Do you need a hearing baseline for temporary workers?

By: Travis Rhoden

Publication: Workplace Safety Regulatory Alert

Date Posted: 03/09/2020

A common scenario for employers is to hire a temp or seasonal worker, who will only be with the company for a few weeks or months, maybe even days in some cases.

But, if those workers are exposed to high levels of noise, do host employers still have to establish a baseline audiogram, as required in the regulation?

OSHA says no to hearing baseline

While the noise standard does not include a specific exemption from audiometric testing for temporary or seasonal workers, OSHA says in a recent letter of interpretation that audiometric testing would be administratively difficult or impossible because these workers work for several employers in a season or over the course of a year.

“In many cases,” OSHA writes, “It is not practical nor appropriate to require audiometric testing of seasonal or temporary workers because the employee will not be employed long enough for the employer to obtain an annual audiogram against which to compare the baseline audiogram.”

“Accordingly, if a temporary or seasonal employee’s audiometric testing is due after the employee’s term of employment has ended, the employer is not required to establish a baseline audiogram.”

Importance of the baseline

The baseline audiogram is extremely important since it is the reference against which future audiograms are compared to determine the extent to which an employee’s hearing is deteriorating. Although not required, OSHA encourages employers to make baseline audiograms available to employees as soon as possible after an employee has been exposed to workplace noise at or above the action level. In general, baseline audiograms administered near the time of an employee’s first exposure are more accurate for determining hearing loss. An early baseline may also make it easier for temporary employees to subsequently evaluate hearing loss as they move from one employer to another.

OSHA recognizes the practical difficulties with audiometric testing of temporary workers, especially when employers use mobile testing services, and therefore section 1910.95(g)(5)(ii) includes the additional six-month time period for conducting baseline audiograms.

But, hearing protection must be used

OSHA reminds employers that section 1910.95(i)(2)(ii)(A) specifically requires employers to ensure that hearing protectors are used by any employee, including temporary and seasonal employees, who has been exposed at or above the action level and has not yet had a baseline audiogram.

Finally, in situations where the cumulative noise exposure for an employee meets or exceeds the six-month or one-year timeframes, the employer must comply as provided by section 1910.95(g)(5)(i) or 1910.95(g)(5)(ii). In other words, if a temporary or seasonal employee works for the same employer during two or more separate periods of time within a 12-month period, and is exposed to noise at or above the action level during all periods of employment, the employer must make audiograms available to that temporary or seasonal worker.

What the noise regs say

OSHA’s noise standard at section 1910.95(g)(1) requires employers to make audiometric testing available to all employees whose exposures equal to or exceed an 8-hour time-weighted-average of 85 dB (the action level). Section 1910.95(g)(5)(i) requires that employers establish a valid baseline audiogram within six months of an employee’s first exposure at or above the action level. Section 1910.95(g)(5)(ii) goes on to provide that employers using mobile testing services to satisfy their audiometric testing obligations are allowed one year to obtain a valid baseline audiogram, provided that six months after an employee’s first exposure to workplace noise at or above the action level, the employee uses hearing protectors until the baseline audiogram is obtained.

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