In the United States, when an employee is found to have a Standard Threshold Shift (STS) on the annual audiogram as part of an occupational hearing conservation program, certain evaluation and follow-up actions are required.
- A repeat audiogram is allowed to determine if the STS is still present but must be completed within 30 days.
- If the STS is confirmed or if no retest is completed, and the decrease in hearing results in hearing levels that are consistent with at least a mild hearing loss (25 dB average hearing level), the STS must be recorded on the Occupational Safety and Health Administration (OSHA) Illness and Injury Log (OSHA 300 Log).
These “recordable” hearing loss cases have received some attention since the new rules for recordable hearing loss went into effect in January 2003. Prior to that, hearing loss was lumped in with “Other” illnesses, but now under the revised record keeping Final Rule, hearing loss cases are recorded in a separate column.
In an Oct 2009 Government Accountability Office (GAO) report on “Workplace Safety and Health,” auditors noted that there was pressure on physicians and health care professionals to determine hearing loss as not work-related. The OSHA “Occupational Injury and Illness Recording and Reporting Requirements – Final Rule” states that although work-relatedness is not presumed, the determination of work-relatedness is on a case-by-case basis. So let’s look at some of the issues of recordable hearing loss and decision points that affect the recordability of a hearing loss.