Hearing Conservation Program & Annual Training (1910.95)

The 85 dBA Line Changes Everything

Noise is the injury you don't feel happening. OSHA's rule turns on one number: once workers are exposed to an 8-hour average of 85 dBA, the employer owes a full hearing conservation program — not just earplugs, but monitoring, audiograms, hearing protection, annual training, and records.

At a glance: An 85 dBA 8-hour TWA (the action level) triggers a hearing conservation program under 1910.95(c); the 90 dBA 8-hour TWA is the PEL (Table G-16, 1910.95(b)). The program's elements are monitoring (c), audiometric testing (g), hearing protectors (i)–(j), annual training (k), and recordkeeping (m). Construction requires a hearing conservation program above its 90 dBA limit (1926.52(d)(1)) but does not list its content. OSHA requires a hearing conservation program once workers are exposed to an eight-hour average of 85 decibels, including noise monitoring, annual audiograms, hearing protectors, and annual training on 1910.95.

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Two Numbers: The Action Level and the PEL

The trap is thinking the PEL is the only number that matters. You can be under 90 dBA and at or above 85 — and still owe the entire program. The action level is deliberately lower than the PEL because hearing loss accumulates well before the permissible limit.

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What the Program Contains (1910.95)

A "continuing, effective" hearing conservation program has five moving parts:

1. Monitoring (c) / (d). Measure exposures to identify who is at or above 85 dBA, and repeat monitoring when changes in production, process, or controls could increase exposure.
2. Audiometric testing (g). Establish a baseline audiogram within 6 months of first exposure at the action level (1910.95(g)(5)), then an annual audiogram (1910.95(g)(6)), and compare for a Standard Threshold Shift.
3. Hearing protectors (i)–(j). Make HPDs available to all exposed at or above 85 dBA, ensure they're worn by those who've had an STS or are above the PEL, and provide a choice of types with training on fit and care.
4. Training (k). Annual — content below.
5. Recordkeeping (m). Keep noise exposure measurements for two years (1910.95(m)(3)(i)) and audiometric test records for the duration of the affected employee's employment (1910.95(m)(3)(ii)).

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Audiometric Testing and the Standard Threshold Shift

The program's early-warning system is the audiogram. The baseline is the reference; each annual test is compared to it. A Standard Threshold Shift (STS) is an average worsening of 10 dB or more at 2000, 3000, and 4000 Hz in either ear relative to baseline (1910.95(g)(10)(i)). When an STS appears, you refit or reissue hearing protection, retrain the worker, and — if the shift is work-related and reaches the recordability threshold — record it (a recordable hearing loss also needs a total level of 25 dB above audiometric zero; see when a hearing loss is recordable).

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What Annual Training Must Cover (1910.95(k))

Training is annual (1910.95(k)(2)) for every employee in the program, and it must cover three specific topics (1910.95(k)(3)):

• (i) The effects of noise on hearing — how exposure causes permanent, cumulative loss.
• (ii) Hearing protectors — their purpose; the advantages, disadvantages, and attenuation of the various types; and instruction on selection, fitting, use, and care.
• (iii) Audiometric testing — the purpose of the testing and an explanation of the test procedures.

Because the training is annual and content-specific, a generic once-at-hire safety orientation doesn't satisfy it — the three topics have to be delivered every year to everyone in the program, and documented.

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Construction vs. General Industry — An Honest Note

Most of the detailed program above lives in the general-industry standard, 1910.95. Construction has its own, thinner noise rules: a 90 dBA PEL in 1926.52, a hearing-protection requirement in 1926.101, and a duty to administer "a continuing, effective hearing conservation program" wherever sound levels exceed the Table D-2 values (29 CFR 1926.52(d)(1)). What the construction standard does not do is list the program's content: the audiometric testing, annual training, monitoring and 85 dBA action level of 1910.95(c)-(n) were never extended to construction. OSHA's August 4, 1992 letter of interpretation named the elements it expects, including baseline and annual audiometry, and said a program must incorporate as many of them as are feasible. Many contractors nonetheless run a full 1910.95-style program as best practice — it's the defensible standard of care, and some state plans require more than the federal construction minimum. Don't assume "construction" means the noise program is optional. (See the 90 vs 85 dBA myth in construction.)

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Protector Attenuation: Two Targets (1910.95(j))

Handing out earplugs is not enough; the protector has to bring the exposure down far enough. 29 CFR 1910.95(j)(2) requires hearing protectors to attenuate exposure at least to an 8-hour TWA of 90 dBA, and 1910.95(j)(3) tightens that to 85 dBA or below for an employee who has already had a Standard Threshold Shift. Protectors are mandatory, not just available, for anyone above the PEL, for anyone at 85 dBA or more who has not yet had a baseline audiogram, and for anyone at 85 dBA or more who has had an STS (1910.95(i)(2)). The employer evaluates attenuation for the specific noise environment using one of the methods in Appendix B to 1910.95, and re-evaluates when exposure increases.

When a Hearing Loss Goes on the OSHA 300 Log (1904.10)

An STS found in the program is not automatically a recordable injury. Under 29 CFR 1904.10(a), you record the case on the 300 Log when the audiogram shows a work-related STS in one or both ears and the employee's total hearing level is 25 dB or more above audiometric zero, averaged at 2000, 3000 and 4000 Hz, in the same ear. Both conditions have to be met. That is why the baseline audiogram matters twice: it defines the shift for the hearing conservation program, and it anchors the comparison that decides whether the case is recordable. The audiometric record itself stays on file for the duration of the worker's employment (1910.95(m)(3)(ii)), which is what lets a later audiogram be compared with the baseline years afterward.

The standard, tools & related reading

• The standard: Occupational noise — 29 CFR 1910.95 · Construction noise PEL — 1926.52 · Training hub
• On the job: Noise Exposure Calculator · PPE Selector · Training Record
• Related reading: The 90 vs 85 dBA construction noise myth · OSHA safety training requirements

Hearing loss is permanent and preventable — the 85 dBA action level exists because by the time a worker notices, the damage is already done.