Who Can See an Employee's Audiogram? OSHA Access Rules Explained

Who is legally entitled to see an employee's audiogram?

Under 29 CFR 1910.1020, the employee whose hearing was tested and that employee's designated representative, which can be a physician, attorney, or anyone the employee names in writing, must be given access to the audiogram on request¹. The employer has fifteen working days to provide it, or to explain in writing why access is delayed. OSHA compliance officers can also review audiometric records during an inspection, and that access doesn't require employee consent because it flows from the employer's recordkeeping obligation under the standard, not from a medical release. Outside of those three parties, the employee, a named designated representative, and OSHA itself, nobody has an automatic right to see the raw test data. A supervisor asking "how'd Dave's hearing test go" is asking a question the audiogram file isn't required to answer.

Does a supervisor or HR get to see the actual results?

Not by default. The hearing conservation standard at 1910.95 requires the employer to maintain audiometric records, but it doesn't grant general workplace access to supervisors or HR staff managing performance or attendance issues². What the employer is required to know, and act on, is different from what individual managers are entitled to see in the file. An employer must know whether an employee had a standard threshold shift so it can trigger retesting, hearing protector refitting, or medical referral under 1910.95(g). That obligation doesn't require circulating the audiogram itself through the chain of command. In practice, the professional supervising the audiometric program (usually an audiologist, physician, or the CAOHC-certified technician's supervising professional) reviews the results and reports actionable findings, such as an STS, back to the employer without the employer necessarily seeing every dB reading at every frequency.

Party	Access right	Condition
Employee	Full access to their own record	Written request, 15 working days
Designated representative	Full access	Employee's written authorization
OSHA	Full access	During an inspection, no consent required
Supervisor / HR	No automatic access	Only findings the program requires the employer to act on
Workers' comp insurer	No automatic access	Requires a signed release tied to a specific claim

Is a hearing test result covered by HIPAA?

Usually not directly. HIPAA governs covered entities, health plans, healthcare clearinghouses, and providers that transmit health information electronically for billing. An employer running a mandatory hearing conservation program under 1910.95 is acting as an employer, not a covered entity, so the audiogram sits under OSHA's medical recordkeeping framework rather than HIPAA's¹. That distinction matters because the two frameworks set different rules: HIPAA's minimum necessary standard and patient-authorization requirements don't automatically apply, but 1910.1020's access, retention, and confidentiality provisions do. If a third-party audiologist or clinic that also treats the employee as a patient generates the audiogram, HIPAA can apply to that provider's own records even while the employer's copy is governed by 1910.1020. Employers who assume "no HIPAA, no rules" are wrong just as often as employers who assume HIPAA covers everything; the correct answer is that OSHA's own confidentiality structure fills the gap.

What happens to audiogram access when testing happens on a mobile unit?

Mobile and on-site hearing conservation programs don't change who is entitled to access, but they do change where the record lives and who handles it physically on test day. A testing vendor operating inside a client facility is typically acting as the employer's agent for purposes of generating and initially holding the record, and the same 1910.1020 rules apply to that vendor's copy as to a copy held in an HR filing cabinet. The practical risk on a mobile unit isn't a legal gap, it's a logistics gap: results printed and handed across a table, a laptop screen visible in a hallway line, or a roster left on a clipboard where the next employee in line can read the name above theirs. A program with a real confidentiality standard treats the mobile unit's paper and digital handling the same way it would treat a locked HR cabinet, not a lighter standard because the visit is temporary.

How Foster handles audiogram confidentiality on mobile testing days

Every account we test gets individual, sealed results, not a shared printout or a roster with hearing thresholds visible next to names. Results go to the employer's designated HR or safety contact and, on request, directly to the employee, never posted on a breakroom bulletin board or left with a site supervisor to hand out. Our reviewing professional flags standard threshold shifts and other actionable findings in a separate summary so the employer gets what it needs to act, without every manager on-site needing to read a raw audiogram. For employers juggling this across dozens of employees and multiple test dates a year, keeping the access boundary straight by hand is where mistakes creep in, which is part of why Foster's Compliance Workspace tracks each employee's testing and training requirements with the record itself, not a spreadsheet a manager can open and scroll through unsupervised.

What should an employer do if a manager asks to see someone's results?

Redirect the request to the designated recordkeeper and, if the intent is to confirm the employee is meeting a job requirement or medical restriction, ask for the specific pass/fail or fitness determination rather than the underlying audiogram. Most of what a manager actually needs, whether an employee cleared the annual test, whether a retest is scheduled, doesn't require reading raw thresholds at 500 Hz through 6000 Hz. If the request is tied to a workers' compensation claim or legal proceeding, that access has to go through a signed release specific to that purpose, not a general "can I see the file" ask. Employers that build this redirect into policy avoid the more common failure mode, which isn't malicious snooping but casual access nobody thought to restrict.

Frequently asked questions

Can a former employee still request their audiogram?

Yes. Access rights under 1910.1020 aren't limited to current employees, and records must be retained for the duration of employment, so a former employee can request their file after leaving¹.

Does the employee have to pay for a copy of their audiogram?

No. 1910.1020 requires the employer to provide the copy, copying facility, or loan of the record without cost to the employee.

Can an employer refuse to release results to a workers' comp carrier?

An employer should require a signed release from the employee before sending records to an insurer; blanket release forms that predate a specific claim don't substitute for authorization tied to the actual request.

Do union representatives count as designated representatives?

Yes, if the employee names the union representative in writing as their designated representative, that representative gets the same access rights the employee would have.

Is a verbal request enough to trigger the 15-day access clock?

No. 1910.1020 access rights attach to a written request; employers should still respond reasonably to verbal requests, but the enforceable timeline runs from the written one.

For a hearing conservation program built around defensible recordkeeping from the start, see our hearing testing services and audiometer calibration pages, or request a quote for a mobile testing day. Related reading: how long OSHA audiogram records must be kept.

Sources

• 29 CFR 1910.1020, Access to Employee Exposure and Medical Records
• 29 CFR 1910.95, Occupational Noise Exposure