If an employee hasn’t had a hearing test for many years, can we establish a new baseline?

OSHA says that you may substitute an annual audiogram for the baseline audiogram, if a qualified person (a physician or audiologist) says that there is a standard threshold shift that is persistent or if the hearing threshold in the annual audiogram indicates significant improvement over the baseline audiogram.

However, OSHA doesn’t really address what to do if there has been a long gap between testing periods. OSHA has addressed the issue of what to do in the case of a rehire in a Letter of Interpretation (LOI). That LOI says that as a general rule, the baseline audiogram that is first in time will provide the most accurate information to compare to. Therefore, if you still have the original audiogram, that should be used as the baseline and subsequent audiograms would be compared to that one. If you didn’t keep the original baseline audiogram, then a new one should be taken upon rehire.