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OSHA Hearing Conservation
Program Annual Checklist
Complete all 6 required 1910.95 program elements. Check off each item, see your compliance score in real time, and identify gaps before an OSHA inspection does.
29 CFR 1910.95 compliance
6 required elements
~10 minutes to complete
No form. No email required.
Is Your Program Fully Compliant?
OSHA 1910.95 requires six distinct program elements for any employer with workers exposed at or above 85 dBA TWA. Each element is separately citable — an otherwise solid program with one gap is still fully exposed on that item. This checklist covers every OSHA-required item across all six elements so you can identify gaps before an inspector does.
What this checklist covers
- Noise monitoring documentation and re-monitoring triggers
- Baseline and annual audiogram compliance
- STS detection, notification, and follow-up workflows
- Hearing protection selection, enforcement, and derating
- Annual training content and recordkeeping
- Audiometric record retention and employee access rights
OSHA 1910.95 program completeness audit — 6 elements, 30 checkpoints
Each unchecked item is a potential citation. Every item checked but not documented is the same as not checked — OSHA inspectors ask for records, not verbal confirmation.
Program status
Complete the checklist above to see your program status and recommended actions.
Quick Reference: 1910.95 Requirements by Element
Key thresholds and deadlines for each program element under 29 CFR 1910.95.
| Element | Key Threshold / Trigger | Deadline | Retention |
|---|
| Noise monitoring | 85 dBA TWA action level; 90 dBA PEL | Before enrollment; re-monitor on process change | 2 years |
| Baseline audiogram | First exposure at or above 85 dBA TWA | Within 6 months (12 months if mobile van) | Duration of employment |
| Annual audiogram | All enrolled workers | Every 12 months from last audiogram | Duration of employment |
| STS detection & response | 10 dB average shift at 2k/3k/4k Hz either ear | Notify within 21 days; retest within 30 days | Duration of employment |
| Hearing protection | Mandatory at 90 dBA PEL; offered at 85 dBA AL | Provide at no cost before first exposure | Issuance log retained |
| Annual training | All enrolled workers | Within 1 year of enrollment; annually thereafter | Best practice: 3+ years |
| Recordkeeping & access | All audiometric and noise records | Records available within 15 working days of request | 2 yrs noise / employment duration audiograms |
Ready to automate all 6 elements?
Stop managing compliance manually.
Soundtrace does it for you.
Automated audiometric testing, noise monitoring, HPD fit testing, STS detection, 21-day notification tracking, and 30-year cloud recordkeeping — supervised by a licensed audiologist. All six 1910.95 elements in one platform.
No CAOHC certification required for operators
Per-audiogram ambient noise validation
Licensed audiologist oversight included
Frequently Asked Questions
What does OSHA require for a hearing conservation program?
OSHA 29 CFR 1910.95 requires six elements for any employer with workers exposed at or above 85 dBA TWA: noise monitoring, audiometric testing (baseline and annual), hearing protection devices at no cost, annual employee training, recordkeeping, and employee access to information and records. Each element is separately citable — partial compliance is still citation exposure on the missing element.
When is an OSHA hearing conservation program required?
A full six-element program is required when any employee's noise exposure equals or exceeds 85 dBA as an 8-hour TWA — the action level. The PEL is 90 dBA TWA, above which engineering and administrative controls are also required. Many employers incorrectly believe the program starts at 90 dBA. It starts at 85 dBA.
How often does this checklist need to be completed?
Industry best practice is to complete a full program review annually — before any mobile van visits, before high-inspection-risk periods, or whenever there are changes to production processes, equipment, or personnel. Completing this checklist and documenting the results supports good faith credit if an inspection occurs.
What happens if gaps are found?
Each gap is a separately citable violation with penalties up to $16,131 per serious violation in 2026, or up to $161,323 for willful or repeat violations. Having a documented review process and taking corrective action demonstrates good faith and can reduce penalties by up to 25%. See:
OSHA Hearing Conservation Violations: Penalties & Citations.
Does an employer need a certified audiologist to administer audiometric testing?
Not necessarily. Under 1910.95(g)(3), microprocessor audiometer operators are not required to hold CAOHC certification — they must demonstrate competence as defined by the Professional Supervisor. A licensed audiologist or physician must review audiograms and make STS determinations, but the testing itself can be conducted by trained, competent personnel. Oregon, Washington, and Texas have state-level requirements that may differ.
