Hearing Conservation: OSHA Compliance and Best Practices

  • Jul 11, 2023, 10:53 AM
Staying compliant with OSHA is tough for any company. There are several pieces that must come together to make a successful, OSHA-compliant safety program including; inspections, audits, training programs, recordkeeping, and so much more. It is easy to unintentionally neglect certain areas of a safety program. 

One area of a successful safety program that cannot be neglected is hearing conservation. Hazardous noise can harm and individual's quality of life and become a chronic health condition if gone unchecked. But noise is around us every day - so what exactly is considered "hazardous noise"? 

Defining Hazardous Noise 

Sound is measured in decibels (dB), which are a measurement of how loud a noise is. Once a certain dB is reached a noise becomes hazardous to the health of our eardrums. At this point, called an “action level”, action is required to minimize exposure to hazardous noise. Governing safety organizations (OSHA and MSHA) were able to determine that this level is anything at or above 85 dBs averaged over eight working hours – most industrial facilities meet these action level criteria. For reference, the Centers for Disease Control and Prevention (CDC) measures a normal conversation at 60 dBs, while a motorcycle is around 90 dBs.  

Whether it’s general industry, construction, or mining – noise is a common, if not the most common hazard in the workplace. According to the National Institute for Occupational Safety & Health (NIOSH): 

  • 46% of Manufacturing industry workers are exposed to hazardous noise. 
  • 51% of Construction industry workers are exposed to hazardous noise. 
  • 76% of Mining industry workers are exposed to hazardous noise. 
  • 61% of Mining, Oil, and Gas Extraction workers are exposed to hazardous noise. 

Mitigating Hazardous Noise: Best Practices

Industrial equipment (motors, compressors, conveyors, etc.) are essential, but loud. What can the employer do to continue production without potentially damaging the hearing of the workers? 

The first place to start is every safety professional's golden rule; the Hierarchy of Controls. 

Safety Hierarchy of Controls

We will explore how these levels of the hierarchy apply to hearing conservation. Due to how widespread hazardous noise is in the workplace, it is near impossible to correct the entire issue using the top three controls in this hierarchy. A Hearing Conservation program falls into the administrative level. 

Eliminate: To eliminate noise in the workplace, all machines and equipment would have to be eliminated. This cannot be done. 

Some older machines/equipment can be substituted for new ones, potentially resulting in a reduction of a few decibels. This can help but is not a holistic solution. 

Workers can be moved to different areas away from hazardous noise if there is enough space. Walls can also be built to reduce noise exposure. Again, this can help reduce exposure, but will not protect ALL workers. 

Administrative Controls:
This is where the Hearing Conservation Program is implemented. After trying to eliminate, substitute, and engineer noise out of the workplace and failing to stay under OSHA’s action level (85 dB), it is time for the employer to implement a Hearing Conservation Program. This involves monitoring, hearing protection, training, and audiograms. 

In summary, some minor solutions can be identified while trying to eliminate, substitute, and engineer hazardous noise out of the workplace, but the most realistic solution is a robust Hearing Conservation Program. Trying to determine what is required in this program can be a daunting task. The specific standards for a hearing conservation program can be found under CFR 1910.95(c), but for this article, we have broken the program down into 4 areas. 

4 Steps to a Successful Hearing Conservation Program  

Noise monitoring or sound level monitoring is used to determine which employees need to be included in the hearing program, and what level of hearing protection is required based on the dB reading of the work areas. This is the first step. 


Step 1: Noise Monitoring. 
Noise monitoring or sound level monitoring is used to determine which employees need to be included in the hearing program, and what level of hearing protection is required based on the dB reading of the work areas. This is the first step. 

Step 2: Hearing Protection.  
Once the noise levels have been assessed at the workplace, the employer can decide on the necessary hearing protection. This decision should be based on the noise level of an area and the hearing protection’s noise reduction rate (NRR). 

Step 3: Training.  
OSHA states that employees need to be trained in the effects of noise on hearing, the purpose of hearing protectors, the advantages, disadvantages, etc. It is important that employees are aware of the risk, and how to adequately protect themselves. 

Step 4: Audiograms. 
An audiogram or audiometric test is a type of hearing threshold examination done by a licensed or certified audiologist, otolaryngologist, physician, or technician who is certified by the Council of Accreditation in Occupational Hearing Conservation. OSHA declares every employee identified in the hearing conservation program must have a baseline audiogram conducted (at no cost to the employee) within 6 months of their first exposure at or above the action level and annually after that. The employer must inform the employee of significant shifts in hearing based on this test. 


Implementing and maintaining a successful hearing conservation program takes some legwork. Many facilities rely on outside help to ensure they are up to OSHA’s code to keep their employees safe. Luckily, SMC has the knowledge and experience to aid the the betterment, or creation of a solid Hearing Conservation Program. 

Sound Monitoring Service: a technician will assess sound in the workplace using a sound level meter to identify and control high noise hazards. This service includes:

  • A report with decibel readings for all applicable areas.
  • Identification of areas that require hearing protection based on OSHA PEL.
  • Recommendations for hearing protection (NRR based on exposure levels). 

Hearing Conservation Training: 

  • Employee hearing conservation training and awareness 
  • Management hearing conservation training and awareness 

Hearing Protection: 

  • Disposable earplugs  
  • Earmuffs  
  • Custom hearing protection  

SMC Tool: Shane McAnally  

Safety professional Shane McAnally is employed by SMC in Springfield MO, managing safety projects, training, and developing safety content. After earning a Bachelor of Science in Occupational Safety from the University of Central Missouri, he started his career as a safety intern at a cement manufacturing facility in Eastern Oregon where he would work his way to becoming the Plant Safety Manager. In this position, he became comfortable with the MSHA handbook and was trained as a part 46 certified miner.  

These experiences have shaped his areas of focus into OSHA/MSHA interpretation, training, program development, incident investigation, and physical inspection. 

Click below to speak with Shane about implementing a customized Hearing Conservation Program for your own facilities.