Is It Recordable?
Scenario Q49

Audiogram Retest: is it recordable?

Verdict: Recordable
Published 2020-05-17

Question

At the start of first shift, a manufacturing employee’s annual audiogram indicates that he has suffered a Standard Threshold Shift (STS) in his right ear. The employee insists his hearing is fine and admits to going to a rock concert the night before the audiogram. The company retests the employee’s hearing at an audiologist office 45 days after the initial audiogram and the results show the employee does not have a Standard Threshold Shift (STS). Is it recordable?

Answer

YES. Even though the second audiogram indicated the employee did not have a STS, the company waited too long for the retest. OSHA allows employers to retest employees who show STSs within 30 days of the initial audiogram. The company waited 15 days too long.
1904.10(b)(4)
Do I have to record the hearing loss if I am going to retest the employee's hearing? No, if you retest the employee's hearing within 30 days of the first test, and the retest does not confirm the recordable STS, you are not required to record the hearing loss case on the OSHA 300 Log. If the retest confirms the recordable STS, you must record the hearing loss illness within seven (7) calendar days of the retest. If subsequent audiometric testing performed under the testing requirements of the §1910.95 noise standard indicates that an STS is not persistent, you may erase or line-out the recorded entry.

https://www.osha.gov/laws-regs/interlinking/standards/1904.10(b)(4)

Illustration for the scenario: Audiogram Retest
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This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.