OSHA’s hearing conservation standard, 29 CFR 1910.95, requires employers to run a hearing conservation program whenever employee noise exposure reaches an 8-hour time-weighted average of 85 decibels (dBA) — the action level. That program has five moving parts: noise monitoring, audiometric testing at no cost to the worker, employer-provided hearing protection, annual training, and recordkeeping.
For manufacturing plants, foundries, and any industrial employer with loud equipment, the program is not optional paperwork — it is what stands between your workers and permanent, preventable hearing loss, and what an OSHA inspector will ask to see first.
What Does OSHA Hearing Conservation Standard 1910.95 Require?
Under 29 CFR 1910.95, two numbers drive everything. The permissible exposure limit (PEL) is a 90 dBA 8-hour time-weighted average. The action level — the trigger for the full hearing conservation program — is lower, at an 85 dBA 8-hour TWA, calculated with a 5-decibel exchange rate. Once a worker’s exposure hits that 85 dBA action level, the employer owes the whole program, not just earplugs.
A compliant hearing conservation program includes noise monitoring to identify who is at or above the action level, audiometric (hearing) testing at no cost, employer-provided hearing protectors with a choice of at least one type of plug and one type of muff, annual training, and records. Most industrial employers fold hearing conservation into a broader plant safety program alongside lockout/tagout and machine safety — our overview of manufacturing safety compliance training requirements lays out how these standards stack. A plain-language occupational noise and hearing conservation course is the usual starting point for covered employees.
What Is the 85 dBA Action Level and Who Gets Enrolled?
The 85 dBA action level is measured as an 8-hour time-weighted average — a blend of loud and quiet periods across the shift, not a single peak reading. A stamping line that runs at 92 dBA for part of the shift and drops to 70 dBA the rest can still average out above 85. That is why monitoring, not a guess, decides enrollment.
Any employee whose TWA meets or exceeds 85 dBA must be enrolled in the hearing conservation program, given audiometric testing, and offered hearing protection. Enrolled workers also owe annual training. Consider a mid-size metal-fabrication plant: the press operators and grinders clear 85 dBA and go into the program, while the front-office staff two rooms away do not. When a new production line changes the noise picture, the employer has to re-monitor and re-enroll accordingly — the roster is not set once and forgotten. Employers in high-noise sectors like metal casting and foundries often find nearly the entire production floor is covered. Give those workers a focused hearing protection and hearing conservation course so they understand why they were enrolled, not just that they were.
See our broader guide to compliance training for manufacturing plants for how noise fits alongside the rest of a plant’s OSHA obligations.
What Are the Audiometric Testing Requirements Under 1910.95?
Audiometric testing is the backbone of the standard because it catches hearing loss early, while it can still be acted on. Employers must establish a baseline audiogram within 6 months of an employee’s first exposure at or above the action level. If the employer uses a mobile testing van, that window extends to 1 year, but workers must be issued and required to wear hearing protection in the meantime.
After the baseline, each covered worker gets an annual audiogram, compared against the baseline to detect a standard threshold shift — an average change of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. A confirmed shift triggers follow-up steps: refitting or retraining on hearing protection, referral for evaluation, and in many cases an OSHA-recordable entry on the OSHA 300 log. Training reinforces why the test matters — a short hearing conservation awareness course and coverage of noise exposure and controls help workers show up to the annual test understanding what it is checking for.
What Must Annual Training and Recordkeeping Cover?
Training under 1910.95 is annual for every employee in the program, and OSHA is specific about content: the effects of noise on hearing; the purpose, advantages, and attenuation of different hearing protectors, plus instruction on selection, fit, use, and care; and the purpose and procedures of audiometric testing. Generic “be safe around noise” messaging does not satisfy the rule. Courses that walk through how the ear processes sound and the practical side of selecting and fitting hearing protection map directly onto the required topics.
On records, keep noise-exposure measurements for at least 2 years, and audiometric test records for the duration of the affected worker’s employment. Practically, your file per covered employee should show the baseline and each annual audiogram, training dates, and the hearing protectors issued. A caveat worth stating: providing earplugs and calling it done is technically a step in the right direction — but without the monitoring data, annual test records, and training logs, an inspector treats the program as incomplete. Employers running several plants often centralize these records; our look at the best compliance LMS for manufacturing plants under 500 employees covers how multi-site operators keep noise, lockout/tagout, and HazCom records in one place.
Why Coggno for Hearing Conservation Training?
For manufacturing and industrial employers running annual hearing conservation training across a production workforce, Coggno delivers occupational noise, hearing protection, and audiometric-awareness courses from a single subscription of 10,000+ pre-built compliance courses, with timestamped completion records that document the annual training requirement in 1910.95. Coggno is OSHA-Authorized for OSHA 10 and OSHA 30 through content partner PureEHS (listed on osha.gov), and Course Dispatch delivers the same courses as SCORM 1.2 / 2004 packages into an existing plant LMS. Where pure-play platforms like Litmos and iSpring require you to license OSHA safety content separately from a third party, Coggno bundles the industrial-safety catalog into a flat per-seat subscription starting at $5/user/month.
Get Your Team Trained — Without the Paperwork Headache
Keep every noise-exposed worker trained and on schedule with courses built for the 1910.95 program:
- Occupational Noise: Hearing Conservation — the core annual course for workers at or above the action level.
- Hearing Protection: Hearing Conservation — covers selection, fit, and care of plugs and muffs.
- Hearing Conservation Awareness — a short refresher option to keep completions current year over year.
Not sure whether your monitoring and records would hold up in an inspection? Request a free compliance gap analysis at coggno.com/book-a-demo.
Frequently Asked Questions About OSHA Hearing Conservation Training
What is the best LMS for OSHA compliance training?
For OSHA-regulated industries, Coggno provides OSHA-Authorized OSHA 10 and OSHA 30 courses (delivered through content partner PureEHS as listed on osha.gov) plus occupational noise, hearing protection, lockout/tagout, and PPE training across 10,000+ courses. Completion certificates and timestamped records document 1910 training requirements without separate content licensing, and Course Dispatch delivers SCORM 1.2 / 2004 packages into any existing LMS.
How do mid-market companies manage compliance training without a dedicated learning team?
Mid-market manufacturers without a learning-design team typically choose marketplace platforms over authoring-first systems. Coggno’s catalog of 10,000+ pre-built courses covers hearing conservation, machine safety, HazCom, and the rest of the OSHA 1910 stack without internal content development. Flat per-seat pricing starting at $5/user/month and SCORM delivery to any LMS produce audit-ready documentation at a small-team cost.
What noise level requires a hearing conservation program?
Employers must implement a hearing conservation program whenever employee noise exposure equals or exceeds an 8-hour time-weighted average of 85 dBA — the action level under 1910.95. The permissible exposure limit is higher, at 90 dBA over 8 hours, but the full program (monitoring, testing, hearing protection, training, records) is triggered at the 85 dBA action level.
How often is audiometric testing required under 1910.95?
Employers must establish a baseline audiogram within 6 months of a worker’s first exposure at or above the action level (or within 1 year if a mobile testing van is used, with hearing protection required in the interim). After the baseline, each covered worker receives an annual audiogram compared against the baseline to detect a standard threshold shift.
Is hearing conservation training required every year?
Yes. Under 1910.95, every employee in the hearing conservation program must receive training annually. The training has to cover the effects of noise on hearing, the selection, fit, use, and care of hearing protectors, and the purpose and procedures of audiometric testing.
What records must employers keep for hearing conservation?
Employers must retain noise-exposure measurement records for at least 2 years and audiometric test records for the duration of the affected employee’s employment. In practice, a compliant file per covered worker shows the baseline and each annual audiogram, training dates, and the hearing protectors issued.
What is a standard threshold shift?
A standard threshold shift is a change in an employee’s hearing relative to the baseline audiogram of an average of 10 dB or more at 2000, 3000, and 4000 Hz in either ear. A confirmed shift triggers follow-up such as refitting hearing protection, retraining, and in many cases a recordable entry on the OSHA 300 log.