Hearing Conservation Without an Audiologist on Payroll

Your stamping presses spike at 100 dBA, air knives scream at 96 dBA, and the nearest occupational audiologist is fifty miles away. OSHA does not give small employers a pass just because specialists are scarce. The rule is blunt: if employees are exposed to 85 dBA averaged over eight hours, you must run a hearing conservation program. The good news? You can do it with the right partners and disciplined scheduling.

Start With Real Noise Data

Guessing at noise levels is the fastest route to a citation. Rent or purchase integrating sound level meters and dosimeters, or partner with your insurance carrier—they often lend equipment. Sample representative employees for full shifts, capturing tooling changes, maintenance, and startup sequences. Document calibration dates for the instruments and keep raw data. If readings approach or exceed 85 dBA, the action level clock starts ticking. Load the results into a noise map so you can see which areas need permanent signage.

Choose an Audiometric Provider You Can Trust

Mobile audiometric vans and occupational health clinics are lifesavers for small facilities. Vet them like any other contractor. Confirm their audiologists are licensed, that they use calibrated equipment, and that they can send digital records securely. Schedule baseline tests within six months of enrollment and annual follow-ups within one month of the anniversary so you have time to reschedule no-shows. If the provider performs retests for standard threshold shifts (STS), document the rapid turnaround; OSHA expects retests within 30 days.

Align PPE With Reality

Your attenuation claims mean nothing if employees wear earplugs incorrectly. Conduct fit testing or at least observe insertions during training. Offer multiple protection options—foam plugs, reusable plugs, custom-molded plugs, earmuffs—and allow dual protection when exposures exceed 100 dBA. Post signage showing minimum protection requirements per area. Replace PPE before it degrades and track distribution by employee so you can prove everyone received equipment.

Train Like People’s Hearing Depends On It

Annual training must cover the effects of noise, the purpose of audiometric testing, and how to use hearing protectors. Make it real by sharing stories of workers who lost hearing from similar tasks. Demonstrate how to insert earplugs, how to clean earmuffs, and how to report ringing ears. Include supervisors so they can enforce use. Document attendance, topics, and instructors. Worksafely SMB can push refresher assignments automatically, but you still need engaged facilitators.

Manage Medical Records Carefully

Audiometric results are confidential medical records. Store them securely—password-protected folders or the medical section of Worksafely SMB—and limit access. Document STS notifications, follow-up actions, and work restrictions if any. Provide employees copies of their tests and explain the results. When an STS occurs, evaluate whether improved protection, retraining, or administrative controls are needed, and record the decision.

Control Noise at the Source Where Possible

PPE is the last resort. Investigate engineering controls: install mufflers, enclose compressors, balance rotating equipment, or add damping material to chutes. Administrative controls like rotating employees or scheduling loud tasks on off-shifts can reduce exposure, but you must document the schedules that make it work. When you implement a control, resample noise levels to prove the improvement.

Keep the Program Alive

Review exposure data annually, track testing completion rates, and audit PPE compliance. When you buy new equipment, analyze noise specs before installation. The companies that protect hearing do so because they treat the program like any other production-critical process—planned, measured, and relentlessly improved.

Next step: Use the Worksafely SMB noise survey template to schedule dosimetry, track audiometric completion, and store STS letters without drowning in spreadsheets.