CAOHC Recordkeeping and Program Management 2 — Questions and Answers
Question 1: Which records must an employer maintain as part of the OSHA hearing conservation program?
- Noise exposure measurements, audiometric test results, and audiometer calibration records (Correct answer)
- Only annual audiometric test results
- Hearing protector purchase receipts only
- Training attendance sheets but not test results
Correct answer: Noise exposure measurements, audiometric test results, and audiometer calibration records
OSHA requires records of noise exposure measurements (2 years), audiometric test results (duration of employment), and calibration records.
Per 29 CFR 1910.95(m), required records include noise exposure measurements retained for 2 years, audiometric test records retained for the duration of employment, and audiometer calibration records.
Question 2: What is the role of the program administrator in a hearing conservation program?
- To coordinate all program elements including monitoring, testing, training, protector provision, and recordkeeping (Correct answer)
- To personally perform all audiometric tests
- To design and manufacture hearing protection devices
- To conduct engineering noise control studies exclusively
Correct answer: To coordinate all program elements including monitoring, testing, training, protector provision, and recordkeeping
The program administrator coordinates the overall hearing conservation program, ensuring all required elements are implemented and maintained.
Effective administrators schedule monitoring, coordinate testing, manage protector selection, organize training, maintain records, follow up on STS cases, and evaluate program effectiveness through metrics like STS rates.
Question 3: How should an employer evaluate the effectiveness of their hearing conservation program?
- By tracking STS rates, comparing them to industry benchmarks, and analyzing trends over time (Correct answer)
- By counting hearing protectors distributed annually
- By measuring noise levels once every five years
- By surveying employees about job satisfaction
Correct answer: By tracking STS rates, comparing them to industry benchmarks, and analyzing trends over time
Program effectiveness is best evaluated by analyzing audiometric trends, STS incidence rates, and comparing metrics against industry benchmarks.
Key metrics include STS rate (rates above 4-5% suggest deficiencies), trend analysis of average thresholds, and NIOSH benchmarking against age-matched non-noise-exposed populations.
Question 4: What information must be included on the OSHA 300 Log when recording a hearing loss case?
- Employee name, job title, date of injury, location, and classification as hearing loss (Correct answer)
- Only the employee name and the STS date
- A complete copy of all audiometric test results
- The hearing protector type and NRR used
Correct answer: Employee name, job title, date of injury, location, and classification as hearing loss
Recordable hearing loss cases must be entered with standard injury recording information including employee identification, dates, and classification.
Cases are checked in column M(5) for hearing loss. Cases are considered work-related unless the employer can demonstrate the loss was caused solely by non-occupational factors.
Question 5: How long must noise exposure measurement records be retained under OSHA?
- At least 2 years (Correct answer)
- At least 5 years
- For the duration of employment
- 30 years after last exposure
Correct answer: At least 2 years
OSHA requires noise exposure measurement records be retained for at least 2 years, shorter than the duration-of-employment requirement for audiometric records.
Best practice recommends retaining noise monitoring data longer because records may be needed for workers compensation claims or demonstrating historical compliance during audits.
Question 6: What is the purpose of the annual program audit in hearing conservation?
- To systematically review all program components for compliance and effectiveness (Correct answer)
- To determine which employees should be removed from the program
- To calculate the total program cost for the fiscal year
- To test the audiometric booth ambient noise levels only
Correct answer: To systematically review all program components for compliance and effectiveness
An annual audit evaluates every HCP element to identify deficiencies and drive continuous improvement.
An effective audit examines noise monitoring, audiometric testing, hearing protectors, training, recordkeeping, and engineering controls, with specific recommendations and timelines.
CAOHC Recordkeeping and Program Management 2
Which records must an employer maintain as part of the OSHA hearing conservation program?