OSHA Hearing Loss Recordability: The STS and 25 dB Test

A standard threshold shift on its own does not put a case on the 300 log. OSHA hearing loss recordability needs a 10 dB average shift and a 25 dB total hearing level in the same ear, and age correction applies to only one of those two tests.

Annual audiograms come back, the provider flags a shift, and the safety team decides what belongs on the 300 log. OSHA hearing loss recordability is narrower than most employers assume. A standard threshold shift on its own does not put a case on the log, and the second half of the test is the part that gets missed.

What OSHA Hearing Loss Recordability Actually Requires

Hearing loss has its own recording rule at 29 CFR 1904.10, separate from the 1904.7 general recording criteria that govern days away, restricted work, and medical treatment. That separation matters. A hearing loss case can be recordable without any lost time, any restriction, or any treatment at all.

The rule sets a two-part test, and both parts must land in the same ear:

• The employee has a work-related Standard Threshold Shift (STS) — an average change of 10 dB or more from the baseline audiogram at 2000, 3000, and 4000 Hz.
• The employee's total hearing level is 25 dB or more above audiometric zero, averaged at those same three frequencies, in the same ear or ears as the shift.

Miss the same-ear requirement and you over-record: an STS in the left ear plus a 25 dB average in the right is not a recordable case.

The inverse trap is just as common. An STS that fails the 25 dB screen is still a real finding under the hearing conservation program, with follow-up duties attached, even though nothing goes on the log. OSHA recordkeeping support keeps those two tracks from collapsing into each other.

The Frequency Set That Over-Records Cases

The single most repeated error in secondary guidance is averaging the wrong frequencies. Audiometric testing under 1910.95 has to cover at least 500, 1000, 2000, 3000, 4000, and 6000 Hz. The recordability math uses only 2000, 3000, and 4000 Hz — for the shift calculation and for the 25 dB total-level check.

Six frequencies get tested. Three get averaged. Templates that quietly average four or six will produce entries the regulation does not call for, and the error stays invisible unless someone checks the raw thresholds.

Age Correction Applies to the Shift, Not the 25 dB Check

Age adjustment is permitted, and it is permitted for exactly one half of the test. Employers may age-adjust the current audiogram using Tables F-1 or F-2 in Appendix F of 1910.95 when determining whether a shift occurred. Employers may not use an age adjustment when determining whether total hearing level is 25 dB or more above audiometric zero.

The order of operations matters:

1. Compare the current audiogram to the baseline or revised baseline at 2000, 3000, and 4000 Hz.
2. Optionally apply the Appendix F age correction to that comparison.
3. Separately, take the uncorrected current audiogram and average the same three frequencies to run the 25 dB check.
4. Record only if both conditions are met in the same ear and the case is work-related.

Appendix F is non-mandatory, so age correction is a choice rather than a duty. Software that age-corrects the whole audiogram and then runs both halves on corrected values will under-record, which is the mirror image of the frequency error and harder to spot because it produces fewer entries.

The 30-Day Retest Window and the Seven-Day Deadline

Employers may retest hearing within 30 days of the first test. If the retest does not confirm the recordable shift, the case does not have to be recorded. If the retest does confirm it, the entry is due within seven calendar days of the retest.

Two details get lost. The 30 days runs from the date of the initial audiogram, not from the day results arrived or the day the employee was notified. And if later testing shows the shift is not persistent, the entry may be erased or lined out, while the audiometric records are still retained.

Separately from the log, the hearing conservation program requires that the employee be informed of a standard threshold shift in writing within 21 days of the determination. That clock runs whether or not the case turns out to be recordable. Common OSHA recordkeeping mistakes after minor injuries covers the same pattern of missed deadlines in the injury context.

Work-Relatedness and the Physician-Only Clause

There are no special work-relatedness rules for hearing loss. The 1904.5 analysis applies: if an event or exposure in the work environment caused, contributed to, or significantly aggravated the condition, the case is work-related. Work does not have to be the primary cause. It only has to be a discernible one.

If a physician or other licensed health care professional determines, following 1904.5, that the loss is not work-related or that occupational noise did not significantly aggravate it, the employer does not have to record the case.

Here is the distinction almost every summary flattens. Under the recordkeeping rule, an audiologist operating within their state license can qualify as a licensed health care professional and can support a not-work-related determination. Under the hearing conservation standard, the clause that switches off the follow-up duties — refitting hearing protectors, retraining, clinical referral — reads physician. An audiologist's opinion can excuse the log entry without excusing the program obligations.

Hearing protector use is not a standalone defense either. Whether protectors were worn, whether the employee was trained, and what prior exposure existed all belong in the analysis. Medical direction for industrial employers helps teams read provider language before "employee wears plugs" becomes a closed question.

Which Column the Case Belongs In

A recordable hearing loss case gets the hearing loss column checked on the 300 log. That is in addition to, not instead of, the classification columns, where only one box is selected based on the most serious outcome.

For a typical shift with no lost time and no restriction, that means the hearing loss column plus "other recordable cases" — counting toward total recordable incidents but not DART. A case that produces days away or a transfer lands in those columns instead and does enter DART. The OSHA recordkeeping 300 log guide walks the column logic in detail.

A Documentation Sequence for Audiogram Season

Give the person who owns the log a repeatable sequence rather than a yearly scramble:

1. Confirm which baseline applies, and that it matches the one used for 1910.95 compliance.
2. Pull raw thresholds at 2000, 3000, and 4000 Hz rather than a vendor pass or fail flag.
3. Run the shift calculation, applying age correction only if the employer uses it.
4. Run the 25 dB check on uncorrected values, in the same ear.
5. Log the 21-day written notice and the initial audiogram date so both windows stay auditable.
6. Route work-relatedness questions to a qualified provider and keep their reasoning on file.

Occupational clinic vetting helps employers confirm that whoever runs the audiometric program can actually produce threshold-level data and written determinations, not just a summary letter.

OSHA Recordability Guardrails

A clinic visit alone does not make a case recordable. Diagnostic procedures such as X-rays, MRIs, and blood tests are not medical treatment by themselves, and an audiogram sits in that same diagnostic category. The case may still be recordable if prescription-strength medication, restricted work, job transfer, days away, or a significant diagnosis later applies. Employers remain responsible for final OSHA recordability determinations. First aid vs medical treatment OSHA recordability covers the broader treatment line for injury cases.

IndustrialMD can help organize the clinical facts and the provider language. The employer still owns the log decision.

Educational and Employer Responsibility Note

This resource is for general educational and informational purposes. It does not provide legal advice, medical advice, OSHA compliance counsel, or a substitute for case-specific review by qualified safety, legal, medical, or compliance professionals. Employers remain responsible for final OSHA recordability, OSHA reporting, workers' compensation, employment, and legal decisions.

If your team wants a defensible audiogram-to-log workflow before the next testing cycle, talk with IndustrialMD about OSHA hearing loss recordability review and medical direction.

FAQ

How does OSHA hearing loss recordability work?

Two conditions must be met in the same ear: a work-related standard threshold shift, meaning an average change of 10 dB or more from baseline at 2000, 3000, and 4000 Hz, and a total hearing level in that same ear of 25 dB or more above audiometric zero.

Is every standard threshold shift recordable?

No. A shift that does not also meet the 25 dB test in the same ear is not recordable, though it still triggers hearing conservation follow-up and the 21-day written notice.

Which frequencies are averaged?

2000, 3000, and 4000 Hz, for both halves of the test. Testing covers more frequencies, but the calculation uses only those three.

Can we age-adjust the audiogram?

Age adjustment using Appendix F of 1910.95 is permitted when determining whether a shift occurred. It may not be used for the 25 dB total hearing level check.

How long do we have to retest before recording?

A retest obtained within 30 days of the initial audiogram can substitute for it. If it confirms the shift, the entry is due within seven calendar days.

Does a hearing loss case count toward DART?

Not on its own. A case with no days away and no restriction or transfer is checked in the hearing loss column and classified as an other recordable case, which affects the total recordable rate rather than DART.