OSHA Hearing Loss Recordability: When a Standard Threshold Shift Goes on the Log
Record hearing loss when an audiogram shows a work-related 10 dB Standard Threshold Shift and a total hearing level of 25 dB or more in the same ear.
The short answer
Record hearing loss when an audiogram shows a work-related 10 dB Standard Threshold Shift and a total hearing level of 25 dB or more in the same ear. Both figures are averaged at 2,000, 3,000, and 4,000 Hz, and you may age-adjust for the shift but not for the 25 dB test.
Hearing cases often arrive from annual testing rather than a single incident.
The rule in plain English
A case goes on the OSHA 300 Log when three things are true: it is work-related (29 CFR 1904.5), it is a new case (29 CFR 1904.6), and it meets at least one general recording criterion (29 CFR 1904.7). The criteria are death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional (cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum). Special rules add needlesticks, medical removal, hearing loss, and tuberculosis (29 CFR 1904.8 to 1904.11).
The 1904.10 test, step by step
- Compare the current audiogram with the baseline, or with the revised baseline if the employee already had a recorded hearing loss case.
- Standard Threshold Shift: an average change of 10 dB or more at 2,000, 3,000, and 4,000 Hz in either ear. You may age-adjust for this step using Appendix F of 29 CFR 1910.95.
- 25 dB level: the employee's current average hearing level at those frequencies is 25 dB or more above audiometric zero in the same ear. No age adjustment here.
- Optional retest: if a retest within 30 days does not confirm the shift, do not record. If it does, record within 7 calendar days of the retest.
- Work-relatedness: decided under 1904.5. If a physician or other licensed health care professional determines the loss is not work-related, it is not recorded.
- On the log: check the hearing loss column.
How it plays out on site
Apply OSHA hearing loss criteria and keep audiogram support with the case file. Recordability answers change as medical facts arrive, so a case decided on day one without notes is hard to defend in January. The fix is to decide in order (work-relatedness, new case, criteria) and to write down the treatment and work-status facts each decision rests on, including medication strength.
Industrial hygienists bring the exposure data that decides work-relatedness in illness cases, so keep sampling results and exposure history linked to the case.
The common mistake
Teams miss baseline revisions or work-relatedness analysis.
Each recordable case adds to the 300A totals and the TRIR; days-away and restricted cases also count toward DART. For establishments with 100 or more employees in Appendix B industries, each case also becomes a row in the ITA case data.
Edge cases
- Retesting and physician review can change the final decision.
- A recommendation counts even if the employee declines it: prescription medication that is prescribed but never filled still makes the case recordable.
Worked example
An annual audiogram shows a 12 dB average shift in the left ear, but the employee's total hearing level there is 22 dB. Only one of the two tests is met, so the case is not recorded. A year later the shift persists and the level reaches 26 dB; now both are met, and the case is recorded in the hearing loss column.
Checklist
- Collect the current and baseline audiograms.
- Test for the shift and the 25 dB level.
- Retest within 30 days if you want to confirm.
- Decide work-relatedness.
- Record within 7 days and check the hearing loss column.
What to keep in the case file:
- What the provider recommended, in writing if possible, including medication strength
- Work status notes (full duty, restrictions, or days away) with dates
- The work-relatedness basis and any exception considered
- The date you learned of the case and the date it became recordable
Where 300log helps
300log records each case's outcome, day counts, and case type in the columns the OSHA 300 Log uses, shows OSHA's definitions (such as restricted work) while you classify, and recalculates the 300A whenever a case changes.
For a quick answer without an account, use the free recordability checker.
Frequently asked questions
Who decides recordability, the doctor or the employer?
The employer. Providers supply the medical facts and recommendations; the employer applies Part 1904 to those facts and records the case.
What if the facts change after we log the case?
Update the log. If a first-aid case later needs medical treatment, or a recordable case later results in days away, change the entry (29 CFR 1904.33(b)).
Is a clinic visit automatically recordable?
No. A visit for observation, counseling, or diagnostic tests is not medical treatment. The case is recordable only if a recording criterion is met, such as treatment beyond first aid or a work restriction.
Is prescription medication always recordable?
A recommendation to use prescription medication, or a nonprescription drug at prescription strength, is medical treatment. The exception is medication used solely for diagnosis, such as eye drops to dilate pupils.
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.10: Recording criteria for occupational hearing lossOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]29 CFR 1904.7: General recording criteriaOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA detailed guidance for the injury and illness recordkeeping ruleOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.