What this is
What is the 'action level' under OSHA 1910.95?
What is the 'action level' under OSHA 1910.95?
The action level is 85 decibels as an 8-hour time-weighted average (TWA) — the threshold at which 1910.95 requires a hearing conservation programme: monitoring, audiometric testing, training and available protectors. It sits below the 90 dB(A) permissible exposure limit (PEL), the point at which controls become mandatory rather than merely offered.
What's the difference between a noise survey and dosimetry?
A noise survey maps sound levels across a work area with a handheld meter, to find zones above the action level. Dosimetry measures one worker's cumulative exposure across a shift using a badge-mounted dosimeter — this is what actually determines whether that person needs enrolling in audiometric testing.
What is a standard threshold shift (STS)?
An STS is an average shift of 10 dB or more at 2000, 3000 and 4000 Hz in either ear, against the worker's age-adjusted baseline audiogram. It's the trigger event the plan has to define a response to — retest, refit, or referral — not just a result to file.
Scope
When is a hearing protection program plan required?
This plan sits above individual protectors and hearing tests — it's the programme document, not the record of any one worker's test. Using it to log a single test result or a one-off complaint produces a plan that never closes and a template nobody trusts for its real purpose.
Use this template when
- Noise monitoring has confirmed one or more areas or tasks sit at or above the OSHA action level
- A hearing conservation programme needs to be established, or re-issued at its stated review interval
- Engineering and administrative controls, hearing protectors, audiometric testing and training all need to be tied to one owned, dated plan
- You are running the Safety Programme Management programme and this is one of its named steps
- A linked hearing test record in KnowHealth needs a plan to attach to
Do not use it for
- Safety Management Plan, which sets out how safety is managed across the whole site — roles, processes, resources — not one noise programme within it.
- Annual Safety Objectives, which sets the year's safety goals and targets, not the operating detail of a single hazard programme.
- Safety Program Review, which is where you assess how this plan performed over the year, not where you write the plan itself.
- PPE Program Plan, which covers protective equipment generally; use it for anything not governed by the attenuation and fit-testing rules here.
- Anything outside KnowSafe — audiometric results themselves belong in KnowHealth, not in this plan.
Compliance mapping
Which OSHA 1910.95 requirements does this satisfy?
OSHA 1910.95 sets out a hearing conservation programme, not a single form — the clauses map its obligations onto the plan's five sections.
| Clause | Requirement | Where it lands |
|---|---|---|
| 1910.95(c) | Establish and maintain a hearing conservation programme wherever exposure is at or above the 85 dB(A) action level | Header |
| 1910.95(d) | Monitor noise exposure and identify employees whose exposure requires enrolment in the programme | Noise exposure |
| 1910.95(d)(3) | Use monitoring methods, including dosimetry, covering continuous, intermittent and impulsive noise | Noise exposure |
| 1910.95(b)(1) | Use feasible engineering or administrative controls to reduce exposure before relying on personal protective equipment | Control before protection |
| 1910.95(i)(1) | Make hearing protectors available, at no cost, in a variety of suitable types | Protection |
| 1910.95(i)(3) | Ensure attenuation is adequate for the employee's exposure, without over-protecting to the point of isolating them from warnings | Protection |
| 1910.95(g) | Provide an audiometric testing programme, including baseline and annual audiograms, at no cost to the employee | Surveillance and training |
| 1910.95(g)(6) | Define and follow a procedure when a standard threshold shift is identified | Surveillance and training |
What it does not cover
- Areas Above Action Level recorded as zero while Highest Exposure dB sits at or over 85, which means the monitoring data and the trigger for the whole programme don't agree with each other.
- Engineering Controls Considered left at Fail with no entry in Controls Implemented, which reads as noise reduction that was never actually looked at, not a controls hierarchy that was run and rejected.
- Fit Testing Provided marked Fail while protectors are still recorded as Available At Zone Entrances, which means workers are being handed protection nobody has confirmed fits them.
- Threshold Shift Response Defined marked Partial with no CAPA raised through Action Required, which leaves a detected hearing change with no committed next step.
- Next Review Due left blank or past its own date, which turns a live programme document into an expired one nobody is accountable for re-issuing.
Global
Hearing Protection Program Plan requirements by country
OSHA 1910.95 is US federal law, but where a site sits changes what this plan has to satisfy.
29 CFR 1910.95
The baseline this template is built against: 85 dB(A) TWA action level, 90 dB(A) PEL, and the full hearing conservation programme once triggered.
Use the plan largely as issued; scoring and clause references line up directly with the federal standard.
State plans approved under OSHA, e.g. Title 8 CCR Section 5095–5100
State plans must be at least as effective as federal OSHA and can add requirements — some set extra recordkeeping or notification duties beyond 1910.95.
Check the state plan's own hearing conservation section before treating this plan as complete; a pass against federal OSHA may not satisfy the state's extra duty.
Local noise-at-work regulation, e.g. the Control of Noise at Work Regulations 2005 (UK), implementing EU Directive 2003/10/EC
Many jurisdictions set lower action levels — 80/85 dB(A) exposure action values under the UK regulations, against OSHA's single 85 dB(A) level — and use different exchange rates for averaging.
Treat OSHA 1910.95 as a reference architecture, not applicable law; re-set the thresholds behind Areas Above Action Level and Highest Exposure dB to the local instrument first.
How to complete it
How to complete a hearing protection program plan, step by step
Four judgement calls decide whether this plan defends the programme, or just documents a filled-in form.
Engineering Controls Considered, Buy Quiet Policy In Place and Noise Zones Signed only mean something together. A plan scoring well on protection while these sit at Partial or Fail hasn't reduced noise at source — it has substituted PPE for the harder work upstream.
Over Protection Avoided exists because more attenuation isn't automatically better — a protector rated well beyond measured exposure can cut a worker off from alarms and reversing vehicles. The call is whether attenuation was set against actual Highest Exposure dB, not whatever the supplier had in stock.
Baseline Tests Completed and Annual Tests Current confirm testing happened. Threshold Shift Response Defined is harder — whether a detected shift moves into a retest, refit or referral, tracked through Action Required and CAPA ID, rather than sitting as a number nobody revisits.
Noise Survey Current and Next Review Due decide whether the plan is still trustworthy. One built on a survey from before a line change or process redesign defends against a noise environment that no longer exists, however complete every other field looks.
What auditors find
Most common hearing protection program plan findings
These patterns recur across plans that pass their own scoring but wouldn't survive a regulator walking the floor.
| Finding | Clause | What fixes it |
|---|---|---|
| Areas Above Action Level and Workers Above Action Level are populated, but Engineering Controls Considered is Fail with Controls Implemented blank. | 1910.95(b)(1) | Record what engineering or administrative options were assessed — enclosure, isolation, quieter equipment, job rotation — and why each was ruled out or scheduled, before relying on protectors alone. |
| Protection Selected By Attenuation passes, but Over Protection Avoided is left at Not considered. | 1910.95(i)(3) | Compare the protector's rated attenuation against Highest Exposure dB explicitly — don't let a high-NRR protector pass by default. |
| Fit Testing Provided is marked Fail or Partial, but Available At Zone Entrances still records Yes. | 1910.95(i) | Suspend the Yes on availability until fit testing closes, or restrict availability to the types already fit-tested. |
| Audiometric Testing Programme In Place is Yes, but Baseline Tests Completed is No for workers already above the action level. | 1910.95(g) | Sequence enrolment so a baseline audiogram exists before, or within the regulatory window after, first exposure — an annual test with no baseline has nothing to compare against. |
| Threshold Shift Response Defined is marked Partial, and Action Required is left at No despite the Partial score. | 1910.95(g)(6) | Treat a Partial or Fail on the response definition as its own action — raise it through Action Required with a CAPA ID and owner, not just a lower score. |
| Training Provided Annually is Partial, with no Course ID entered and no CAPA raised. | 1910.95(k) | Link the course record through Course ID, and if training lapsed for part of the workforce, raise the action rather than let the Partial score stand alone. |
Case in point
Case in point: the plan that passed while the programme failed
A site issued its hearing protection plan at rollout with a clean survey, full protector availability and passing scores throughout. Eighteen months later an audiometric retest turned up three threshold shifts on the same line — the line that had added a second stamping press nine months after the plan was issued and never been re-surveyed.
Every field in the original plan was still technically true. Noise Survey Current had simply never been asked again, because Next Review Due matched the annual cycle rather than any trigger tied to a process change. The fix wasn't a new template — it was treating a line change as its own review trigger, not waiting for the calendar.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
5 sections
- Reference
- SAF-126
- Archetype
- Plan
- Record ID
- HPP-2026-000
- Scoring
- Not scored
- Direction
- n/a
- Singleton
- No
- Basis
- OSHA 1910.95
- Links
- Links KnowHealth hearing records
- Tags
- Programme, Noise
- Sections
- 5
- Fields
- 41
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 5
Header
9 fieldsPlan ID*
Auto sequence. Format HPP-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Plan Version*
Issue Date*
Next Review Due*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Plan Owner*
Approved By*
Noise exposure
6 fieldsNoise Survey Current*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Survey ID
Links to HLT-030 Survey ID
Areas Above Action Level*
Highest Exposure dB*
Workers Above Action Level*
Dosimetry Completed*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Control before protection
6 fieldsReduce The Noise First
Hearing protection is the last step. Enclosure, damping, isolation and quieter equipment all come first and protect everyone rather than one person.
Engineering Controls Considered*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Controls Implemented
Buy Quiet Policy In Place*
- Yes3 pts
- Informally1 pt
- No0 pts
Noise Zones Signed*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Exposure Time Limited Where Possible*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Protection
6 fieldsProtection Selected By Attenuation*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Over Protection Avoided*
Too much attenuation isolates workers from alarms and warnings.
- Yes, attenuation matched3 pts
- Not considered0 pts
Choice Of Types Offered*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Fit Testing Provided*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Fit Check ID
Links to HLT-029 Check ID
Available At Zone Entrances*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Surveillance and training
14 fieldsAudiometric Testing Programme In Place*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Baseline Tests Completed*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Annual Tests Current*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Threshold Shift Response Defined*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Training Provided Annually*
- Pass2 pts
- Partial1 pt
- Fail0 pts
- N/Aexcluded from denominator
Course ID
Links to FDN-007 Course ID
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Plan Owner*
Signature*
Occupational Health*
Second Signature*
SAF-126 · record IDs look like HPP-2026-000 · Links KnowHealth hearing records
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The form is the easy part. Keeping the survey current, closing out threshold shifts and holding the evidence trail together against real audiometric data is the work that actually slips.
Holds the plan against its review interval, flags when Noise Survey Current has gone stale relative to a process change, and keeps Engineering Controls Considered from being skipped in favour of protectors.
Runs the audiometric testing itself — baseline and annual audiograms — and surfaces a threshold shift back to this plan the moment it's recorded, instead of leaving it in a health record nobody in safety opens.
Tracks who's actually completed annual hearing conservation training against the roster exposed above the action level, and ties Course ID back to a real, dated course record rather than a name in a text box.
Coordinates the crew across KnowSafe and KnowHealth, rolls open threshold shifts and overdue reviews into one view, and holds every write for your approval before it touches a record.
This template lives in KnowSafe — safety and compliance. Incidents, hazards, permits, inspections and the critical controls behind them.
Meet KnowSafe→Glossary
Hearing Protection Program Plan definitions and key terms
- Action level
- The exposure threshold — 85 dB(A) as an 8-hour time-weighted average under OSHA 1910.95 — at which a hearing conservation programme becomes mandatory, even though hearing protection itself isn't yet required at this level.
- Permissible exposure limit (PEL)
- The 90 dB(A) TWA ceiling under 1910.95 above which hearing protectors must be worn and feasible engineering or administrative controls must be applied, not merely offered.
- Dosimetry
- Personal exposure measurement using a badge-mounted dosimeter worn across a shift, distinct from an area noise survey taken with a handheld meter.
- Standard threshold shift (STS)
- An average shift of 10 dB or more at 2000, 3000 and 4000 Hz in either ear against a worker's age-adjusted baseline audiogram — the trigger event for a defined follow-up response.
- Attenuation
- The noise reduction a hearing protector provides, typically expressed as a Noise Reduction Rating (NRR); matching it to actual exposure — not maximising it — is the point of Over Protection Avoided.
FAQ
Frequently asked questions about hearing protection program plan
What is the hearing protection program plan template based on?+
It's built against OSHA 1910.95, the US federal standard for occupational noise exposure — covering the action level, monitoring, audiometric testing and hearing protectors. Outside the US, treat it as a reference architecture and re-set the thresholds to the local regulation.
What sections does the template contain?+
Five: Header, Noise exposure, Control before protection, Protection, and Surveillance and training. Together they hold 41 fields, most required, moving from monitoring data through the controls hierarchy to protector selection and audiometric surveillance.
How often is a hearing protection program plan raised?+
A new plan is raised when the programme is first established, and re-issued at its stated review interval — plus whenever a survey, process change or line addition means the existing plan no longer describes the environment it controls.
Does hearing protection replace the need for engineering controls?+
No — 1910.95(b)(1) puts feasible engineering and administrative controls first. The Control before protection section exists so a plan can't score well on protectors while skipping the harder work of reducing noise at source.
What happens when a worker has a standard threshold shift?+
The plan has to define a response — typically retest, refit or referral — through Threshold Shift Response Defined, tracked via Action Required and CAPA ID. A shift that's recorded but not actioned is the most common gap in these programmes.
Can the template be changed?+
Yes. Every field, option, score and conditional rule is editable, and the link to KnowHealth hearing records comes with it. Most teams install it as issued, run it for a cycle against real audiometric data, then adjust the scoring.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Safety Programme Management
Regulatory Inspection Record
Records a visit by a regulator, including what was inspected, what was said and any orders issued
Management Review Record
Records the periodic review of the management system by senior leadership, covering performance, risks, resources and improvement
Interested Party Register
Holds the parties whose needs shape the management system, from regulators and customers to neighbours and the workforce
Safety Management Plan
Sets out how safety is managed across the site, covering roles, processes, resources and how performance is measured
Annual Safety Objectives
Sets the safety goals for the year with measures, owners and target dates
Safety Program Review
Reviews how a specific programme, such as PPE or working at height, is performing
More in Programs
Safety Management Plan
Sets out how safety is managed across the site, covering roles, processes, resources and how performance is measured
Annual Safety Objectives
Sets the safety goals for the year with measures, owners and target dates
Safety Program Review
Reviews how a specific programme, such as PPE or working at height, is performing
Site Safety Rules
The short list of rules everyone on site must follow, including visitors and contractors
PPE Program Plan
Sets out what protective equipment is required for which task, how it is selected, issued, maintained and replaced
Contractor Safety Plan
Sets out the safety requirements contractors must meet on your site, and how they are checked
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- OSHA 1910.95 — Occupational noise exposure
- OSHA 1910.95(g) — Hearing conservation amendment: audiometric testing
- ANSI/ASA S12.6 — Methods for measuring the real-ear attenuation of hearing protectors
- Control of Noise at Work Regulations 2005 (UK), regs 5–10
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.