Hearing Conservation Programs: Workplace Requirements and Testing

Every year, 22 million American workers are exposed to dangerous noise levels on the job. That’s not just a statistic-it’s 22 million people at risk of losing their hearing permanently, often without ever realizing it until it’s too late. Noise-induced hearing loss (NIHL) doesn’t happen overnight. It creeps in slowly, over months or years, masking itself as background hum or tired ears at the end of a shift. By the time workers notice the problem-struggling to hear conversations in noisy rooms, turning up the TV too loud-it’s usually permanent. The good news? This kind of hearing loss is almost entirely preventable. And the law says so.

What a Hearing Conservation Program Actually Is

A Hearing Conservation Program (HCP) isn’t just a policy on a wall or a yearly training video you half-watch. It’s a legally required system designed to stop noise from stealing your hearing. Under OSHA’s 29 CFR 1910.95 regulation, any workplace where employees are exposed to noise at or above an 8-hour average of 85 decibels (dBA) must have a full HCP in place. That’s the action level. It’s not the limit-it’s the trigger. Once you hit 85 dBA, the program kicks in. No exceptions.

This isn’t about being extra careful. It’s about following federal law. And the consequences of skipping it are serious. OSHA issued over 1,800 citations for HCP violations in 2022 alone, with fines ranging from $15,625 to nearly $160,000 per violation. More than that, workplaces without proper programs see higher absenteeism and lower productivity. Workers with untreated hearing loss are more likely to miss work, make mistakes, or get injured because they can’t hear alarms, warnings, or instructions.

The Five Core Components You Can’t Skip

A legal HCP has five non-negotiable parts. Missing even one means you’re not compliant-and you’re putting workers at risk.

1. Noise Monitoring: You can’t protect what you don’t measure. Employers must use calibrated sound level meters or noise dosimeters to identify areas where noise hits or exceeds 85 dBA. This isn’t a one-time check. Every time you change equipment, add machinery, or reconfigure a workspace, you need to retest. A new grinder, a louder fan, or even rearranging workstations can push noise levels over the limit.
2. Audiometric Testing: This is the early warning system. Every employee exposed to 85 dBA or higher must get a baseline audiogram within six months of starting their exposure. The test must happen after at least 14 hours without workplace noise-no loud concerts, power tools, or even headphones the night before. After that, annual tests are mandatory. The frequencies tested? At least 500, 1000, 2000, and 3000 Hz. But by 2025, new rules are expected to require 4000 and 6000 Hz too, because that’s where early hearing loss shows up first.
3. Hearing Protection: If noise is too loud, you give workers protection. But it’s not enough to hand out earplugs and call it done. Employers must provide a variety of options-earmuffs, foam plugs, custom-molded plugs-and train workers on how to use them correctly. A poorly fitted earplug can reduce protection by 90%. That’s why fit testing is becoming more common. And the protection must bring exposure down to at least 90 dBA. Not 95. Not 92. 90.
4. Training: Annual training isn’t optional. It has to cover: how noise damages hearing, why hearing protectors matter, how to use them properly, and what the audiometric tests are for. Workers need to understand that this isn’t just a safety checkbox-it’s about keeping their ability to hear their kids, their favorite music, or even a conversation with a friend.
5. Recordkeeping: You must keep noise exposure records for at least two years. Audiometric test results? Those must be kept for the entire time the employee works there. If they leave, you still have to store them. These records aren’t just for OSHA inspections-they’re your defense if a worker later claims their hearing loss was work-related.

What Happens When Hearing Loss Is Detected

The goal of annual audiograms isn’t just to track hearing over time-it’s to catch a Standard Threshold Shift (STS). An STS means a worker’s hearing has worsened by 10 dB or more, averaged across 2000, 3000, and 4000 Hz, compared to their baseline. When that happens, you have 30 days to act.

First, you must notify the employee in writing within 21 days. No phone call. No email alone. A formal letter. Then, you must retrain them on hearing protection, refit their earplugs or earmuffs, and offer a higher-rated protector if needed. If the shift is significant or there’s reason to suspect a medical issue-like an ear infection or a tumor-you must refer them for a clinical audiological evaluation. This isn’t optional. It’s a medical red flag.

And here’s something many employers miss: the baseline audiogram can be revised. If an STS is confirmed to be permanent and persistent, you can update the baseline to reflect the new level. That way, you’re not constantly flagging the same shift year after year. But you can’t do this without a professional supervisor of audiometry signing off.

Why Most Programs Fail

OSHA’s data shows that 62% of violations are tied to audiometric testing problems. That’s the biggest failure point. Why? Because testing is messy. Workers don’t show up. They skip the 14-hour quiet period. The testing room isn’t soundproof. The audiometer isn’t calibrated. The results aren’t reviewed by a qualified professional.

Another big issue? Training. 28% of violations come from inadequate training. Workers get handed earplugs like candy. They’re told, “Just wear these.” But they don’t know how to roll them properly, how to check the seal, or why it matters. A 2023 SHRM survey found that 68% of safety managers struggle with employee participation in testing. People don’t see the point. They think, “I can still hear fine.”

Small businesses suffer the most. With fewer than 50 employees, 37% are non-compliant. Why? Cost. A full HCP runs $250-$400 per employee a year. Audiometric testing makes up nearly half of that. But here’s the truth: the cost of not doing it is higher. Lost productivity, workers’ compensation claims, OSHA fines, and lawsuits add up fast. Mobile audiometric units-used by 73% of compliant companies-cut employee downtime by 60%. That’s not an expense. It’s an investment.

What’s Changing in 2025

OSHA is updating the rules. The proposed changes, expected to be finalized in late 2024, will make HCPs stricter. Here’s what’s coming:

• Audiometers must meet ANSI S3.6-2018 standards, not the outdated 1969 version.
• Testing must include 4000 Hz and 6000 Hz frequencies to catch early damage.
• Hearing protectors must be chosen based on actual noise levels-not just to bring exposure down to 90 dBA. If you’re exposed to 100 dBA, your protector must do more than just hit 90. It must be matched to the level.

These changes will raise costs by 8-12%. But experts say they’ll prevent 150,000 more cases of hearing loss every year. That’s the goal: not just compliance, but real protection.

What You Should Do Now

If you’re an employer:

• Test your noise levels. Don’t guess. Use a calibrated meter.
• Identify everyone exposed to 85 dBA or higher.
• Get baseline audiograms for them-within six months, with 14 hours of quiet.
• Offer real choices in hearing protection. Let workers pick what works.
• Train them every year. Make it meaningful, not a PowerPoint slideshow.
• Keep records. Always.
• Act fast if an STS shows up. Don’t wait.

If you’re a worker:

• Ask if your workplace has a Hearing Conservation Program.
• Make sure you’re getting your annual hearing test.
• Wear your protection correctly. If you can’t hear your own voice through the earplug, you’re doing it right.
• Report if your earplugs are uncomfortable or don’t fit. You deserve better.
• Don’t ignore ringing in your ears after a shift. That’s your body warning you.

Hearing loss is silent. But the program to stop it isn’t. It’s loud, clear, and legally required. And it works-when it’s done right. Don’t wait for the damage to show up. Protect your hearing before it’s too late.