Hearing test recording rules: 4 numbers to check

• in California, a Standard Threshold Shift is an average change of 10 dB or more at 2000, 3000 and 4000 Hz, according to California Department of Industrial Relations in its definition.
• in California, you may not use an age adjustment for the total hearing level test at 25 dB or more above audiometric zero, according to California Department of Industrial Relations in its recording criteria.
• in California, if you retest within 30 days of the first test and the retest does not confirm the recordable STS, you are not required to record the case, according to California Department of Industrial Relations in its retest provision.
• in California, if the retest confirms the recordable STS, you must record the hearing loss illness within seven (7) calendar days of the retest, according to California Department of Industrial Relations for that deadline.

Hearing test results may reach the owner or the team lead before anyone decides whether they belong on a record. At that point the reader has an audiogram, a test date and a state rule to apply, and those items are the starting point. This guide keeps to the numbers in the state rules quoted here, so the decision begins with the numbers rather than with memory.

The sources in this guide come from California, Washington and Minnesota. For the wider noise program, see Protect your team with 5 noise safety program items.

Your first step is to pull the baseline audiogram for the tech and the most recent audiogram. The California definition is measured against the baseline audiogram for that employee, according to California Department of Industrial Relations. That reference point is the one to name in the file.

10 dB average threshold shift

California's wording reads: "A Standard Threshold Shift, or STS, is defined in the occupational noise exposure standard at section 5097(d)(8) as a change in hearing threshold, relative to the baseline audiogram for that employee, of an average of 10 decibels (dB) or more at 2000, 3000, and 4000 hertz (Hz) in one or both ears." That statement, according to California Department of Industrial Relations, measures the change against the baseline audiogram for that employee.

Washington's wording reads: "If the average threshold shift at 2000, 3000, and 4000 Hz from the original baseline or previously recorded audiogram to the current age adjusted audiogram is less than 10 dB, the hearing loss case is not required to be recorded." That statement, according to Washington State Legislature, compares the current age adjusted audiogram with an earlier audiogram. Your file should say which starting point you used, since the Washington wording names the original baseline or previously recorded audiogram.

The California definition describes the shift as an average at 2000, 3000, and 4000 Hz, according to California Department of Industrial Relations, so the figure in the file should be that average rather than a single reading at one frequency. Your file should also say whether the change was in one ear or both ears, since the definition speaks of a change in one or both ears.

Two different phrasings

Washington's wording reads: "It is not required to record an STS when the average threshold level for the employee's current audiogram at 2000 Hz, 3000 Hz, and 4000 Hz average less than 25 dB." That statement, according to Washington State Legislature, points to the current audiogram rather than an older one. You can take the current audiogram average at 2000, 3000 and 4000 Hz and check it against 25 dB.

California's wording reads: "You may not use an age adjustment when determining whether the employee's total hearing level is 25 dB or more above audiometric zero." That statement, according to California Department of Industrial Relations, covers the total hearing level test.

A borderline result is a question for whoever reviewed the audiogram, because this guide does not interpret individual audiograms.

Washington's wording uses the phrase average threshold level, according to Washington State Legislature, while California's wording uses total hearing level above audiometric zero, according to California Department of Industrial Relations. Those are different phrases in two different state sources, so each 25 dB figure should be read with the phrase used by its own source.

The Washington wording takes the average from the employee's current audiogram at 2000, 3000 and 4000 Hz, according to Washington State Legislature, so the current audiogram is the starting record for that check. Your file can label each audiogram as current or earlier, so a later reader sees which one the check used.

The 25 dB figure appears in the Washington wording, according to Washington State Legislature, and in the California wording, according to California Department of Industrial Relations, so each result can be read against the wording of its own source.

30 days from the first test

California's wording reads: "No, if you retest the employee's hearing within 30 days of the first test, and the retest does not confirm the recordable STS, you are not required to record the hearing loss case on the Cal/OSHA 300 Log." That statement, according to California Department of Industrial Relations, sets the 30-day window from the first test. You can note the first test date and the retest date in your file, so the window can be checked.

Washington's wording reads: "(4) The employer is not required to record the hearing loss case on the OSHA 300 Log if they retest the employee's hearing within thirty days of the first test, and the retest does not confirm the STS." That statement, according to Washington State Legislature, uses a thirty-day window measured from the first test. Your file can keep the retest result beside the first result, so both results sit on one line.

If a retest is scheduled after the window has passed, check the state's wording before you decide anything, because this guide relies on the wording quoted in this section. A late retest is a question for the state source, not a guess. You can write the decision date beside the test dates, so the record shows when the decision was made.

The California wording pairs a retest within 30 days with a retest that does not confirm the recordable STS, according to California Department of Industrial Relations, as the condition for the case not being required on the Cal/OSHA 300 Log.

Your file can record the retest result itself, not only the retest date, because both quoted sources tie the rule to whether the retest confirms the shift. Your team can pick a retest date inside the window at the time of the first test, which is an editorial suggestion rather than a quoted rule.

Seven calendar days after the retest

California's wording reads: "If the retest confirms the recordable STS, you must record the hearing loss illness within seven (7) calendar days of the retest." That statement, according to California Department of Industrial Relations, ties the deadline to the retest. Mark the retest date on the record, and confirm with the California source how the first day is counted.

You should check your own state's wording before using this deadline in another state, because the figure quoted here applies to California's rule. A deadline from one state's source does not decide what another state requires. You can add a note on the record that names the rule the deadline came from, so the source is easy to find.

The seven-day deadline applies when the retest confirms the recordable STS, according to California Department of Industrial Relations.

Your team can add a calendar entry for the deadline when the retest is booked. For the entry itself, see Job injury log entry within 7 calendar days.

Suppose a tech's current audiogram averages 10 dB worse than the baseline audiogram at 2000, 3000 and 4000 Hz. That change meets the 10 dB number, so the case needs a closer look. Imagine a retest 25 days after the first test that does not confirm the shift. Under the California wording quoted above, the case is not required to be recorded on the Cal/OSHA 300 Log. Had the retest confirmed the recordable STS, the seven-day deadline in that wording would apply. This example is illustrative only, so check the state wording before you decide.

Minnesota's wording reads: "Under the standard, employers must use OSHA Form 300, Log of Work-related Injuries and Illnesses, and Form 300A, Summary of Work-related Injuries and Illnesses." That statement, according to Minnesota Department of Labor and Industry, describes the Minnesota standard, so it is not a rule for every firm.

If your firm falls under the Minnesota standard, use the forms it names when you prepare the log. If you work under another state's rules, check the form that state names.

California's wording names the Cal/OSHA 300 Log, according to California Department of Industrial Relations, in the sentence that sets the 30-day retest rule.

Washington's wording refers to the OSHA 300 Log for the hearing loss case, according to Washington State Legislature, so the log line and the retest note can be kept for the same employee. For a checklist before you enter a case, see OSHA 300 log: 7 checks before recording injuries.

You can keep audiogram copies, test dates and retest notes in one folder, so the results sit side by side. Your folder can also hold a copy of each state's wording beside its audiogram, so a later reader sees which source each entry followed.

The table below sets out the quoted wording for each source named in this guide.

• lockout checks before equipment is opened
• head protection rules before dispatch

Your next step today is to check your last hearing test results against the 10 dB and 25 dB numbers and note any retest date. You can keep the state wording open beside each result while you do this, so each figure stays tied to its source.

What is a Standard Threshold Shift?

California's source describes a Standard Threshold Shift as a change in hearing threshold, relative to the baseline audiogram for that employee, of an average of 10 dB or more at 2000, 3000, and 4000 Hz in one or both ears, according to California Department of Industrial Relations. Use the definition from the state whose rule applies.

Can I age adjust the 25 dB level?

California's wording says you may not use an age adjustment when determining whether the employee's total hearing level is 25 dB or more above audiometric zero, according to California Department of Industrial Relations. Washington's wording for the 25 dB level refers to the current audiogram average at 2000, 3000, and 4000 Hz, according to Washington State Legislature. The two answers stay separate, because each comes from a different state source. Your entry can note whether an age adjustment was used, so a later reader can see that choice.

How long do I have to retest a tech's hearing?

California's wording says that if you retest within 30 days of the first test and the retest does not confirm the recordable STS, you are not required to record the hearing loss case on the Cal/OSHA 300 Log, according to California Department of Industrial Relations. Washington's wording covers a retest within thirty days of the first test, according to Washington State Legislature. The window quoted here comes from the California and Washington sources, so check your own state's rule before you schedule a retest.

How soon must I record a confirmed shift in California?

If the retest confirms the recordable STS, California's wording says you must record the hearing loss illness within seven (7) calendar days of the retest, according to California Department of Industrial Relations. Confirm with that source how the first day is counted. You can use this deadline for California records and check the rule for any other state. The seven-day date can be marked on the file when the retest is booked.

Is a shift under 10 dB recordable?

Washington's wording says the hearing loss case is not required to be recorded when the average threshold shift is less than 10 dB, according to Washington State Legislature. California's definition uses an average of 10 dB or more at 2000, 3000, and 4000 Hz, according to California Department of Industrial Relations, and is read on its own terms.

What form does an employer use for the log?

Minnesota's wording says that, under the standard, employers must use OSHA Form 300, Log of Work-related Injuries and Illnesses, and Form 300A, Summary of Work-related Injuries and Illnesses, according to Minnesota Department of Labor and Industry. That wording describes the Minnesota standard, so it is not a rule for every firm. Your folder can hold a copy of the form beside the audiogram records.