OSHA Hearing Protection Program: Complete Guide for Small Business

15 min read
OSHA Hearing Protection Program: Complete Guide for Small Business

Why Your Business Needs a Hearing Conservation Program (And How to Build It)

Your employee just filed a workers’ comp claim for hearing loss. $30,000 in medical costs. Years of wage loss. And that claim affects your experience modifier rate for at least 3 years. Oh, and your employee has to live with hearing loss for the rest of their life.

All because you didn’t have a Hearing Conservation Policy.

Here’s what makes this so bad: hearing loss is 100% preventable. Even still, it’s the third most common chronic condition in America—more common than diabetes or cancer. Over 22 million U.S. workers are exposed to hazardous noise levels every year. Most businesses do nothing about it until it’s too late.

The workers’ comp system spends $242 million a year on hearing loss alone. Most of that is preventable with a simple policy and basic controls.

If your workers are exposed to noise levels of 85 decibels or higher for 8 hours, OSHA requires a Hearing Conservation Program. Not recommended. Required.

Here’s why this matters for your business—and how to build your policy.

Table of Contents

Why Hearing Loss Destroys More Than Hearing

Noise-induced hearing loss doesn’t happen overnight. It’s gradual. Your workers don’t notice until it’s too late. And once it’s gone, it’s permanent.

The Human Cost

What happens to your employees:

  • Permanent hearing damage—no reversal, no cure
  • Difficulty communicating at work and home
  • Social isolation and depression
  • Increased safety risk (can’t hear warnings, alarms, or equipment)
  • Reduced quality of life
  • Tinnitus (constant ringing) that never stops

Your workers don’t just lose hearing. They lose the ability to have dinner conversations with their families. To hear their grandkids. To enjoy music. To feel normal.

The Business Cost

What happens to your company:

Workers Compensation Claims:

  • Average hearing loss claim: $20,000–$40,000
  • Medical treatment and testing
  • Hearing aids ($2,000–$7,000 per ear)
  • Ongoing medical monitoring
  • Wage loss compensation
  • Legal fees if disputed

Experience Modification Rate Impact:

  • Each claim raises your EMR
  • EMR stays elevated for 3 years minimum
  • 10-20% premium increase per claim is common
  • On $50,000 premium: $5,000–$10,000/year additional cost
  • Total 3-year impact: $15,000–$30,000+ per claim

See our post on how your experience modification rate works.

OSHA Penalties:

  • $16,550 per serious violation
  • $165,514 per willful/repeated violation
  • Citations for missing hearing conservation programs are common

Operational Costs:

  • Lost productivity from injured workers
  • Training replacement workers
  • Reduced team morale
  • Difficulty recruiting in high-noise environments

One hearing loss claim can cost your business $50,000+ when you factor in medical costs, EMR impact, and operational disruption. Get a breakdown of the real cost using our safety ROI calculator: select Custom and enter the $50,000 claim cost. Spoiler: It costs you almost 3X what it costs the insurance company.

Compare that to the cost of prevention: noise monitoring, hearing protection, training. Maybe $2,000–$5,000 total to protect your entire workforce.

What Is a Hearing Conservation Policy?

A Hearing Conservation Policy is your written plan for protecting workers from hearing loss.

It covers:

  • Who needs protection and when
  • How you’ll monitor noise levels
  • What hearing protection you provide
  • How you’ll train employees
  • How you’ll test hearing over time
  • How you’ll document everything

When you need one:

OSHA requires a Hearing Conservation Program when workers are exposed to noise levels at or above 85 decibels (dBA) for 8 hours. That’s the action level.

What does 85 dBA sound like?

  • Heavy city traffic
  • Gas-powered lawn mower
  • Noisy restaurant
  • Garbage disposal

If your workplace is louder than that for extended periods, you need a program.

Industries that always need hearing conservation:

  • Manufacturing
  • Construction
  • Warehousing
  • Aviation
  • Agriculture
  • Oil and gas
  • Mining
  • Transportation
  • Entertainment/venues

If you’re not sure whether you need a program, measure the noise. Don’t guess.

OSHA Requirements: What You Must Do

OSHA’s standard (29 CFR 1910.95) isn’t optional. Here’s what compliance requires:

1. Noise Monitoring

Measure workplace noise levels:

  • Use calibrated sound level meters or dosimeters
  • Identify all areas and jobs with 85 dBA or higher exposure
  • Monitor whenever equipment or processes change
  • Provide employees access to monitoring results
  • Keep records for 2 years

Don’t guess. Don’t assume. Measure.

2. Engineering Controls (First Priority)

Reduce noise at the source:

  • Buy quieter equipment when replacing machinery
  • Add enclosures around loud equipment
  • Install vibration damping
  • Use sound-absorbing materials
  • Maintain equipment (worn parts are louder)

Engineering controls are OSHA’s first choice. They eliminate the hazard instead of just managing it.

3. Administrative Controls (Second Priority)

Limit exposure time:

  • Rotate workers out of high-noise areas
  • Schedule noisy operations during times with fewer workers
  • Limit time spent in noise zones
  • Use remote operation when possible

These controls reduce exposure but don’t eliminate the hazard.

4. Hearing Protection (Last Resort, But Required)

When controls aren’t enough:

  • Provide hearing protection at no cost to employees
  • Offer multiple types (earplugs, earmuffs)
  • Ensure proper fit for each worker
  • Require use in designated areas
  • Make protection mandatory at 90 dBA
  • Make protection available at 85 dBA

Hearing protection is your backup plan. Not your only plan. Many companies just go ahead and require it at 85 dBA, and you should too.

5. Audiometric Testing

Baseline testing:

  • Within 6 months of first exposure
  • Establishes normal hearing levels
  • Must be done by a certified audiologist or a qualified technician

Annual testing:

  • Compare to the baseline each year
  • Identify Standard Threshold Shift (STS) - 10 dB change in hearing
  • Retest within 30 days if STS detected
  • Keep records for the duration of employment

This catches hearing loss early.

6. Employee Training (Annual)

Cover these topics every year:

  • Effects of noise on hearing
  • Purpose of hearing protection
  • Types of protection available
  • How to select and fit protection
  • Purpose of audiometric testing
  • Results of their hearing tests
  • Their right to access records

Training isn’t a one-time event. Annual refreshers are required. Smarter Risk includes this training.

7. Recordkeeping

Maintain these records:

  • Noise monitoring results (2 years)
  • Audiometric test records (employment duration)
  • Training documentation (3 years)
  • Hearing protection issued
  • Policy updates and reviews

When OSHA shows up, they ask for records first.

What Your Hearing Conservation Policy Must Include

Don’t overcomplicate it. Cover these essential elements:

1. Purpose and Scope

State clearly:

  • This policy exists to protect employees from noise-induced hearing loss
  • It applies to all workers exposed to 85 dBA or higher
  • Compliance is mandatory, not optional

2. Responsibilities

Assign accountability:

Program Administrator:

  • Oversees the entire program
  • Ensures monitoring happens
  • Reviews test results
  • Maintains records
  • Updates policy as needed

Supervisors:

  • Enforce hearing protection use
  • Report equipment changes that affect noise
  • Ensure new employees are tested
  • Monitor compliance in their areas

Employees:

  • Wear hearing protection as required
  • Report hearing problems immediately
  • Attend annual training
  • Participate in audiometric testing

3. Noise Monitoring Procedures

Detail your process:

  • Who conducts monitoring
  • What equipment is used
  • How often monitoring will occur
  • How results are documented
  • When re-monitoring is required

4. Engineering and Administrative Controls

List your controls:

  • Specific equipment with noise reduction features
  • Enclosures and barriers that are in place
  • Job rotation schedules
  • Equipment maintenance requirements

5. Hearing Protection Requirements

Specify:

  • Where protection is required (85+ dBA areas)
  • Types of protection available
  • How to obtain protection
  • Fitting procedures
  • Replacement policy
  • Enforcement consequences

6. Audiometric Testing Program

Describe:

  • Who provides testing
  • When baseline tests occur
  • Annual testing schedule
  • How employees access results
  • What happens with STS detection
  • Record retention period

7. Training Requirements

Outline:

  • Who needs training
  • Training frequency (annual)
  • Topics covered
  • How attendance is documented
  • Refresher requirements

8. Recordkeeping

Specify what you maintain:

  • Noise exposure data
  • Audiometric test results
  • Training attendance
  • Hearing protection issued
  • Policy reviews and updates

Common Hearing Conservation Mistakes

Don’t make these errors:

Mistake #1: No Baseline Testing
New employees start working in high-noise areas before baseline audiograms are done. You can’t detect hearing loss without a baseline.

Mistake #2: Skipping Annual Training
“They already know” isn’t compliance. Annual training is required. Document everything.

Mistake #3: Inadequate Hearing Protection
One-size-fits-all foam earplugs don’t work for everyone. Offer options. Ensure proper fit.

Mistake #4: Not Enforcing Protection Use
Requiring hearing protection means nothing if you don’t enforce it. Supervisors must hold workers accountable.

Mistake #5: Ignoring Standard Threshold Shifts
When testing shows 10+ dB hearing loss, you must act. Refit protection. Increase controls. Document response.

Mistake #6: Poor Recordkeeping
OSHA wants records. If you can’t produce them, you’re in violation—even if you did the testing.

Mistake #7: No Engineering Controls
Relying only on hearing protection isn’t enough. OSHA expects you to reduce noise at the source first.

How Smarter Risk Makes This Simple

Building a comprehensive Hearing Conservation Policy used to mean months of research, template hunting, and hoping you didn’t miss anything.

Not anymore.

Build Your Policy in Minutes

Smarter Risk’s Policy Builder generates a complete, customized Hearing Conservation Policy based on your risk assessment.

What you get:

  • Complete policy document aligned with OSHA 29 CFR 1910.95
  • Noise monitoring procedures
  • Audiometric testing protocols
  • Training requirements
  • Record templates
  • Employee notification forms

Download in Word format. Customize further if needed. Implement immediately.

What’s Included with Smarter Risk

Intelligent Plan ($500/year):

150+ Safety Forms

  • Noise monitoring logs
  • Audiometric test records
  • Training attendance sheets
  • Hearing protection issuance forms
  • STS notification templates

50+ Training Courses

  • Hearing conservation training
  • PPE requirements
  • Footwear protection
  • Respiratory protection

Policy Builder

  • Hearing Conservation Policy
  • PPE Policy
  • Hazard Communication
  • 20+ other safety programs

Continuous Tracking

  • Document training completion
  • Track audiometric testing schedules
  • Monitor protection compliance
  • Update risk score automatically

No safety expertise required. RISK-B, our AI assistant, guides you through everything.

Implementation: Your 30-Day Plan

Don’t let this sit on a shelf. Here’s how to implement fast:

Week 1: Assess and Document

  • Conduct noise monitoring in all work areas
  • Identify employees exposed to 85+ dBA
  • Document current noise levels
  • Generate your policy with Smarter Risk

Week 2: Equipment and Testing

  • Order hearing protection (multiple types)
  • Schedule baseline audiometric testing
  • Post hearing protection required signs
  • Set up testing schedule

Week 3: Train Your Team

  • Conduct initial training for all exposed workers
  • Demonstrate proper hearing protection use
  • Explain testing requirements
  • Review policy with supervisors

Week 4: Go Live

  • Require hearing protection in designated areas
  • Begin audiometric testing
  • Enforce compliance
  • Document everything

Ongoing

  • Annual audiometric testing
  • Annual training refreshers
  • Re-monitoring when equipment changes
  • Policy reviews and updates

The Bottom Line

Hearing loss is permanent. But it’s also 100% preventable.

A Hearing Conservation Policy protects your workers from irreversible damage. It protects your business from expensive claims that raise your experience mod for years.

OSHA requires it when noise levels hit 85 dBA. Most manufacturers, construction companies, and warehouses meet that threshold easily.

The question isn’t whether you need a policy. It’s whether you’ll implement one before the claims start—or after.

With Smarter Risk, implementation takes minutes instead of months. For $500/year, you get a complete hearing conservation program that meets OSHA requirements.

One prevented hearing loss claim pays for itself 60x over.

Build Your Hearing Conservation Policy Today

Don’t wait for OSHA to cite you. Don’t wait for a workers comp claim.

Start your free risk assessment and generate your complete Hearing Conservation Policy in minutes.

Or explore our Safety Made Simple approach to building comprehensive safety programs from scratch.

Frequently Asked Questions About Hearing Conservation

What is the OSHA action level for noise exposure?

85 dBA over an 8-hour time-weighted average (TWA). At this level, you must offer hearing protection and begin monitoring. At 90 dBA, hearing protection becomes mandatory.

How often should audiometric testing be done?

Baseline testing within 6 months of first exposure to 85+ dBA. Annual testing after that. Additional testing is required within 30 days if a Standard Threshold Shift (STS) is detected.

Who pays for hearing protection and testing?

The employer. OSHA requires hearing protection and audiometric testing to be provided at no cost to employees. This includes fitting, training, and replacement.

How do I measure workplace noise levels?

Use a calibrated sound level meter or noise dosimeter. Sound level meters measure noise at a point in time. Dosimeters measure cumulative exposure over a shift. Consider hiring an industrial hygienist for initial assessment. Contact your insurance carrier, they may be able to provide resources.

What is a Standard Threshold Shift (STS)?

An average change of 10 decibels or more at 2000, 3000, and 4000 Hz in either ear when compared to baseline. This indicates hearing loss is occurring. You must refit hearing protection and inform the employee within 21 days.

Can hearing protection reduce noise enough?

Yes, but only if worn properly. Properly fitted earplugs can reduce noise by 15-30 dB. Earmuffs provide 20-35 dB reduction. Double protection (plugs + muffs) offers maximum protection for extreme noise.

Is training on hearing conservation mandatory?

Yes. All employees exposed to 85+ dBA must receive annual training on noise effects, hearing protection selection and use, audiometric testing procedures, and their rights under the program.

What noise level requires hearing protection?

Protection must be available at 85 dBA. Protection is mandatory at 90 dBA. Many companies make it mandatory at 85 dBA to simplify enforcement.

What if an employee refuses to wear hearing protection?

Document the refusal. Retrain on proper use and importance. Explain consequences. If refusal continues, disciplinary action may be necessary. But the employer still has a duty to protect and must enforce the policy.

Can I use smartphone apps to measure noise?

Not for compliance purposes. OSHA requires calibrated instruments. Smartphone apps can give rough estimates, but aren’t acceptable for official monitoring or documentation.

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About the Author

John Morlan - Founder of Smarter Risk

John Morlan

Founder & CEO, Smarter Risk

John Morlan is the founder of Smarter Risk, a platform helping small businesses implement practical safety and risk control programs. With years of experience in workers' compensation and risk management, John has helped businesses reduce their risk and save on insurance costs through proactive risk control and safety strategies.