OSHA's hearing conservation standard requires employers to make audiometric testing available at no cost to all employees whose exposures equal or exceed the action level, and to "obtain" audiograms — the regulatory obligation falls on the employer (29 CFR 1910.95(g)(1)-(2)). An employer cannot physically compel an employee to submit to testing.
OSHA’s hearing conservation standard requires employers to make audiometric testing available at no cost to all employees whose exposures equal or exceed the action level, and to “obtain” audiograms — the regulatory obligation falls on the employer (29 CFR 1910.95(g)(1)-(2)). An employer cannot physically compel an employee to submit to testing. In practice, an employee’s refusal should be documented in the employee’s Hearing Conservation Program record, the employer’s obligation to offer testing should be documented as fulfilled, and the refusal itself should be treated as a recordkeeping entry. Employer documentation that testing was offered and refused protects the program’s compliance record. Some employers address persistent refusals through progressive discipline policies — the appropriateness of this approach depends on applicable employment agreements and state law. SHOEBOX: When testing is available on-site and on-demand rather than requiring employees to travel off-site or wait for a scheduled van visit, the friction that contributes to refusals is reduced. Programs using SHOEBOX PureTest report that the short test duration and familiar tablet interface lower resistance compared to traditional booth-based testing.
