How Long Must OSHA Audiogram Records Be Kept?

How long does OSHA require audiogram records to be kept?

Audiometric test records must be retained for the duration of the affected employee's employment, not for a fixed number of years¹. That standard comes from 29 CFR 1910.95, the occupational noise exposure rule, and it applies to every baseline and annual audiogram generated under a hearing conservation program. The practical effect is that a safety manager can't set a five- or seven-year purge cycle for audiogram files the way they might for some other safety records, because the retention clock doesn't start over and doesn't have a fixed end date until the employee actually leaves. A record created in an employee's first year on the job has to stay accessible for as long as that person stays on payroll, which for long-tenured employees can mean decades of audiograms in the same file.

Why is the audiogram retention rule different from noise exposure record retention?

OSHA's general recordkeeping standard, 29 CFR 1910.1020, sets a default of duration of employment plus 30 years for most employee exposure records, but 1910.95 carves out two different, more specific rules for hearing conservation data. Noise exposure measurement records, the dosimetry and sound level survey data used to determine who needs to be in the program, only need to be kept for two years. Audiometric test records get the longer duration-of-employment standard because they document an individual's hearing over time, not a point-in-time measurement of the workplace. The two-year and duration-of-employment rules apply to different documents inside the same program, which is where recordkeeping systems that lump everything under one retention policy tend to get it wrong.

Record type	Retention period	Governing rule
Baseline and annual audiograms	Duration of employment	29 CFR 1910.95(m)
Noise exposure measurements (dosimetry, sound surveys)	2 years	29 CFR 1910.95(m)
General employee exposure/medical records (default)	Duration of employment + 30 years	29 CFR 1910.1020

What happens to audiogram records when an employee leaves or a business is sold?

The retention obligation doesn't disappear when an employee separates or when the business changes hands. OSHA has addressed this directly in standard interpretations: a successor employer that continues the same business operation inherits the recordkeeping obligation for audiometric and exposure records created by the predecessor². In practice, this means an acquisition or an internal reorganization is not a clean break for hearing conservation records, and a company that discards or fails to request audiogram files during a merger can end up unable to produce a departed employee's testing history years later, when it matters most in a hearing-loss claim or an OSHA inspection.

What does this mean for a hearing loss claim or an OSHA inspection years later?

Standard threshold shift claims and workers' compensation hearing loss cases often surface years after the noise exposure occurred, sometimes after the employee has left the company entirely. A complete audiogram history, baseline through the most recent annual test, is what lets an employer show a documented threshold shift was caught, addressed, and followed up on rather than ignored. Without that history, an employer facing a claim has no way to demonstrate when a shift occurred, whether it was work-related, or whether the required follow-up steps, retest, hearing protector refitting, or referral, actually happened. A gap in the audiogram file doesn't just create an inspection finding; it removes the employer's best evidence in a dispute over causation.

How Foster keeps audiogram records retrievable for the life of the employment relationship

When Foster runs a hearing conservation program, each employee's baseline and every subsequent annual audiogram are logged against the same employee record rather than as a stack of loose test-day printouts, so a full testing history is retrievable on request instead of reconstructed from whichever technician's paperwork survived a filing cabinet move. That matters most at the two moments recordkeeping usually breaks down: when an employee who tested years ago separates, and when a customer needs to produce a complete history fast for an inspection or a claim. Foster's records stay matched to the employee for as long as the employer needs them, not purged on a generic document-retention timer that was never built for 1910.95's duration-of-employment requirement.

Foster's on-site hearing testing program keeps baseline and annual audiograms on file per 1910.95's retention rule, and Foster's on-site occupational health testing can combine audiometry with other required annual screenings in one visit. Programs setting up recordkeeping for a new or growing hearing conservation program can start with a quote. For the underlying calculation behind a flagged record, see Foster's post on standard threshold shift calculation.

Frequently Asked Questions

Do audiogram records need to be kept for 30 years like other OSHA exposure records?

No. The 30-year-after-employment default under 1910.1020 applies to most exposure and medical records, but 1910.95 sets a more specific rule for audiometric test records: duration of employment, not a fixed 30-year tail after separation.

How long must noise exposure measurement records be kept, separate from audiograms?

Noise exposure measurement records, such as dosimetry results and sound level surveys, only need to be retained for 2 years under 1910.95, a much shorter period than the duration-of-employment standard for the audiograms themselves.

What happens to audiogram records if the company is sold or merges with another business?

OSHA has ruled that a successor employer continuing the same business operation takes on the recordkeeping obligation for audiometric and exposure records created by the predecessor employer, so the records need to transfer, not be discarded, in a sale or merger.

Can an employer purge an employee's audiogram file after a few years if there's no flagged shift?

No. The duration-of-employment requirement applies regardless of whether a standard threshold shift was ever found. An unremarkable testing history still has to stay on file for as long as the employee remains with the company.

Sources

• OSHA: 29 CFR 1910.95, Occupational Noise Exposure (recordkeeping, paragraph (m))
• OSHA Standard Interpretation: Retention of exposure and audiometric testing records by successor employers