing loss is not recordable, the original entry may be lined out. A retest audiogram may not be substituted for an initial audiogram unless it is obtained within thirty calendar days of the date of the initial audiogram. The 1993 annual test in your example may not be used to line out the 1992 case. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief Division of Recordkeeping Requirements

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.

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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.