Hearing Conservation Program — OSHA 29 CFR 1910.95 Compliant
The written program required at 85 dBA TWA Action Level. Covers noise monitoring, baseline + annual audiometric testing, hearing protector selection, employee training, and STS follow-up.
When this template is required
Required of every general industry employer whose employees' 8-hour TWA noise exposure equals or exceeds 85 dBA (the Action Level). All six program elements — monitoring, audiometric testing, hearing protection, training, recordkeeping, and information access — are mandatory once any employee crosses the Action Level.
Why this template
Triggers at 85 dBA, not 90 dBA
Many employers wrongly believe the program applies only above the 90 dBA PEL. The Action Level (85 dBA TWA) is what triggers the full six-element program — engineering controls are required above the PEL but the program kicks in earlier.
All six required elements pre-built
Monitoring, audiometric testing, hearing protection, training, recordkeeping, and information access. Each element is a separate inspection target — partial compliance gets cited element-by-element.
STS 21-day notification protocol
When an annual audiogram shows a Standard Threshold Shift (10 dB shift at 2/3/4 kHz), the employee must be notified in writing within 21 days. Missing this notification is a routine citation. The template includes the notification letter and follow-up procedure.
Recordkeeping windows built in
Noise exposure records: 2 years. Audiometric records: duration of employment. The template captures both with the appropriate retention schedules.
What you receive
- Hearing Conservation Program (Word .docx) — all six required elements
- Noise monitoring procedure and Personal Dosimetry log
- Audiometric testing program (baseline + annual schedule)
- Standard Threshold Shift (STS) follow-up procedure (21-day notification)
- Hearing Protector Device (HPD) selection matrix (foam, banded, custom, electronic)
- Employee training outline with annual refresher requirement
- Recordkeeping log (2-year noise records, employment-duration audiograms)
- Workplace noise hazard map template (high-noise area posting)
How you get it
This document is written and reviewed against the standard it cites, and it is ready now. The download link is emailed as soon as your payment clears.
Revisions included — if something about your operation changes what the document should say, reply to the delivery email and we will amend it.
Who buys this
- Manufacturing facilities (stamping, machining, fabrication)
- Construction (covered under 1926.52 with HCP as best practice)
- Utilities (power generation, substations)
- Mining and aggregate operations
- Airport ground crews and aviation maintenance
- Agriculture (tractors, equipment, grain handling)
Frequently asked
When does OSHA require a hearing conservation program?
At any time an employee's noise exposure equals or exceeds an 8-hour TWA of 85 dBA — the Action Level under 29 CFR 1910.95(c)(1). This is lower than the 90 dBA PEL. Once any single employee crosses 85 dBA TWA, the full six-element program is required for that employee and all similarly-exposed workers.
What's the difference between the Action Level and the PEL?
Action Level = 85 dBA TWA. Triggers the hearing conservation program (monitoring, audiometric testing, HPDs offered, training). PEL = 90 dBA TWA. Triggers mandatory engineering or administrative controls to reduce exposure, plus mandatory HPD use. Most workplaces with hearing hazards trigger the Action Level long before they trigger the PEL.
How often do employees need audiometric testing?
Baseline audiogram within 6 months of first exposure at or above the Action Level (or within 12 months if using a mobile test van, with interim HPD use). Annual audiograms thereafter for the duration of exposure. The audiograms must be done by a licensed audiologist, otolaryngologist, other physician, or CAOHC-certified technician under medical supervision.
What is a Standard Threshold Shift (STS)?
An average shift of 10 dB or more at the test frequencies of 2000, 3000, and 4000 Hz in either ear, compared to the baseline audiogram (age-correction is allowed). When an STS occurs, OSHA 1910.95(g)(8) requires written notification to the employee within 21 days, refitting and retraining on hearing protection, and re-evaluation of the HCP for that employee.
Does this cover construction noise (1926.52)?
29 CFR 1926.52 (the construction noise standard) is structurally similar to 1910.95 but doesn't explicitly mandate a written hearing conservation program. In practice, OSHA enforces the equivalent of an HCP via the General Duty Clause when construction noise exceeds 85 dBA. The template works for construction with minor adjustment — the audiometric testing requirement is less explicit but recommended.