Hearing Loss

Continuing our discussion of the prevention of recordable hearing loss, today's question is: What information can help the professional supervisor make a determination regarding work-relatedness?


The National Hearing Conservation Association has recently published “NHCA Guidelines for Recording Hearing Loss on the OSHA 300 Log.” These guidelines provide general principles for Professional Supervisors. The primary principle is that Professional Supervisors must be able to substantiate their determinations and therefore, “unless there are clear and cogent reasons why the loss is entirely unrelated to the work environment” it should be considered work related and thus recordable.


Pitfalls in work-relatedness determinations

  • Ascribing hearing loss to non-occupational exposures without adequate documentation. Be very careful not to jump to conclusions. The burden of proof is on the PS/A and thus the employer to show that occupational exposure DID NOT contribute and that non-occupational factors are sufficient to cause the ENTIRE hearing loss. The PS/A has both ethical and medical-legal obligation to get the diagnosis right.
  • Assuming a given decrease in exposure due to use of HPD. You must measure this to be able to confidently assume protection. This can be measured by point measurement with earplug fit-testing or with continuous monitoring of protected exposure levels. 
  • Bending to pressure to reduce recordable cases. PS/As must follow legal and ethical standards as they use their professional judgment. Both physicians and audiologists are held to ethics codes in order to maintain their license to practice. 
  • Missing a diagnosis of other cause of hearing loss. This brings up the issue of who pays for the evaluation of hearing loss cases. While OSHA does not require the employer to pay, it may be in the employer’s best interest to pay for initial evaluation of the hearing loss. If the follow-up evaluation does not take place, the , the hearing loss is presumed to be recordable.


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 www.caohc.org
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 www.OSHA.org)

In the United States, when an employee is found to have a Standard Threshold Shift (STS) on the annual audiogram as part of an occupational hearing conservation program, certain evaluation and follow-up actions are required. 


  • A repeat audiogram is allowed to determine if the STS is still present but must be completed within 30 days. 
  • If the STS is confirmed or if no retest is completed, and the decrease in hearing results in hearing levels that are consistent with at least a mild hearing loss (25 dB average hearing level), the STS must be recorded on the Occupational Safety and Health Administration (OSHA) Illness and Injury Log (OSHA 300 Log). 


These “recordable” hearing loss cases have received some attention since the new rules for recordable hearing loss went into effect in January 2003. Prior to that, hearing loss was lumped in with “Other” illnesses, but now under the revised record keeping Final Rule, hearing loss cases are recorded in a separate column.


In an Oct 2009 Government Accountability Office (GAO) report on “Workplace Safety and Health,” auditors noted that there was pressure on physicians and health care professionals to determine hearing loss as not work-related. The OSHA “Occupational Injury and Illness Recording and Reporting Requirements – Final Rule” states that although work-relatedness is not presumed, the determination of work-relatedness is on a case-by-case basis. So let’s look at some of the issues of recordable hearing loss and decision points that affect the recordability of a hearing loss.




If anything, hearing and communication are critical in any workplace. Our ability to hear -- and hear without impedance -- connects us to others and our environments, and has a significant impact on our quality of life both at work and at home. 


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