The Prevention of Recordable Hearing Loss (Part 2): What is “Work-Relatedness”?

The Prevention of Recordable Hearing Loss (Part 2): What is “Work-Relatedness”?


In our series discussing the prevention of recordable hearing loss cases, our first question is: What does “work-related” mean in OSHA context?

Recordable determination is done on a case-by-case basis and the employer is allowed to seek guidance from a physician or licensed health care-provider. In the case of hearing loss, we use the term “Professional Supervisor” of the audiometric testing portion of the hearing conservation program to describe that health care professional. The Council for Accreditation in Hearing Conservation (CAOHC) offer training and certification for physicians and audiologists as a “Professional Supervisor of the Audiometric Monitoring Program” (PS/A). These are the two professions that are qualified by their credentials to evaluate hearing and hearing loss. For more information, please see
OSHA specifies some situations that are not recordable in the recordkeeping standard.
You are not required to record injuries and illnesses if . . .
At the time of the injury or illness, the employee was present in the work environment as a member of the general public rather than as an employee.
The injury or illness involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure that occurs outside the work environment.
The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, exercise class, racquetball, or baseball.
The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption (whether bought on the employer's premises or brought in). For example, if the employee is injured by choking on a sandwich while in the employer's establishment, the case would not be considered work-related.
Note: If the employee is made ill by ingesting food contaminated by workplace contaminants (such as lead), or gets food poisoning from food supplied by the employer, the case would be considered work-related.
The injury or illness is solely the result of an employee doing personal tasks (unrelated to their employment) at the establishment outside of the employee's assigned working hours.
The injury or illness is solely the result of personal grooming, self medication for a non-work-related condition, or is intentionally self-inflicted.
The injury or illness is caused by a motor vehicle accident and occurs on a company parking lot or company access road while the employee is commuting to or from work.
The illness is the common cold or flu (Note: contagious diseases such as tuberculosis, brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at work).
The illness is a mental illness. Mental illness will not be considered work-related unless the employee voluntarily provides the employer with an opinion from a physician or other licensed health care professional with appropriate training and experience (psychiatrist, psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental illness that is work-related.
 Table of Exceptions from CFR 1904.5. (available at

The prevention of recordable hearing loss is an issue that lies at the center of each and every Hearing Conservation program. In the coming weeks, we’ll continue to share – and discuss – those questions on this topic that we hear the most during our education and training sessions with employers around the U.S. 

Next: Role of a Professional Supervisor

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