Tracking audiometric testing compliance means knowing, on any given day, which employees are past due for a baseline or annual audiogram, which are waiting on a retest or a follow-up action, and which completed tests haven’t been reviewed yet.
Those lists can change daily, because OSHA’s audiometric testing requirements are written per employee; each person’s due dates come from their own first exposure date. Knowing what share of your active employees are current, broken out by site and team, turns those dates into a number you can act on.
Why do hearing tests get missed?
Because due dates correspond to each employee’s own first exposure date, not a company-wide calendar, so they never collect into a single testing season.
Under OSHA regulation 29 CFR 1910.95, you have to establish a valid baseline audiogram within six months of an employee’s first exposure at or above the hearing conservation program action level of 85 dBA over an 8-hour time-weighted average (TWA). If you use mobile test vans, that window is one year, but if the baseline falls more than six months after first exposure, the employee must wear hearing protectors beyond those six months until you obtain it. After the baseline, you owe each employee a new audiogram at least annually.
Each of the following either puts an employee out of compliance or leaves an obligation open:
- New hires start their own clock. Each one needs a valid baseline within six months of their own first exposure (one year with mobile test vans). Miss that deadline and the employee is out of compliance until a baseline is on file.
- Retests run on a shorter clock. When an annual audiogram shows a standard threshold shift (STS), you may obtain a retest within 30 days and treat it as the annual audiogram. Miss the 30-day window and the original shift stands, along with every notification and follow-up obligation that comes with it.
- A shift starts more clocks. Once a shift is determined, you have 21 days to notify the employee in writing, and unless a physician determines the shift isn’t work-related or aggravated by occupational noise, follow-up obligations attach: fitting or refitting hearing protectors, training or retraining, and referral for evaluation where appropriate (29 CFR 1910.95(g)(8)). An employee can be tested on time and still have an open obligation.
- Fixed testing dates don’t match rolling due dates. Whatever your program uses (an on-site booth day, a clinic appointment block, a scheduled provider visit), employees keep coming due in between.
Missed deadlines show up in OSHA enforcement data. In fiscal 2025, the most commonly cited failure under 1910.95(g) was having no audiometric testing program at all, followed by missing annual audiograms and then missing baseline audiograms.
What does compliance mean for a hearing testing program?
For a hearing testing program, compliance means every employee who is owed a test has had it on time, and every shift that turns up has been handled on time. Under 29 CFR 1910.95(g), that covers baselines and annual audiograms completed by their due dates, standard threshold shifts retested within 30 days when you choose to retest, employees notified in writing within 21 days of a determination, and the follow-up actions that attach to a shift.
Your compliance percentage measures test currency: the share of active employees whose required audiogram is on file and whose next test isn’t due yet. An employee is current from the day that audiogram lands, and overdue the day a required test date passes without one.
Current isn’t the same as finished. The audiogram still has to be compared against that employee’s baseline, and if that comparison shows a shift, the notification and follow-up actions have to happen too (29 CFR 1910.95(g)(7) and (g)(8)). None of that moves the compliance percentage, which is why pending reviews, employees waiting for retests and outstanding follow-ups are counted separately. The percentage tells you about testing currency. The counts underneath it tell you about the program.
Which hearing testing compliance numbers should you track?
Five numbers cover it: four counts, and the percentage they produce.
| Number | Why it matters |
|---|---|
| Active employees | Your denominator. It moves with hiring, transfers, and role changes, so it has to come from live data. |
| Employees tested | Tests actually completed, meaning the audiogram is in hand. A booked appointment doesn’t count, and neither does a test whose audiogram you don’t have yet. Whether that test has been reviewed, and whether a shift triggered follow-up actions, are tracked in the row below. |
| Overdue, split by annual, initial, and retest | Splitting the total tells you which process to go fix. A pile of overdue initials points to onboarding, overdue annuals to scheduling, overdue retests to follow-up. |
| Outstanding follow-ups, retests, and pending reviews | Employees who’ve been tested but aren’t finished. A shift awaiting a retest, an open follow-up action, or a completed test that hasn’t been reviewed is still an open obligation. |
| Compliance percentage | The headline. It’s the number leadership asks for, and the one that decides whether anyone looks closer. It’s only as accurate as the counts above it. |
Track all five, and the data answers two questions: how the program is doing and what to do next.
Why isn’t one organization-wide compliance number enough?
An overall score tells you whether to worry. It doesn’t tell you how to fix it.
Hearing Testing, Evolved
FDA-listed tablet audiometry. OSHA compliant. Test anywhere — no sound booth required.
Say your dashboard shows 95% overall compliance across roughly 1,900 active employees. In the same view, one crew sits at 54%. The 95% tells you the program looks healthy. The 54% tells you which crew to investigate.
A corporate average won’t tell you why you’re not at 100%, and it won’t separate a crew out on its own line. The questions that would explain a gap are local ones: how that crew is scheduled around shift changes, who owns the follow-up list there, whether new hires get tested at onboarding. You can’t ask those questions until you know which crew to ask. For the operational side, see managing a hearing conservation program across multiple locations.
Where should you set your hearing testing compliance thresholds?
Sort sites into compliant, at risk, critical, and non-compliant, and you will know which sites need attention first.
Where you draw those lines is a management choice. OSHA doesn’t grade programs on a percentage at all. Its requirements apply per employee, so an employee tested late is a gap, regardless of your overall number, which means the only score that represents full compliance is 100%. Thresholds help you triage the distance between your number and 100%. Pick cut points that match how your organization already reports safety metrics, so a hearing testing number sits alongside your other measures without needing a translation. If leadership treats anything under 95% as a problem, don’t set your compliant threshold at 80%.
How do you turn a compliance percentage into scheduled tests?
Knowing a crew is at 54% doesn’t automatically increase your test completion rates. Someone has to get from the number to a list of names, each with a last test date and a next due date, and hand that list to whoever schedules testing. If that means exporting records and reconciling them by hand, the list is only as current as the last time someone rebuilt it.
Tracking only helps increase OSHA compliance when the numbers link to the names associated with them.
How does the SHOEBOX PureTest Data Management Portal help you close compliance gaps?
The Compliance Dashboard is the first screen in the SHOEBOX PureTest Data Management Portal after you log in. Across the top, you will see your number of active employees, completed tests, employees overdue for testing, and an overall compliance score, color-coded to the compliance thresholds you set. You don’t need to request a report; you see your program’s status without clicking anything.
See what’s outstanding, not just what’s overdue. The General Overview tab breaks your program into groups: employees overdue for testing, those with outstanding follow-up actions, those waiting for a retest, and, for reviewing audiologists, tests still pending review. Each group links straight to the employees behind it.
See every group at once. A project is whatever grouping of employees you want it to be: a site, a shift, a crew, a department. You set them up yourself, so they match how your program is organized. The Project Overview tab then gives you one row per project, with total numbers of active and inactive employees, employees tested, STS, Recordable STS, overdue counts, and a compliance percentage per project. Filter by compliance status, search by project name, or sort by any column, and your weakest projects come to the top. If you only manage some of them, the project selector can narrow the whole view to yours.
See which kind of overdue you’re looking at. Overdue counts break out by annual, initial, and retest, so you can tell a new-hire backlog from a follow-up backlog without opening anything.
Get to names in one click. Every count, on the dashboard and in the tables, is a link to a list of the employees behind it. For example, if you select an overdue count, you get the list of employees overdue for testing, with last tested and next test due dates. Tables are also searchable by employee name. Who sees which level of detail is set by your program administrators, so the people with access work from their lists.
Find what already works. Once your sites sit in one sortable table, your strongest performer is as visible as your weakest. Now you can replicate whatever the site at 96% is doing differently, because you know where to look and who to ask.
Report on the same numbers you act on. Recordable STS sits in its own column, so the shifts you need to review for your OSHA 300 log come from the same view you use to chase overdue tests.
Access is built around who should see what. Administrators with access to protected health information (PHI) see compliance data for the whole organization. Users with PHI access but no administrator rights see the same views, limited to the projects assigned or shared with them. Administrators without PHI access can set the compliance thresholds but never see employee data. That separation is deliberate: hearing test results are health information, and the dashboard only ever shows a user the employees they’re responsible for.
The project table and the employee lists behind it are refreshed overnight, and a banner shows when they were last updated, so a test completed this morning appears there tomorrow. The summary figures across the top and the General Overview tab are live.
How do you test employees as they come due?
A list of names with due dates is only useful if you can test the people on it.
Employees come due all year, so staying current means being able to test year-round. The SHOEBOX PureTest solution includes a boothless, tablet-based audiometer, clinically validated for use outside a sound booth, that stays at your facility. A qualified technician on your team can test new hires in their first week, catch a retest inside the 30-day window, and pick up whoever missed a testing day, without waiting for the next scheduled event.
What would the Compliance Dashboard look like for your program?
Request a demo using the form below and we’ll walk through the Compliance Dashboard in the SHOEBOX PureTest Data Management Portal and how it would map to your sites, projects, and testing schedule. If you’re ready to price it for your program, request a quote.
Sources
- 29 CFR 1910.95, Occupational noise exposure. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.95
- 29 CFR 1904.10, Recording criteria for cases involving occupational hearing loss. https://www.osha.gov/laws-regs/regulations/standardnumber/1904/1904.10
- SHOEBOX analysis of OSHA enforcement data: 29 CFR 1910.95(g) citations issued in FY2025, federal and state-plan programs. U.S. Department of Labor Open Data Portal, OSHA Violation and Inspection datasets joined on inspection number, accessed July 2026. Figures reflect a point-in-time snapshot; the datasets update daily, and citations may be revised or added. https://data.dol.gov/datasets/10338 and https://data.dol.gov/datasets/10334
