Hearing Conservation Programs: Workplace Requirements and Testing Explained

Every year, millions of workers lose their hearing-not from aging, not from music, but from noise they’re exposed to every day on the job. In the U.S., hearing conservation programs are the law, not just a best practice. If your workplace hits 85 decibels over an 8-hour shift, you’re legally required to have a plan in place to protect your ears. And yet, nearly two out of three companies still get it wrong.

Why Hearing Conservation Isn’t Optional

Noise-induced hearing loss (NIHL) is permanent. Once the hair cells in your inner ear are damaged, they don’t grow back. Unlike a sprained ankle or a cut, you can’t heal from it. And it doesn’t happen overnight. It creeps up slowly, often unnoticed until it’s too late. By the time someone realizes they’re missing conversations or turning the TV up too loud, the damage is done.

The science is clear: 22 million American workers are exposed to dangerous noise levels every year. That’s one in seven people in the workforce. And while many think earplugs are enough, the real solution is a full hearing conservation program-not just gear, but structure, testing, and accountability.

The Five Legal Requirements of a Hearing Conservation Program

OSHA’s 29 CFR 1910.95 spells out exactly what’s needed. There’s no wiggle room. If you’re above 85 dBA over an 8-hour shift, you must have all five components:

• Noise monitoring-You can’t protect what you don’t measure. Employers must use calibrated noise dosimeters or sound level meters to map out which areas, machines, or tasks push workers over the action level. This isn’t a one-time check. Anytime you change equipment, add a new line, or reconfigure a workspace, you must retest.
• Audiometric testing-This is the heartbeat of the program. Every employee exposed to 85 dBA or higher must get a baseline hearing test within six months of starting the job. They must be out of noise for at least 14 hours before the test. After that, annual tests are mandatory. The test must include frequencies at 500, 1000, 2000, 3000, and 4000 Hz, conducted in a room that meets strict soundproofing standards. The audiometer must be calibrated to ANSI S3.6-2018, not the outdated 1969 version.
• Hearing protection-Earplugs and earmuffs aren’t optional extras. Employers must provide at least two types of protectors and let workers choose. They must also train employees on how to insert earplugs correctly-most people get it wrong. The goal isn’t just to hand out gear; it’s to make sure it actually works. Protection must reduce exposure to 90 dBA or lower.
• Training-Annual training isn’t a checkbox. It needs to explain how noise damages hearing, how protectors work, why testing matters, and what to do if you notice a change in your hearing. Workers who understand the risk are far more likely to use protection consistently.
• Recordkeeping-You must keep noise exposure records for at least two years. Audiometric test results? Those stay with the employee’s file for as long as they work there. If OSHA shows up, you need to produce them-fast.

What Happens When Hearing Loss Is Detected?

The real test of a program isn’t whether it runs-it’s what happens when it finds a problem. If an employee’s hearing shifts by 10 dB or more at 2000, 3000, and 4000 Hz compared to their baseline, that’s called a Standard Threshold Shift (STS). It’s a red flag.

When an STS is found, the employer has 30 days to act:

• Notify the employee in writing within 21 days.
• Re-fit and retrain them on hearing protection.
• Offer a protector with higher noise reduction if needed.
• Refer them for a clinical audiological exam if there’s any suspicion of medical issues like ear infections or tumors.

And here’s something most people don’t know: the baseline audiogram can be updated if the shift is confirmed as permanent. That prevents the same person from being flagged year after year for the same loss. But you can’t reset it just to avoid reporting.

The Hidden Costs of Ignoring Hearing Conservation

Some employers think HCPs are expensive. They’re right-but the cost of not having one is worse.

A full program runs $250-$400 per employee per year. Audiometric testing makes up nearly half that cost. But companies with strong programs see 5-10% higher productivity and 15-20% fewer absences. Why? Because workers aren’t struggling to hear instructions, aren’t miscommunicating on the floor, and aren’t dealing with the stress of tinnitus or social isolation from hearing loss.

The financial risk is real too. OSHA issued 1,842 citations for hearing conservation violations in 2022. Penalties range from $15,625 to over $150,000 per violation. And it’s not just big factories. Small businesses with under 50 employees have a 37% non-compliance rate-nearly double that of larger firms.

Why Most Programs Fail

The biggest problem isn’t the law-it’s execution. A 2023 SHRM survey of 1,200 safety managers found:

• 68% struggle with employee participation in audiometric testing. People skip appointments. They think, “I’m fine.” But hearing loss doesn’t announce itself.
• 52% can’t get workers to fit hearing protection properly. A poorly inserted earplug can cut protection by 75%.
• 47% have trouble keeping accurate exposure records. Spreadsheets get lost. Data isn’t updated after equipment changes.

The most successful programs use mobile audiometric testing units. These vans come to the site, reducing downtime by 60%. Workers get tested during their shift, no travel, no excuses. And when you make it easy, participation jumps.

What’s Changing in 2025?

OSHA is updating its standards. The proposed rule, expected to be finalized in late 2024, includes:

• Requiring the latest ANSI S3.6-2018 audiometer calibration standard (replacing the 1969 version).
• Adding 6000 Hz to the required test frequencies-this catches early high-frequency hearing loss before it spreads.
• Requiring protectors that reduce exposure below 90 dBA when noise hits 100 dBA or higher. Right now, 90 dBA is the limit. That’s not enough.

These changes will raise costs by 8-12%, but experts say they could prevent 150,000 new cases of hearing loss each year.

What You Should Do Now

If you’re an employer:

• Test your noise levels. Don’t guess. Use a calibrated dosimeter.
• Set up annual audiometric testing with a certified provider.
• Offer real choices in hearing protection-not just the cheapest option.
• Train employees every year, not just once.
• Track every test result and exposure reading.

If you’re an employee:

• Take your hearing tests seriously. Show up. Don’t skip them.
• Ask for help fitting your earplugs. Most people do it wrong.
• Speak up if you notice ringing in your ears or trouble hearing in meetings.
• Know your rights. You’re not asking for a favor-you’re enforcing the law.

Final Thought

Hearing is one of the senses you can’t replace. You can get a new hip. You can fix a bad knee. But once your hearing is gone, it’s gone for good. A good hearing conservation program isn’t about avoiding fines. It’s about keeping people connected-to their families, their jobs, their lives.