An photo of a workplace employee having his hearing tested with an Occupational health and safety manager administering the test

OSHA Requirements for Occupational Hearing Testing

Hearing Conservation, Hearing Conservation eBook

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 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 Audiometry 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 requirement.


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 frequency is recommended by experts in the field as it is helpful in the audiological and work-relatedness analysis of the results.


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.


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 Audiometry 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)

This table briefly references the required OSHA 29 CFR 1910.95 sections for occupational hearing testing.

OSHA 29 CFR 1910.95 sections for occupational hearing testing

OSHA 29 CFR 1910.95 sections for occupational hearing testing

OSHA 29 CFR 1910.95 sections for occupational hearing testing

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 test configuration to facilitate ongoing ambient noise monitoring.

OSHA testing requirements


In addition to meeting the OSHA 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 Audiometry 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: DocumentManagement/Document/pub_guidetoaudiometrictesting.pdf