Occupational Hearing Testing Guide
Everything your organization needs to establish, manage, and maintain an OSHA-compliant occupational hearing testing program — from testing environments to audiometer calibration and STS recordkeeping.

12 Chapters · 59 min read
Establishing an OSHA-Compliant Occupational Hearing Testing Program

We’ve helped hundreds of companies bring their occupational hearing testing programs in-house. And we’ve helped a similar number of service providers add mobile hearing testing to their toolbox. Here are some of the lessons we’ve learned in that time.
Many organizations realize significant cost savings. They regain control of their testing programs by being able to adopt flexible testing schedules. And they are achieving greater levels of compliance as more employees opt into the testing process. Equally importantly, their program members report preferring the experience over traditional testing methods.
To share what we’ve learned, we put together a comprehensive reference guide. Whether you are interested in bringing your program in-house, or are a service provider looking to expand your offerings, it will provide answers to the most common questions that we get asked. The full guide will cover:
Hearing Testing Options
There are several options for how to conduct testing including sending staff to clinics or bringing mobile clinics on site. In this guide, we’ll share the pros and cons of each and compare them to boothless, automated audiometry.
The Key Players
There are various people involved in most occupational hearing testing programs. This guide will cover the role that each plays. What’s the difference between a program manager and a professional supervisor? What are the responsibilities of the test administrator and the HSE/EHS? When do you involve your medical director (if you have one) or audiological reviewers? Even your union reps can play a critical part.
OSHA Requirements for Occupational Hearing Testing
Hearing testing is only one component of an occupational Hearing Conservation Program. Other OSHA-mandated components include noise assessment and monitoring, provision of hearing protection, employee training programs, and records management. This guide will cover the specific OSHA requirements for compliant audiometric testing including testing environments, test frequencies and levels, required equipment, calibration, testing processes, scheduling, audiological review, actioning hearing shifts, providing notifications to employees, and more.
Test Environments: Finding an OSHA-Compliant Location
Boothless audiometry affords the opportunity to conduct testing outside of a sound booth, however, your environment must meet the OSHA-mandated maximum permissible ambient noise levels (MPANLs). We’ll cover what MPANLs are, the steps you can take to find a suitable test location, how to mitigate room noise, and how to conduct a pretest room scan.
How to Maintain your Audiometer
OSHA and ANSI have well-defined requirements related to the maintenance of your audiometric testing equipment. This guide covers the steps necessary to keep your audiometer compliant with the ANSI Standard described in the previous chapter. These include daily verifications, annual calibrations, test configurations, and functional checks.
Hearing Testing Workflow: Steps to Follow
This section will serve as a step-by-step walkthrough of a typical testing day. Equipment maintenance and room preparation, identifying who is due for testing, instructing employees, test administration, communicating results, and determining next steps.
Audiological Review and Clinical Referral Paths
A key component of a program includes the verification and confirmation of hearing shifts and other medical indications by a licensed professional. This step ensures the necessary review of test results, as well as recommended next steps even if your program spans multiple states. Here we’ll discuss centrally-coordinated audiological review requirements to meet the time-bound OSHA reporting rules.
Maintaining OSHA 300 Logs
The OSHA 300 form is used to record all reportable injuries that occur in the workplace including a recordable shift in hearing from baseline. This form tracks when the injury was identified, the name and title of the employee, and the number of days they could potentially be away from work, or restricted to light duty. We’ll cover details on how to maintain an OSHA 300 form, including when recordable shifts need to be filed as well as what to do if additional information becomes available in future (e.g. retests).
Managing Occupational Hearing Testing Data
Bringing your program in-house starts with clean data which can be a challenge for some companies. We’ll cover the importance of establishing up-to-date baseline records and review the common issue of missing or incomplete records.
Flexible Testing Schedules
A major benefit of bringing your program in-house, or offering mobile services, is the flexibility to test on a more regular basis. Choosing birth dates or work anniversaries can ease the burden of scheduling large groups of employees in a relatively short period of time. We’ll share tips on how to automate some of the scheduling processes.
Delivering an Optimal Employee Experience
Some of the most compliant programs we’ve seen are those where the employees are active participants in the testing process. Delivering an optimal experience is good for your staff and better for your overall program.
Infection Control
Events in recent times have brought forward the added importance of infection control. Starting with exceptional hygiene, enabling hearing testing while maintaining adequate distance between the employee and administrator, to how to disinfect the testing equipment. In this chapter we’ll cover best practices to de-risk your hearing testing activities.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. If you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more on how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
Occupational Hearing Testing Options: Clinics, Mobile Clinics, and Boothless Audiometry

Employers have several options in how to conduct testing as part of a Hearing Conservation Program (HCP). These include sending staff to clinics or bringing mobile clinics on site. Many forward-thinking employers are opting to manage their programs in-house by leveraging boothless, automated audiometry.
While there are pros and cons to each, one option offers cost savings benefits and greater flexibility around testing schedules.
Sending Staff to the Clinic
Sending your staff to local audiology or occupational health clinics for their annual hearing test is an option for employee annual audiogram requirements.
However, this approach can be expensive, not to mention disruptive for both the employee and the employer. Costs include paying the clinic’s testing fee, and clinic hours will dictate when employees can be tested. This can mean paid time away from work while employees visit the clinic. Depending on the type of business you run, it may also mean the cost of a second employee to cover that shift and any other transportation or parking expenses you cover for your employees. While costs add up, productivity is being impacted.
Sending staff to a local clinic can also pose a potential challenge for record-keeping. The typical output of a clinic visit is a paper copy of the audiogram. For compliance maintenance, that audiogram must be filed with the employee’s records and be kept for 30+ years. It can be a challenge for health and safety managers to ensure these audiograms are filed in the days or weeks after the clinic visit. Alternatively, the manager can manually enter the results into an audiometric monitoring software platform, but that also takes time.
If yours is a small team of people who need to have an annual hearing test, sending them to a clinic can be a good approach. Nevertheless, as the team grows, the cost and compliance challenges may nudge you towards considering a different approach.
Bringing a Mobile Clinic On-Site
This may be the most common approach employers use to conduct annual testing. Bringing a clinic on-site can be more convenient for your employees than sending them out to the local clinic. Mobile clinics – a truck outfitted with several sound booths in the back – can test two-to-four employees at the same time, which can speed up testing for larger teams.
The service-provider approach will be presented as a turn-key solution for employers. However, there can still be a heavy burden on the health and safety team to manage annual testing schedules for all members of your HCP. For facilities that run 24-hour work shifts, the mobile clinic is not likely to stay onsite overnight to accommodate these workers. Roughly 10-15% of employees will miss their scheduled appointment for a variety of reasons, such as illness, emergencies, or other work priorities. This will require more time from the health and safety team to reschedule these employees. And you must decide if you bring the truck back on-site or send these individuals out to the local clinic. Either way, costs will add up, and productivity suffers.
Other considerations for bringing trucks onsite include having space large enough to accommodate them at your facility. Where the trucks need to park may not be convenient for your staff. And may not be optimal in terms of noise control.
Additionally, people generally don’t enjoy the experience of being tested in the mobile clinic. The sound booths installed in them can be small, cramped, and dated. Noise produced by generators, fans, heaters, and air conditioners can impact ambient noise levels and may need to be turned off during testing – resulting in uncomfortable conditions.
Boothless Audiometry
There is a movement underway to bring testing programs in-house. New modern, mobile technology optimized for out-of-the-booth testing is making it possible.
Frustrated by the cost of clinics and service providers and fed up with the challenge of annual testing schedules, these companies are willing to assume additional responsibilities in exchange for having greater control over their programs.
When you decide to bring your HCP in-house, there may be more work for you and your team as you take on the task of testing, notifications to employees, and record-keeping. However, it will likely result in significantly-reduced overall expenses. Also, managing the testing schedule will be easier as you will not be limited to testing only when mobile testing units are available. One of the significant advantages of having tablet-based testing in-house is that you, as an employer, will be able to obtain baseline audiograms much closer to the employment start date than if you had to wait for a mobile unit. This results in more accurate, and therefore more useful, baseline measures. Annual tests can then be scheduled on the anniversary of the employee’s hire date, for example.
With these types of systems, all records are digital and stored in a secure, easy-to-access web portal. Data can be organized by location, by team, or by department. Historical data – whether from previous service providers, audiometric data storage software, or the local clinic – can easily be transferred to these digital systems, and it may be possible to offer custom integrations with HR systems, Learning Management systems, or other data management tools.
Bringing your HCP in-house can be more cost-effective and convenient without sacrificing accuracy or compliance. Our boothless solution, SHOEBOX for Occupational Hearing Testing, has been clinically validated to produce diagnostic test results, and the equipment meets the audiometric specifications for occupational testing of ANSI/ASA S3.6-2018.
The workplace audiometric testing equipment and data management platform are designed to help you manage your HCP in-house. We also offer comprehensive audiological services delivered by a network of licensed audiologists who specialize in occupational health reviews. Offering coverage across the United States and Canada (expansion planned to other regions in future), the Reviewer Network can offer your HCP:
- Shift determination and confirmation
- Identification and review of problem audiograms
- Baseline audiogram revisions
- Ensuring completeness of results
- Medical and/or audiological referrals recommendations, as needed
- Test follow-up recommendations
If you do not have an audiologist or physician overseeing your program, our CAOHC-certified Audiology Team of Professional Supervisors can perform this role for you, offering:
- Support to ensure your testing environment meets OSHA requirements for open-room testing
- Review of your historical records and record-keeping best practices
- Testing configuration support
- Training of test administrators
- Review of your annual hearing conservation training for employees
- Review of the various options of hearing protection employers need to provide
- Recommendations when shifts are clustered within groups of employees or at a higher incidence than expected
- Consultation for various hearing conservation tasks and OSHA audiometric testing requirements
Boothless audiometry can help you take back control of your HCP while at the same time offering a more optimal experience for your staff. Testing can be performed close to where employees work in any comfortable OSHA-compliant room, including quiet offices or meeting rooms. Missed tests are easily re-booked for the next available opportunity. This type of flexibility can significantly improve your overall testing compliance as retests become easier and more accessible. Adhering to all retest recommendations can reduce the number of your annual recordable hearing shifts by as much as 50%.
This chapter outlines various options for audiometric testing of individuals who are part of a Hearing Conservation Program, along with important considerations for each. Options are helpful when designing the best annual testing set-up for your company, and innovation has brought forth some interesting and efficient new offerings. Our teams at SHOEBOX can help you design or re-design your annual testing set-up with one or a combination of these options.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next 11 weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more about how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
The 10 Key Roles in Your Occupational Hearing Conservation Program

If you are new to hearing conservation, or your workplace has recently been assessed for noise and is now at or above the OSHA action level of 85 dB(A) time-weighted average (TWA) over an 8-hour day, you may be wondering who you need to engage to help build your Hearing Conservation Program (HCP). While there are many roles to fill, several can be held by only a few people, and thankfully, not all are mandatory. As your business grows, you may want to hire people with more specialized skill sets to help your program run smoothly.
The following are the 10 key roles you may find in a Hearing Conservation Program:
The Program Manager
This person is often an EHS (Environmental Health and Safety) manager who may run several programs, of which the Hearing Conservation Program (HCP) is only one. They will be responsible for overseeing the program, ensuring testing is completed on time, tracking compliance, monitoring the effectiveness of hearing protection, and record-keeping (noise measurements, noise controls, and maintenance of the OSHA 300 Log). They may also be in charge of scheduling and the audiometric testing itself. In cases where a Standard Threshold Shift (STS) has been identified, they are responsible for notifying the employee, reviewing the employee’s workspace for physical noise mitigations, fitting of HPDs (Hearing Protection Devices), and additional training on proper use of HPDs both on and off the job.
Role of Employees in an Occupational Hearing Testing Program
In the context of an HCP, this includes anyone who is exposed to noise (85 dB(A) time-weighted average or more) at work. Once they are exposed, you must make at least two different types of hearing protection available for these employees, and they must be included in the monitoring program. If the employees are exposed to 90 dB(A) TWA, hearing protection for these employees is mandatory. Employees can play a major part in your program compliance. When employees are engaged in the program and understand the benefits of wearing hearing protection both on and off the job, your injuries will be reduced, and less time and money will be spent on evaluations and worker’s compensation.
Environmental Health & Safety Managers
Regional EHS Managers have similar roles to the Hearing Conservation Manager (HCM) but on a local or site level. Commonly these are Board-Certified Safety Professionals (CSPs), who are often responsible for maintaining the OSHA 300 Logs for the locations they oversee. They may also assist with hearing testing, scheduling, fitting and insertion of HPDs, and are often the people facilitating the annual hearing conservation training.
Occupational Hearing Conservationists and Qualified Test Examiners
The Council for Accreditation in Occupational Hearing Conservation (CAOHC)1 provides training across the US and abroad to become certified in hearing testing for occupational programs. This training is mandated in some states and considered best practice for all those involved in audiometric testing. When testing using an automated method such as SHOEBOX PureTest, additional training is provided by the manufacturer to gain expertise in the use of their technology.
Occupational Health Nurses
If your organization has Occupational Health Nurses, they can be very useful members of the team who may serve a similar role to the Regional EHS Manager. They may be responsible for conducting the hearing testing, record-keeping, and training. Nurses are trained in otoscopy (looking in employee’s ears); therefore, they can check for things such as wax impaction or ear anomalies. Nurses are typically only found in larger organizations that have an on-site clinic and may have access to sound booths to perform testing.
Industrial Hygienists
Industrial Hygienists (IH) maintain workplace health and safety by identifying, evaluating, and controlling exposure to various chemical, physical, ergonomic, and biological hazards. Their responsibilities vary depending on the industry, workplace, and the types of hazards affecting employees; however, their goals are often the same: to implement control measures that will reduce the incidences of sickness or injury and identify potential health threats in the workplace. The IH has a particular expertise in noise monitoring. They are trained in the use of sound level meters for noise surveys and the creation of noise maps. These are the average sound levels (time-weighted over an 8-hour period) mapped across a physical workspace on a grid and help identify which workers are at risk of noise exposure. They would also be responsible for tracking and determining the Personal Exposure Levels (PELs) of workers through dosimetry and, ultimately, for helping determine who qualifies for inclusion into the hearing conservation program.
Professional Supervisors
The 1983 OSHA’s Hearing Conservation Amendment first emphasized the role of a hearing healthcare professional in the audiometric testing components of 29 CFR 1910.95 (g). For example: “A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist, or physician.’’ Similar rules exist in the MSHA Noise Regulation (30 CFR Part 62). The Professional Supervisor (PS) “has responsibility for ensuring the adequacy of the audio-metric testing environment, procedures, and record-keeping; the training of audiometric technicians; as well as the coordination of audiometric services delivered by a third-party healthcare provider”2. The Professional Supervisor could also be the healthcare professional who reviews the employee audiograms, but this is not always the case. For example, a company that has locations in several different states would typically only have one Professional Supervisor but could have multiple audiogram reviewers, as those individuals need to be licensed in the state in which the employee is stationed. Professional Supervision responsibilities include:
- Ensuring that baselines are appropriately set and modified
- Ensuring all testing equipment, as well as the testing environment(s), meet regulatory compliance guidelines
- Ensuring proper testing protocols, including annual testing, retests, and confirming appropriate paths of referrals
- Reviewing the annual hearing conservation training content provided to employees
- Ensuring that there are a minimum of two types of hearing protection options for employees
- Investigating trends in hearing shifts
- Overseeing the training of the hearing test administrators, including how the results are shared with the employee
Audiological Reviewers
The review of audiograms is required under 1910.95(g)(7) (iii) and states that ‘‘The audiologist, otolaryngologist, or physician shall review problem audiograms and shall determine whether there is a need for further evaluation.’’ Reviewers are responsible for ensuring that the results for a particular employee are valid and complete and whether or not there is a shift in hearing from previous evaluations. They would record their clinical impressions as well as recommendations for the next actions, which could include requesting a retest, notifying the employee of a change in hearing, modifying baselines, and/or recommending a medical or audiological referral. More on the role of the Professional Supervisor and Audiological Reviewers is available in Chapter 7 (Establishing an OSHA-Compliant Occupational Hearing Testing Program).
Safety Specialist or Engineer
A Safety Engineer spends a lot of time at worksites to ensure proper implementation and monitoring of safety factors. When aiding a Hearing Conservation Program, their role would be to implement engineering controls to prevent unnecessary noise exposure. These controls can reduce sound exposure levels for most noise sources. They can involve altering equipment (i.e. converting a mechanical component to an electronic one), replacing old machinery, and making physical barriers at the noise source to block the transmission path and reduce the noise level at the worker’s ear. This type of prevention is preferred over administrative controls, such as reducing the time an employee is exposed during their shift or using different personal protective equipment (PPEs). By combining a knowledge of health and safety with systems engineering, they are able to ensure that equipment, machinery, chemicals, and other environmental factors are safe. This is not a mandatory role but can be very helpful to the Health and Safety Team in administering the HCP. Often the Hearing Conservation Program Manager would take on these tasks if a Safety Engineer was not on staff.
Acoustical Engineer
An Acoustical Engineer is an engineer who specializes in the science of sound and vibration. Their primary role is the control of noise or vibration that can be harmful to employees and the general public. They are commonly found in the industrial, manufacturing, architecture, and transportation sectors, all those which benefit from expertise in acoustical engineering. Within an HCP, the Acoustical Engineer would be responsible for the diagnoses of noise problems in a noisy environment. They are looking for the dominant sound sources as well as the solutions that make it possible to reduce the noise. Acoustic diagnostics in noisy environments require, in addition to the traditional sound level meter, more specialized tools such as sound intensity probes, sound mapping, and beamforming antenna (a signal processing technique).
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next 10 weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more about how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
References:
1 Hearing Conservation Manual, Council for Accreditation in Occupational Hearing Conservation, 5th Edition (2017)
2 The Role of the Professional Supervisor in the Audiometric Testing Component of Hearing Conservation Programs. ACOEM Task Force on Occupational Hearing Loss. Journal of Occupational and Environmental Medicine. 60(9):502-506, September 2018.

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↓ Download Free PDFOSHA Requirements for Occupational Hearing Testing

Noise is one of the most pervasive occupational health challenges facing numerous organizations. In the United States, approximately 25 percent of workers have been exposed to hazardous noise, with 14 percent (22 million) exposed in the last year. Roughly 34 percent of noise-exposed workers report not wearing hearing protection. Exposure to high sound levels over extended periods of time may cause significant hearing loss. An occupational Hearing Conservation Program (HCP) could be critical to the safety and well-being of your employees.
Noise-Induced Hearing Loss (NIHL) is often preventable, and a well-designed HCP can be effective in helping to preserve the hearing of employees. An employer is mandated to establish an HCP when workers are exposed to 85 dB(A) of noise time-weighted (TWA) over eight working hours. Hearing protection devices, such as ear muffs and ear plugs, are mandatory when workers are exposed to 90 dB TWA or more. For reference, examples of sounds at levels of 80 to 90 dB include heavy traffic, a noisy restaurant, or a power lawnmower.
Elements of an OSHA-compliant hearing conservation program include: environmental noise surveys, annual training and education, provision of various types of hearing protection devices as well as training in their proper use and insertion, baseline and annual audiometric testing, records management, and follow-up procedures as necessary.
Employers are required to provide audiometric testing at no charge to relevant employees in order to monitor the hearing health of workers throughout the duration of their employment. To be OSHA compliant, an employer should obtain a new employee’s baseline hearing levels within six months of employment. However, the best practice would be to test the employee’s hearing within the first month of employment. As per OSHA 29 CFR 1910.95, the employee must be free from workplace noise for a minimum of 14 hours before a baseline audiogram is obtained. The employee should then be tested at a minimum every 12 months. OSHA does not specify a noise-free period for regular annual tests. Audiometric testing is not only necessary for compliance; it encourages employees to be mindful of their hearing protection and their overall hearing health.
Advancements in modern mobile technology have made clinically valid audiometric testing more affordable and accessible. Tablet-based audiometric testing equipment and digital data management solutions have been explicitly designed to support employers in managing their HCP. Automated testing interfaces and a powerful individualized and HIPPA-compliant web portal empower organizations to administer the testing in-house. This high level of control and portability creates a positive experience for both your company and your employees.
Valid audiograms must adhere to specific OSHA hearing conservation program requirements. A clinically valid automated testing platform allows an administrator to easily test all required frequencies accurately. Workers can be tested on-site as long as background noise levels adhere to permissible ambient noise levels. Higher noise levels may mask the presentation tones used during audiometric testing. A compliant portable system for occupational hearing testing will accurately monitor ambient noise against the OSHA-prescribed Maximum Permissible Ambient Noise Levels (MPANLs). A future chapter on finding compliant testing locations is included in this guide.
It can be difficult to know for sure if the test equipment being used meets OSHA requirements for testing in your (HCP). While compliance remains the responsibility of the employer, SHOEBOX PureTest can be used with confidence, as it meets the requirements for testing equipment in all relevant sections of 1910.95. Here is a breakdown of the relevant sections and an explanation of how SHOEBOX meets each OSHA audiometric testing requirement.
1910.95(h)(1)
Audiometric tests shall be pure tone, air conduction, and hearing threshold examinations, with test frequencies including as a minimum 500, 1000, 2000, 3000, 4000, and 6000 Hz. Tests at each frequency shall be taken separately for each ear.
As SHOEBOX is a portable audiometer, its form factor is unique in Hearing Conservation Programs (HCP). It uses pure tone stimuli via audiometric headphones and includes the required test frequencies in the default OSHA automated test configuration: 500, 1000, 2000, 3000, 4000 and 6000 Hz – described in 1910.95(h)(1). The OSHA default settings in SHOEBOX also include 8000 Hz as a test frequency. Including this audiometric test frequency is recommended by experts in the field as it is helpful in the audiological and work-relatedness analysis of the results.
1910.95(h)(2)
Audiometric tests shall be conducted with audiometers (including microprocessor audiometers) that meet the specifications of and are maintained and used in accordance with American National Standard Specification for Audiometers, S3.6-1969, which is incorporated by reference as specified in Sec. 1910.6.
1910.95(h)(3)
Pulsed-tone and self-recording audiometers, if used, shall meet the requirements specified in Appendix C: “Audiometric Measuring Instruments.”
SHOEBOX falls into the category of microprocessor audiometers. It performs diagnostic threshold hearing testing using the gold-standard modified Hughson-Westlake protocol. Our PRO version of SHOEBOX meets all the specifications of an ANSI/ASA S3.6 Type 3 audiometer, which exceeds the OSHA occupational health requirement to test using, at minimum, a Type 4 audiometer. SHOEBOX also offers pulsed-tone and self-recording capabilities addressing OSHA 29CFR 1910.95 Appendix C requirements. For more information, please consult the American National Standard – Specification for Audiometers ANSI/ASA S3.6-2018.
1910.95 Appendix D
Rooms used for audiometric testing shall not have background sound pressure levels exceeding those in Table D-1 when measured by equipment conforming at least to the Type 2 requirements of American National Standard Specification for Sound Level Meters, S1.4-1971 (R1976), and to the Class II requirements of American National Standard Specification for Octave, Half-Octave, and Third-Octave Band Filter Sets, S1.11-1971 (R1976).
SHOEBOX has been optimized for use outside of a traditional audiometric testing booth. However, you are still required to ensure that the test environment meets the Maximum Permissible Ambient Noise Levels (MPANLs) mandated by OSHA. To address the issue of background noise, SHOEBOX PureTest includes a room scan feature which allows noise measurement in the room where the audiometric evaluation is taking place. It uses a Class 2 external microphone that provides octave-band sound pressure noise level measurement. SHOEBOX’s room scan functionality meets the functional noise monitoring requirement as described in OSHA 1910.95 Appendix D: Audiometric test rooms:
- Use of an ANSI/ASA S1.15 1997 (R2016) Class 2 external microphone with traceable annual calibration
- Hardware-assisted Fast Fourier Transform (FFT) isolates five frequencies (0.5, 1, 2, 4, 8 kHz) with Z-weighting
- Class II Octave-Band filtering applied as per ANSI/ASA S1.11-2004 (R2009)
| Number | Requirement | SHOEBOX | |
|---|---|---|---|
| 1910.95(g) | Audiometric Testing Program | ||
| 1910.95(g)(7)(iii)(C) | Measurements of background sound pressure levels in the audiometric test room as required in Appendix D: Audiometric Test Rooms. | ✓ | SHOEBOX PureTest includes a room scan feature which, together with its Class 2 external microphone, provides octave-band sound pressure level measurement capability. |
| 1910.95(g)(10) | Standard Threshold Shift | ✓ | SHOEBOX reporting alerts user to OSHA standard threshold shifts. |
| Number | Requirement | SHOEBOX | |
|---|---|---|---|
| 1910.95(h) | Audiometric Test Requirements | ||
| 1910.95(h)(1) | Audiometric tests shall be pure tone, air conduction, hearing threshold examinations, with test frequencies including as a minimum 500, 1000, 2000, 3000, 4000, and 6000 Hz. Tests at each frequency shall be taken separately for each ear. | ✓ | SHOEBOX PureTest meets these requirements. |
| 1910.95(h)(2) | Audiometric tests shall be conducted with audiometers (including microprocessor audiometers) that meet the specifications of, and are maintained and used in accordance with, American National Standard Specification for Audiometers, S3.6-1969, which is incorporated by reference as specified in Sec. 1910.6. | ✓ | SHOEBOX PureTest meets specifications of a Type 4 Audiometer as defined by ANSI/ASA S3.6-2025. |
| 1910.95(h)(3) | Pulsed-tone and self-recording audiometers, if used, shall meet the requirements specified in Appendix C: “Audiometric Measuring Instruments.” | ✓ | SHOEBOX PureTest meets all requirements of Appendix C. |
| Number | Requirement | SHOEBOX | |
|---|---|---|---|
| 1910.95(h)(5) | Audiometer Calibration | ||
| 1910.95(h)(5)(i) | The functional operation of the audiometer shall be checked before each day’s use by testing a person with known, stable hearing thresholds, and by listening to the audiometer’s output to make sure that the output is free from distorted or unwanted sounds. Deviations of 10 decibels or greater require an acoustic calibration. | ✓ | SHOEBOX PureTest includes a biological calibration feature to enable compliance with this requirement. |
| 1910.95(h)(5)(ii) | Audiometer calibration shall be checked acoustically at least annually in accordance with Appendix E: “Acoustic Calibration of Audiometers.” Test frequencies below 500 Hz and above 6000 Hz may be omitted from this check. Deviations of 15 decibels or greater require an exhaustive calibration. | ✓ | SHOEBOX offers calibration service that enables compliance with this requirement. |
| 1910.95(h)(5)(iii) | An exhaustive calibration shall be performed at least every two years in accordance with sections 4.1.2; 4.1.3.; 4.1.4.3; 4.2; 4.4.1; 4.4.2; 4.4.3; and 4.5 of the American National Standard Specification for Audiometers, S3.6-1969. Test frequencies below 500 Hz and above 6000 Hz may be omitted from this calibration. | ✓ | All SHOEBOX PureTest calibrations are exhaustive calibrations per ANSI S3.6-2025. |
| Appendix C | Audiometric Measuring Instruments | ✓ | SHOEBOX PureTest complies. |
| Appendix D | Sound Level Monitoring | ✓ | SHOEBOX’s room scan functionality meets the functional noise monitoring requirements as described in OSHA 1910.95 Appendix D by the following methods:
Furthermore, SHOEBOX continuously monitors ambient noise during automated testing and will alert the administrator if OSHA MPANLs are exceeded. |
| Appendix E | Acoustic Calibration of Audiometers | ✓ | SHOEBOX PureTest complies. |
| Appendix F | Calculations and Application of Age Corrections to Audiograms | ✓ | SHOEBOX includes age correction feature. |
When testing with SHOEBOX, the mandated frequencies, intensity, and noise monitoring are pre-populated with OSHA testing requirements as shown below. The range of tone intensity for occupational testing is from 0 dB(HL) to 90 dB(HL). The ambient noise monitoring is set to ‘OSHA’ by default in this audiometric test configuration to facilitate ongoing ambient noise monitoring.

In addition to meeting the OSHA hearing test requirements for hearing testing equipment, SHOEBOX remains committed to customer satisfaction, product quality, and regulatory compliance. The company maintains an ISO 13485 quality management system and the following medical device registrations:
- Listed as a Class II medical device with US FDA
- Licensed as a Class II medical device with Health Canada
In addition to meeting the ANSI/ASA S3.6-2018 and IEC 60645-1:2017 Type 3 Audiometer Standards, SHOEBOX PureTest also complies with the following:
- Algorithms comply with ISO 8253:2010 Part 1: Pure-tone air and bone conduction audiometry
- Calibrations comply with ANSI/ASA S3.6-2018 and IEC 60645-1:2017
Finally, employers are required to keep records of all audiometric testing for the entire duration of an individual’s employment, and records need to be maintained for 30 years after the date of testing. Mobile audiometers enable organizations to go paperless, as the audiometric records are automatically synced to a secure data management portal. These solutions offer significant cost and efficiency benefits. Within seconds of completing a test, internet-connected mobile devices can upload the results, and reports can be securely viewed from any location through a simple web browser. Audiologists and employers can collaborate across locations to review data and coordinate follow-up actions. Once they have had a chance to review the results, employees and test administrators can provide digital signatures on audiometric examinations, which helps to streamline documentation practices.
Managing an occupational Hearing Conservation Program that is fluid, employee-friendly, and detailed enough to meet all relevant OSHA requirements can be challenging. Mobile, automated audiometers can make hearing testing easier to schedule, more convenient for the employees, offer greater flexibility in test environments, and enable better digital record keeping.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next nine weeks! However, if you want to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more about how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
References:
https://www.ishn.com/articles/84126-all-about-osha-s-audiogram-requirements
http://www.wcb.pe.ca/ DocumentManagement/Document/pub_guidetoaudiometrictesting.pdf
https://www.shoebox.md/content/uploads/OSHA-Hearing-Testing.pdf
Testing Environments: Finding an OSHA Compliant Testing Location When Using SHOEBOX

One thing that makes SHOEBOX unique is that it has been optimized for hearing testing outside of a sound-proof booth. However, that doesn’t mean that any location will be acceptable for testing. OSHA provides detailed guidelines for how to test outside of a booth as long as you stay within the prescribed sound levels or Maximum Permissible Ambient Noise Levels (MPANLs). More on these can be found in the OHSA document 29 CFR 1910.95 Appendix D.
SHOEBOX offers two methods to help with MPANL compliance. First, it uses a built-in Type 2 Sound Level Meter to perform a room scan prior to beginning a hearing test. This scan will assess your space and indicate if the noise levels in your testing room are within the maximum allowable limits. It also comes with a calibrated Class 2 external microphone that plugs into the lightning port of the iPad. This can also be used for room scanning and assessment prior to beginning testing to ensure the test location meets the OSHA-defined MPANLs.
For those who may need to manage a large fleet of SHOEBOX devices but are worried about compliance, the system can be configured to ensure that a room scan produces a passing result prior to being able to proceed to a test. You can also enforce that the room can be completed before beginning a day of testing, ensuring that this step can not be skipped.
After a room scan has been completed and the hearing test has started, you can configure the system’s built-in sound level meter to continuously monitor the room to detect any changes in background noise. If problematic noise is detected, the test will pause if the MPANLs have been exceeded. The individual being tested will be alerted, and action from the Test Examiner will be requested from the software. They will be asked to check for common sources of noise, such as people talking, phones ringing, etc. If the noise persists, the Test Examiner will need to decide if testing should be moved to a new room. In the event that a test is interrupted by noise, the system will prompt to retest any affected frequencies to ensure the noise does not affect the overall results.
Testing can be performed in any reasonably quiet room, such as a conference room, office, or lounge. Depending on your available testing areas, you may be challenged in finding a suitable testing space — one that meets the OSHA MPANLs. If your facility has a permanent space that can be designated for testing but slightly exceeds the OSHA MPANLs, it is possible to install noise-dampening panels in the room, which can be economical and easy to source. Mufflers applied to overhead fans or ventilation systems can be quite effective. These are known to be common sources of low-frequency noise. If you are required to utilize more than one testing room, it would be important to turn off common noise sources such as fans, printers, or power generators. If these options aren’t effective enough, it is possible to source cost-effective portable testing spaces that are as insulating as a soundproof booth without the high cost and need for regular calibration maintenance.
If you are a service provider and travel frequently, you may wish to bring a portable testing space, which includes noise-dampening fabric or panels such as those used in vocal recordings. These are easy ways to block out noise while also being compact and lightweight.
As the Test Examiner, there are a few things you should keep an eye out for. Once a test is complete, verify the results screen to see if any frequencies have been affected by noise and need to be retested. The room scan result will also be displayed below the audiogram; verify that you have a passing result. Noise measurements that exceed the OSHA MPANLs will be displayed in red, as opposed to compliant measurements, which will be displayed in black. This data is also exportable in CSV format should this be required for record-keeping.
Daily Maintenance and Calibration Requirements for Audiometers Used in Occupational Hearing Testing

There have never been better audiometer options for occupational hearing testing than what’s available now. Despite the advances in technology, there are still quick verification tasks that will help ensure that your testing equipment is performing the way it should every day of testing. Modern audiometers and headsets often offer interesting features to allow for daily verification tasks, routine maintenance, and associated record-keeping. In this chapter, we will be reviewing each of those tasks to help illustrate what maintenance you need to perform to help you meet OSHA hearing testing compliance.
Annual Calibration
All hearing testing systems should be calibrated at least once every 12 months. Historically, audiometers often remained stationary and were calibrated by a technician who visited the site where the OSHA-compliant audiometer was being used and provided a calibration report and associated correction factors. With advancements in technology, both in audiometer capabilities and the improvement in robustness in hardware components in audiometric headsets, calibration can look a little different than in years past. For computerized and tablet-based audiometers, a full calibration can be obtained by testing the headset alone and providing calibration correction factors. These calculations are then applied to the software resulting in a re-calibrated system.
ANSI/ASA S3.6 specifies that all clinical audiometers need to be calibrated at a minimum every 12 months. OSHA 29 CFR 1910.95 differentiates between periodic and exhaustive calibrations; however, once a system or headset is on-hand for calibration, most calibrators will opt for an exhaustive calibration, which in turn meets the ANSI specifications as well as the ones specified by OSHA.
Daily Functional Check
The purpose of the Daily Functional Check is to ensure that the cable connections are interruption-free and that there is no abnormality (static, volume changes) in the sound output of the testing system. For this test, ANSI recommends using a 1000 Hz tone at 70 dB(HL) and requests that the test administrator put on the headphones and present these tones one at a time in each ear, all while putting slight pressure on the headphone jack connectors, and wiggling the cables to listen for any abnormalities. The tone presentation time should be approximately 20 seconds on each ear to allow for adequate manipulation of the jacks and cables. Should abnormalities be discovered, these should be addressed prior to continuing with testing. The Daily Functional Check is a static one-time verification each testing day, and the results should be recorded to help with the possible future investigation of an emerging equipment issue or in the case of an audit request for
equipment verification practices.
Daily Biological Verification
The Biological Verification aims to ensure that there hasn’t been significant sound output drift on a per-frequency basis since the last annual calibration. In order to set up this test, it is recommended that you create a distinct result file for this purpose for each individual who may administer workplace hearing testing. For example, creating a file with the patient name ‘Biological Verification A.A.’ under which every test can be saved and compared to baseline. Only individuals with stable hearing levels should perform Biological Verification.
After the first test for an individual has been marked as a ‘baseline,’ each test after that can be compared frequency-by-frequency for deviations of more than 10 dB(HL). Should there be deviations of more than 10 dB(HL), the system will require additional attention, and we would recommend contacting your Professional Supervisor or Hearing Conservation Program Administrator for recommended next steps.
Example of a Biological Verification Comparison:
| Biological Verification: A.A. (tester’s Initials) | ||||||||
|---|---|---|---|---|---|---|---|---|
| Test date | ear | Test Frequency (Hz) Threshold Result in dB(HL) | ||||||
| 500 | 1000 | 2000 | 3000 | 4000 | 6000 | 8000 | ||
| July 30, 2019 | L | 5 | 0 | 0 | 5 | 10 | 15 | 15 |
| R | 0 | 5 | 0 | 0 | 5 | 10 | 15 | |
| April 17, 2020 | L | 5 | 5 | 0 | 5 | 5 | 10 | 15 |
| R | 5 | 5 | 10 | 5 | 20* | 30* | 30* | |
| Regular Test Day | R | 5 | 5 | 10 | 5 | 20* | 30* | 30* |
* frequencies outside of the accepted range of variation of 10 dB(HL)
Everyday Troubleshooting
Occupational Hearing Testing Workflows: Steps to Follow When Using SHOEBOX Audiometry

Kate Mosley is the SHOEBOX Product Manager for Occupational Hearing Testing. Through deep product knowledge and market research, Kate is laying out a vision for occupational hearing testing that offers more flexibility, is easier to conduct, and is cost-effective to perform.
Kate has vast experience and a keen understanding of the steps – or workflow – involved in running a successful occupational hearing testing program. Here, she shares her insights.
Can you tell us what you mean by “workflow.”
In an occupational hearing testing program, there are a series of steps to follow as you work through the process of testing. We call these steps a workflow. This includes preparing your audiometer for a day of testing, preparing your employees, administering the testing itself, offering training, administering questionnaires, reviewing results with the employees, retesting as needed, and following through on required follow-up actions. All of these activities feed into the workflow of your program.
Who is responsible for conducting hearing testing?
This can vary from one organization to the next. Typically, it is managed by the health and safety managers or any other member of the health and safety team. These could include department administrators, industrial hygienists, occupational health nurses, or occupational hearing conservationists. However, the test administrator cannot be the direct manager of the employees being tested for reasons of health information privacy.
How do you determine who needs to be a part of your program?
Any employee who works in an environment where they are exposed to 85 dB(A) of noise time-weighted over eight hours of work needs to be included in the company’s hearing conservation program. Examples of 85 dB(A) of sound could be produced by lawnmowers, leaf blowers, heavy traffic, noisy restaurants, food blenders, or garbage disposals. Employees working in these conditions need to be trained, are required to wear hearing protection, and should have their hearing tested annually to ensure no change in hearing ability from one year to the next.
What steps would the test administrator typically follow on a testing day, and do these change from state to state or region to region?
The steps are consistent and in line with Federal OSHA regulations.
Step 1. Daily Verification Tasks
First, test administrators need to prepare the audiometer and headphones prior to testing. This ensures the audiometric system is working as expected. The two tasks that should be completed before proceeding with testing employees are the Daily Functional Check and Daily Biological Verification. These tests are also covered in detail in this e-book’s Chapter 5: Daily Maintenance and Calibration Requirements for Audiometers Used in Occupational Hearing Testing.
Essentially, each testing day should begin with a left and right Functional Check. SHOEBOX includes a feature that enables you to perform and record a check of the transducers easily. For this test, the system produces a 70 dB(HL) tone at 1000 Hertz. By putting the transducers on your own head and listening one ear at a time, you can check for intermittences and ensure no crackling sound is observed.
Next, perform a Biological Verification of the device. This ensures that there has not been a significant sound output drift from the annual calibration file. You can do this by testing yourself or someone with known hearing levels at all test frequencies and doing a comparison. By testing this same person prior to each testing day, you can ensure that there have been no significant changes to the sound output. If there is more than a 10 dB change in that person’s results, then you should perform further system checks and potentially replace the transducers.
Step 2. Assess your Room
Ensure that your testing room is adequately quiet and does not exceed the OSHA-defined Maximum Permissible Ambient Noise Levels (MPANLs). SHOEBOX offers a room scan feature that uses a Class 2 external microphone, which plugs into the lightning port of the iPad and is used to monitor sound levels. This scan can be performed throughout the testing day, as often as needed, to confirm that the ambient noise levels have not changed.
Step 3. Completing Questionnaires
Many hearing tests start with a questionnaire. This is a personal hearing health history and self-assessment that helps the test administrator, as well as the Audiology Reviewers, better understand factors that could influence the test, as well as how the employee perceives their own hearing health. SHOEBOX offers a number of questionnaires integrated into the device itself, with one specifically designed for hearing conservation programs.
Step 4. Testing
Once the questionnaire is complete, it is time to start testing. SHOEBOX offers automated, assisted, and manual modes of testing. For occupational health, seven frequencies (500, 1000, 2000, 3000, 4000, 6000 and 8000 Hz) on both the left and the right ear will be selected for testing regardless of which testing mode is chosen.
Step 5. Shift Analysis
Once that test is complete, some audiometric testing equipment will notify you right away if a shift has occurred. With SHOEBOX, reports are generated directly on the iPad that are used to determine whether or not the employee had a Standard Threshold Shift (STS). If there has been a shift, the employee may need to be retested and require additional training (Step 7), but first the results must be reviewed by an audiologist.
What steps do employees need to follow?
There is little for the employee to do other than to offer verification. If the test is performed as a baseline, we need to know if they have been exposed to loud noise where they weren’t wearing hearing protection in the previous 14 hours. For example, if they attended a loud concert, had been hunting, or riding a motorcycle. If they have, they’ll need to postpone their test for another day.
The other would be to assess if they have any congestion or wax build-up in the ear; this can affect results and could potentially show a standard threshold shift where one doesn’t exist. They may need to see their doctor to have wax removed, which is perfectly normal, or wait until the congestion has passed. Otherwise, the employee only needs to show up for their test on time.
What are the next steps for both the employer and the employee after testing is complete?
Step 6. Audiological Review and Reporting
If the results on the audiogram meet any of the predetermined filtering criteria, including changes in hearing and/or medical or audiological flags, it will need to be reviewed by an Audiology Reviewer who will then make recommendations based on their review and expertise. We cover Audiology Reviews in more detail in chapter 8.
Step 7: Retesting
After an initial review of the results, the Audiology Reviewer may request that the employee be retested. This can be due to a variety of reasons: to confirm the validity of a test result, to fully complete a test, or to confirm whether an STS is temporary or persistent. Retests may require sending your employee to a local clinic. When testing with SHOEBOX, retests can easily be done on-site.
Step 8. Retraining
If there has been a Standard Threshold Shift, there are additional steps that need to be taken, starting with retraining on hearing protection options and insertion. Asking the employee to demonstrate how they insert their hearing protection is an easy method to assess their knowledge and technique. A reassessment of the employee’s workspace can help determine if there are remediation steps that should be taken to protect them from sources of elevated noise. Occasionally equipment malfunctions, causing it to operate at a higher or noisier level than normal. Those assessments can all be performed by the employer. If there’s a significant change in hearing or something unusual about the audiogram, additional follow-up recommendations may be made.
Step 9. Follow-up
It may be recommended that the employee see either their primary care physician or an audiologist for a full consultation. If there is a Standard Threshold Shift that is deemed recordable and is work-related, there are additional steps required for the employer to ensure that the recordable shift has been logged on the OSHA 300 Log. This is another topic that warrants a more extended conversation. We cover it in more detail in Chapter 9: What to do when an employee has an STS? What is Required for Maintaining OSHA 300 Logs in Occupational Hearing Testing Programs?
This sums up the hearing testing workflow. There are many other elements of the entire Hearing Conservation Program, but when it comes to testing, it starts with daily preparation – your equipment and the room – executing the questionnaires, running the test, reviewing results, retraining if necessary, and planning the next steps or follow-up.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next 12 weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more about how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
Audiological Review as Part of a Hearing Conservation Program

Vanessa Gauthier-Davidson, an In-house Audiologist at SHOEBOX Ltd, acts as a coordinator of the SHOEBOX Audiology Review Network; an international team of licensed Audiologists available to assist SHOEBOX customers meet their OSHA and MSHA compliance requirements. The Audiology Review Network offers businesses compliant access to regionally licensed Audiologist(s) for rapid review of their occupational hearing testing results. Vanessa has extensive experience and a keen understanding of the various roles. Audiologists play in a successful occupational hearing testing program. Here she shares her insights with us.
Can you explain two main professional roles in a Hearing Conservation Program?
The two main roles that are mandated by OSHA/MSHA are 1) Professional Supervisor and 2) Audiology Reviewer. These roles can be fulfilled by the same person or by different individuals. Various organizations and standards use interchangeable terms from ‘Supervising Audiologist or Physician’ to ‘responsible to an Audiologist or Physician’ to ‘Professional Supervisor.’ For our purposes here, we will combine these under the term ‘Professional Supervisor (PS).’
Notably, the Council for Accreditation in Hearing Conservation (CAOHC) provides a unique certification to Audiologists and Physicians to oversee Hearing Conservation Programs (HCPs): ‘Certified Professional Supervisor of the Audiometric Monitoring Program©.’ This certification is renewable every 5 years, and although not mandatory for an Audiologist or Occupational Health Physician to have when overseeing a program or perform reviews, it is considered best practice. CAOHC also offers the most up-to-date knowledge and materials for certification. Visit for more information on becoming a certified Professional Supervisor.
The PS is responsible for overseeing the clinical, training, and testing aspects of an HCP. They need to understand what type and intensity of noise the employees are exposed to, how the workplace noise is measured and monitored, the content of the annual hearing conservation training, as well as the hearing protection provided to workers. A PS can also fulfill the role of Audiology Reviewer for the same organization, or this role can be fulfilled by other qualified professionals.
Take, for example, a large organization with program participants across multiple states. To be in compliance with state-based audiology clinical regulations, Reviewers must be licensed in the states where they are providing review. Therefore, an organization that has HCP participants in 44 different states would require Reviewers licensed in each of those states. Many Audiologists working in hearing conservation hold licenses in several states. In contrast, individuals holding solely PS responsibilities can oversee a program that is active in multiple states without requiring licensure in all of those states. It would be counterintuitive to require multiple supervisors to oversee a single program to meet individual state licensing requirements. In this scenario, the PS provides direction and oversees the work of the state-licensed Audiology Reviewers across the entire HCP.
Audiology Reviewers must be either a licensed Audiologist or a Physician trained in the interpretation of audiograms. They are responsible for assessing audiograms for all employees in an organization’s HCP. As a clinician, the Reviewer is looking for changes in an employee’s hearing from one test to the next and also for ‘problem audiograms,’ which are results that may indicate the need for further testing. Note that this is an OSHA-mandated audiometric testing requirement on top of reviewing audiograms for noise-related hearing shifts. If further evaluation is needed, the Reviewer will recommend a medical or an audiological referral.
The Audiology Reviewer provides both clinical reviews and knowledge of hearing. They act as a hearing health advisor. While it may be relatively easy to read an audiogram, it’s harder to interpret one and provide appropriate follow-up recommendations. It’s not just about looking at the audiogram and its symbols; the individual responses on the annual pre-test questionnaire, as well as the historical audiograms and trends in results, are key in results interpretation. Several data sources are drawn upon for follow-up recommendations.
Reviewers use their clinical expertise to determine whether a change in hearing could be the result of a medical condition that may benefit from further investigation (e.g. a sudden drop in hearing, potential middle-ear involvement). They also evaluate results to ensure their validity, as some types and degrees of hearing loss should be evaluated manually by a hearing professional, in contrast to testing with a technician. Ultimately, HCPs are in place to prevent workplace hearing loss. And it is preventable! The Professional Supervisor and Audiology Reviewers play key roles as they are responsible for probing into and understanding the reasons why a shift in hearing may have occurred and subsequently making impactful recommendations.
What qualifications or certifications does an Audiology Reviewer require?
If your Reviewer is an Audiologist, they will have a Doctoral or Masters degree in Audiology as well as active state-based licensure. Rules and regulations vary by state/region; therefore, knowledge of those as they pertain to occupational hearing testing would be key. If your Reviewer is a Physician, he or she will be an M.D. or D.O. with experience in occupational medicine.
Although your Audiology Reviewer doesn’t require CAOHC certification, the knowledge provided by this additional training can be of significant benefit to the audiogram assessments and follow-up recommendations. The In-House Audiology Team at SHOEBOX is CAOHC certified as Professional Supervisors.
How is the relationship between Employer and Reviewer established and maintained?
OSHA 29 CFR 1910.95(g)(3) states that “A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist, or physician.”
For companies that outsource their testing to a service provider, that provider usually establishes the connection to the Audiologist or Physician for review and referral. For companies that manage their own testing, they should establish a relationship with a regional Audiologist to provide reviewer and supervision services.
SHOEBOX PureTest customers have access to an international network of licensed Audiologists. These companies use automated testing equipment to run the hearing testing and contract Audiology Review services. Many SHOEBOX occupational health customers also contract review services from the SHOEBOX network of Reviewers. Quality audiogram reviews are provided in a timely and clear fashion via the SHOEBOX individualized web portal. The final step of the clinical workflow for an HCP is that appropriate paths of referrals for both medical and audiological follow-up should be established for each company location.
What process does a Reviewer typically follow to provide their services?
Historically, an employer would send paper audiograms to an Audiology Reviewer with whom they had an established business relationship. The Reviewer then assessed each employee record and provided written recommendations back to their client. This was a lengthy and arduous process that can now be streamlined significantly thanks to technology and innovative new products.
With SHOEBOX PureTest, Reviewers leverage our web portal to perform their reviews and provide feedback. The Reviewers access the hearing health records of the clients in the states they are assigned. The web portal triaging review system intelligently compares the most recent test against an employee’s baseline to know if a shift has occurred and/or if additional review is indicated.
The portal is also the mechanism used for communicating recommendations to the employer, including follow-up actions. When a Reviewer recommends that an employer look at a specific employee file in the portal, we simply change a flag status to “follow-up.” The employer is responsible to log into the web portal and action the Reviewer’s recommendations.
As this is all accomplished digitally, communication is streamlined and easy to access. Tracking of actions is also chronicled, which is especially helpful retrospectively. The steps that remain to be completed are clearly indicated, as well as what has already been actioned. All of this makes complying with OSHA reporting requirements easier and more efficient.
The concept of the SHOEBOX Audiology Reviewer Network is different from how most reviews are done. What are the advantages of using this network?
With the Reviewer Network, we can offer reviews across the United States and Canada. It can be challenging to find a local Reviewer in every state/region where an organization may have facilities. The Review Network removes that burden from the employer and enables a company to offer full hearing conservation services in-house.
With SHOEBOX mobile audiometry, a company can save time and money by conducting tests and retests in-house, and the Reviewer – who is remote but available digitally – can access and analyze the audiograms in real-time. Easy access to the web portal helps the Network to provide swift results turnaround time, with live updates. Furthermore, this real-time progression makes it hassle-free for the reviewer and company to communicate recommended follow-up actions easily.
What happens if a hearing shift is likely not related to noise exposure in the workplace?
When a shift in hearing has been identified by an employee’s annual hearing test, many employers want to know if that hearing loss is potentially due to noise in the workplace or from something else. The employer will want to know if there are factors in the employee’s activities outside of work that may be the main cause of the shift in hearing. During the review process, the Audiology Reviewer will take all factors into consideration and should a cause other than exposure to high levels of noise in the workplace likely be the sole cause of the shift, a recommendation will be made by the Reviewer not to include that shift on the OSHA reporting Log. Often, in this case, a medical or audiological referral is recommended to investigate the cause of the hearing loss further.
In summary, the roles Audiologists and Physicians play in hearing testing results and recommendations, as well as in overall Hearing Conservation Program supervision, are vital to OSHA compliance and the success of the program. SHOEBOX PureTest and the SHOEBOX Audiology Review Network are uniquely positioned to help with these important elements of your program.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next 5 weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more about how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
What To Do When an Employee Has a Standard Threshold Shift (STS): How to Maintain the OSHA 300 Log

In the event that an employee suffers a work-related illness or injury, the employer is required to complete a form known as the OSHA 300 Log. This Log is used to categorize and track the severity of the illness or injury.
Every year at the beginning of February, employers must post the results of their annual OSHA 300 Log publicly to their employees in the workplace. Throughout the year the Log is submitted electronically to OSHA respecting the required reporting guidelines. Companies with 10 employees or fewer are exempt from recording and reporting their work-related illnesses or injuries. The primary goal of OSHA’s record keeping is to capture data for statistical purposes and to look for opportunities to improve health and safety for workers. However, a log won’t protect an employee from a future illness or injury. This is why education, awareness, prevention, and protection are so important.
What is a Standard Threshold Shift?
When it comes to hearing loss, a Standard Threshold Shift (STS) is a 10 dB(HL) deterioration of the average of thresholds at 2000, 3000, and 4000 Hz when comparing the baseline for each ear to the most recent test. Age correction may be permitted depending on the state where the testing is taking place. When an STS is identified, the employee must be notified in writing within 21 days. If an STS is present and the average hearing level at 2000, 3000, and 4000 Hz is equal to or greater than 25 dB(HL), then it should be recorded on the OSHA 300 Log. The employer has 30 days to perform the recommended retest, but ideally it should not be performed on the same day as the original test that reported the STS due to potential transient issues impacting hearing.
After the completion of the retest, and confirmation by a qualified hearing healthcare professional that a work-related STS has occurred, the employer has seven days to record the shift on the OSHA 300 Log. If the retest does not confirm the STS, then no recording is necessary. And if a retest is not performed, the STS is automatically confirmed and is required to be logged within 30 days of the original test. If a subsequent test shows that the recorded STS is no longer present, it can be repealed from the OSHA Log.
Regardless of whether a shift in an employee’s hearing is determined to be recordable or not, there are specific follow-up actions that the employer should take. First, if the employee has already been fitted with hearing protection devices, they should be refitted and retrained. It may also be time to consider hearing protectors that offer greater attenuation if necessary. An employee that is not currently wearing hearing protection devices should be fitted with them and trained on their proper use. Some additional follow-up actions include:
- obtaining new dosimetry – or measurement of noise exposure – for the employee
- investigating noise control mitigation options
- fit-testing of hearing protection
As a final precaution, the employee might have to be referred to an external clinic for further assessment. This will help to determine if a potential medical pathology of the ear is present, or if advanced testing is required.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next 4 weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more on how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
The Importance of Historical and Current Occupational Hearing Testing Data

A successful hearing conservation audiometric testing program is highly dependent on quality historical records. OSHA 1910.95 mandates that testing reports include:
- Name and job classification of the employee
- Test date
- Test Administrator’s name
- Date of the audiometer’s most recent calibration
- Background sound pressure levels in audiometric test rooms
- Employee’s most recent noise exposure measurement (TWA)
- Completion of training materials
You will be required to produce these records should an employee, former employee, or auditor request them. As per OSHA, testing data must be kept on file for the duration of the employee’s employment. You may be asked to provide audiometric testing data for the entirety of an employee’s tenure with your organization. If you’re testing outside of a standard sound booth (as many clients do with SHOEBOX), you must also maintain ambient room noise records to prove that the environment was sufficiently quiet to adhere to OSHA’s Maximum Permissible Ambient Noise Levels (MPANLs).
In contrast, noise surveys and dosimetry records pertaining to specific employees need to be kept on file throughout employment, as well as for a minimum of two years following termination of employment.
Advantages of Digital Record Keeping
For customers who use SHOEBOX for occupational hearing testing, the entirety of their audiometric test and associated data, as listed above, is saved and stored digitally. There are several key advantages in favor of digital record keeping over paper files.
What comes to mind first is the space required to store paper-based records properly and safely. Some organizations have had to resort to paying for storage units that provide the necessary extra space to house paper records securely. With risks of fire, flooding, and paper degradation, this is not an optimal choice in the current information and technology age.
With digital records, there are no space limitations. Filtering through the information to find what is needed is also much more convenient with the advent of electronic record keeping. Precise information can be obtained immediately with a search query in a database for a specific employee’s name, ID number, and/or date range. The same type of search is significantly more tedious when using paper records. You must be highly organized to find needed data when searching through thousands, or even tens of thousands, of paper records potentially going back decades.
Turnover happens, and roles change within all levels of an organization. This can result in an overabundance of records, especially for companies with higher turnover rates. An employee may have only worked for your organization for a couple of months, but their hearing test data must be maintained with the same regard as your most tenured workers. The individuals administering your program can also exit your company, or the program may expand to a level where additional help is needed. Electronic records make the management of a hearing conservation program more straightforward for the people maintaining it today and for years to come.
Record Maintenance
A pervasive problem we often see is one of missing records and out-of-date baseline indicators. Once a record is missing, it can be troublesome to track, especially if you don’t know it’s missing. A common cause of missing records occurs when an employee visits an outside clinic for a test or retest. The employee may return with a paper copy of the audiogram that then needs to make its way into their HCP file. The results can get misplaced, or steps can be missed to have them uploaded into a records database. It can be challenging to ensure that hard-copy records are uploaded to the database in a timely manner. Organizations utilizing outside clinic audiometric testing services will likely have a process in place to upload paper records. Chasing down these records with the clinic can be time-consuming and is likely not a priority in a busy Safety Manager’s schedule. Know that once your historical data is uploaded into the SHOEBOX Portal, it is accessible to you at any time in its entirety, at no additional cost to you. For some, it may take some extra time and effort to obtain and import historical records, but once the work is done, it will not have to be repeated in future.
What we encounter most often, however, is out-of-date data. When clients change service providers, some of the data settings can get lost in the process, or the data is incorrectly categorized or uploaded into the new database. If a company has done this several times, the issue becomes compounded and even more troublesome.
When new SHOEBOX clients come on board, we often see baselines that are out-of-date. They may have 20 years of records for an employee, but only a single baseline test is established (usually from the employee’s hiring date). There may have been several persistent threshold shifts during that employee’s tenure. Often, a clinical priority when beginning with a new client is to review and correct their baseline data. If it is not up-to-date, this is highly problematic as it will result in a significantly higher percentage of STSs (Standard Threshold Shifts). For a smaller number of employees (e.g. <300), an Audiology Reviewer is to go case-by-case to update them if they have the bandwidth to do this proactively. Alternatively, historical baselines can be reviewed and updated on a case-by-case basis as patients are triaged following annual hearing testing.
Digital Storage of Hearing Conservation Data
In our early days of offering occupational health solutions, we encountered some apprehension due to concerns with cloud-based storage of digital records. After learning about the advanced security measures that are in place to keep data safe and secure, these concerns are now a thing of the past. On the plus side, electronic records are more accessible, easier to work with, and don’t require any physical space for storage. SHOEBOX for Occupational Hearing Testing includes unlimited data storage. Once people understand the emphasis we place on data security and the new-found ability to manage records, the transition to cloud-based record storage is not only welcomed, it’s embraced.
Accurate and accessible audiometric testing data is one of the foundations of any well-maintained Hearing Conservation Program. Digital records provide organizations with the flexibility needed to scale and the ability to access decades worth of records with a quick and straightforward search.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next three weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more on how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
Shifting Away from Once-a-Year Testing in Hearing Conservation Programs with SHOEBOX

The annual scheduling of all participating employees in a Hearing Conservation Program (HCP) can present significant challenges for many organizations. Here, Kate Mosley, Product Manager for Occupational Hearing Testing at SHOEBOX, provides a vision for adopting a different approach.
What is the advantage of shifting away from testing all employees in an HCP at the same time once per year?
We are asked this question a lot. There are many advantages.
The traditional approach businesses use to manage their HCP is hiring an audiological service provider. This provider comes onsite with a mobile clinic, typically a large truck outfitted with testing booths and equipment. Alternatively, companies may opt to send participating employees to a local clinic. Both of these choices can become prohibitively expensive, as well as time-consuming.
The truck is usually scheduled over a one- or two-day period once per year. On a given day and time, the employee must make their way to the location on campus where the truck is set up. In an organization with hundreds or thousands of employees in their HCP, the burden of scheduling these employees and the oversight required to ensure they get to the mobile clinic can be significant.
This can be challenging, depending on the type of operation you’re running. These employees may be performing an important service or operating a specialized piece of machinery. To pull them away from their job or off of a production line often means a disruption of service. You may even be required to backfill them while they are away to ensure continued operations. Not only is this disruptive, it quickly becomes expensive, especially when you pay overtime to employees who cover a colleague’s workstation while they are undergoing their hearing test. Then, for many reasons, they couldn’t leave their post or make it to work that day, and they missed their scheduled appointment. Now rescheduling is required.
These tests are typically booked close together, often leaving the employee less than 15 minutes to get in and out of the mobile clinic, which could very well be parked on the other side of the campus. Everything needs to line up perfectly. Their replacement needs to arrive on time, they need to be able to leave their post on time, and they need to be able to get from their workplace to the mobile clinic on time.
This model of testing can be very complicated.
Moving towards a more flexible schedule of testing has plenty of advantages. This becomes less of a burden on the Health and Safety Manager responsible for scheduling to do so in a short time. Employees will find this less disruptive and more conducive to their agendas, and it can be much less expensive. This testing flexibility also enables you to test at any time of the day. For those employees who work the “third” or overnight shift, testing them before they begin their day versus having them come in during their personal time offers additional advantages.
Finally, when attempting to schedule very large numbers of employees, it is not unusual for Health and Safety Managers to spend upwards of two weeks just to establish the testing schedule for all participants. This doesn’t take into account rescheduling those folks who missed their appointment. This may not be the most efficient use of time for these skilled professionals.
Is there a better way?
Test more often, and spread the testing out. There are 365 opportunities to get all of your testing done. Figure out what makes the most sense for your business. If you have only 100-200 employees who are part of your program, then perhaps testing a few people once a week makes sense. For larger groups of, say, 500 or 1,000, you may want to set aside a couple of months during the year to focus on hearing testing. The point is, you have the flexibility to set a schedule that works best for your organization. We can offer consulting in this area to help you figure out what might work best for you.
With a spread-out testing schedule, how do you remember who is due for testing?
We suggest using either a date-of-birth schedule or a date-of-hire schedule. Either one works well and is easy to track and manage. Employees will always remember their birthdays, so this is a common approach. If you plan to perform the baseline audiometric test at or very close to a new employee’s hire date, then using the date of hire anniversary may make more sense for you.
Either one works well and has its advantages. You have the flexibility to do what works best for you.
Speaking of new employees, how is getting them added to your program different under this testing model?
OSHA requires that you test new employees within the first six months of their hire date. Best practice is within one month of hiring. Imagine if your service provider was on-site today, and you have a new hire starting next week. That provider will not be returning until next year. You either become out of compliance as soon as that employee hits their six-month-plus-a-day mark, or you must find a local clinic and have them scheduled there. All the usual challenges of sending the employee to a clinic during their work shift apply.
With SHOEBOX, every new employee can be tested within days or weeks of employment.
You’ve touched on this, but can you dive deeper into what happens when an employee misses their scheduled hearing test?
In the past, when an employee missed their scheduled hearing test, they would be sent off-site to a local clinic. Even if you hire a service provider, it is unlikely they will be available or that it would be cost-effective for them to come back on-site to test the small percentage of employees who missed their originally scheduled test.
That clinic trip can be time-consuming and costly. Particularly if you cover travel expenses, the employee visits the clinic during work hours, and you pay someone else overtime to cover their shift. If you are operating in a somewhat remote location with no testing clinics nearby, that could mean a half or even a full day away from work for the employee.
With SHOEBOX, if an employee misses their test, it can be rescheduled for the next time they are at work.
And if an employee requires a retest because their audiogram looks invalid, how is that handled in this type of testing model?
In the past, with the standard model of testing with a van, the employee would be retested immediately. This can be counterintuitive. If an employee has a wax build-up or congestion from a cold, they might present with a Standard Threshold Shift when the tests are performed back-to-back. In this scenario, you are likely to see the exact same result. If you can retest in a week or two after their cold has subsided or had wax removed, you may see more accurate results.
What are the disadvantages of daily audiometric testing? Can you think of any?
I can think of one. Everyone has a lot on their plate, particularly Health and Safety Managers, who have many responsibilities. There is some prep work to ensure your industrial audiometer is functioning properly and is ready for testing. This can take 5-to-10 minutes. If you test daily, this preparation time adds up. Consider grouping some of your testings; for example, test everyone who has a work anniversary this week on Friday. This way, you only do the audiometer preparation work once, but you were still able to test everyone that week.
We believe that making this shift away from once-per-year testing to something more fluid and regular will give your Health and Safety Team more flexibility and more control over your program. We also believe that this approach makes the retest process easier to manage, which could help improve rates of compliance.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing a new chapter each week for the next two weeks! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more about how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.
Delivering an Optimal Employee Experience During Hearing Conservation Testing Using SHOEBOX

While hearing testing may seem like a routine activity, for some employees, it can be stressful. Those uncomfortable in the close quarters of a refrigerator-sized sound booth may be unwilling to participate in annual testing. This will have an impact on your ability to maintain a compliant program.
For those who use a service provider to manage the testing for their Hearing Conservation Program, mobile clinics can offer a convenient way to perform testing. However, sharing the mobile clinic space with a handful of colleagues doesn’t usually result in an optimal experience.
Modern, portable test equipment like SHOEBOX PureTest can help improve employee productivity and their engagement in the HCP, leading to a better experience for everyone.
Productivity
Balancing a compliant program with employee productivity can be challenging. Being pulled away from one’s regular duties for a hearing test may seem to some a waste of time. A common sentiment is, “I still need to get my work done. I just don’t have time for this right now”.
It’s true that conventional approaches to testing, whether at a local clinic or in the mobile van of a service provider, can be time-consuming for the employee. Portable audiometric testing devices like SHOEBOX bring testing closer to the employee. Any reasonably quiet room at their place of employment can be used to administer testing. This is both more convenient and less time-consuming. Portable audiometry helps to minimize interruptions in an employee’s work day.
Employee Engagement
SHOEBOX hearing testing can be automated and self-administered, meaning the employee plays a more active role in the administration of the test. The very nature of how the test is performed results in a higher level of engagement. Plus, the employee is allowed to be in a much more comfortable setting, usually a room by themself, or at most, with one other test administrator.
SHOEBOX PureTest provides a unique benefit in workplaces where employees communicate in a language other than English. The gamified interface is largely language-agnostic. That said, SHOEBOX provides an impressive number of translations for employee-facing testing screens. More languages are added regularly via software updates. Additionally, the SHOEBOX Hearing Conservation Questionnaire is available in both English and Spanish.
Conclusion
While SHOEBOX opens the door to improved flexibility and lower costs, it’s the better employee experience that makes it the testing equipment of choice for many forward-thinking organizations. Having a higher percentage of employees engaged in hearing testing, and hearing conservation activities, results in a more effective overall Hearing Conservation Program – which is a win-win situation for all involved.
This guide is intended to be a useful tool on your journey to in-house mobile hearing testing or adding iPad-based testing to your services business. We’ll be releasing the final chapter next week! However, if you would like to download the complete guide now, complete the form below.
Feel free to share this with colleagues, peers, or others who would benefit from learning more on how to optimize your Hearing Conservation Program with innovative employee-focused testing and follow-up.

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