Record

For general industry, employers should keep an accurate record of noise exposure measurements and audiometric test records for the duration of employment of the employees who are in the hearing conservation program.

The types of hearing test records to be retained include:

• Name and classification of the employee
• Date of the audiogram
• The examiner’s name
• The date of the last calibration of the audiometer
• The employee’s most recent noise exposure assessment
• Measurements of background sound levels in room where audiometric testing is done

Access to all records must be provided to employees, former employees, representatives of employees and OH&S inspectors. When ownership of the company changes or employees are transferred to a new employer, the noise exposure and hearing test records described above must be transferred to the successor employer.

Workers who suffer noise-induced hearing loss related to their employment can make a claim for compensation under their State or Federal Workers Compensation Legislation.

Most decisions made by the people who manage HLPPs are dependent on the quality of the data kept by the employer. When the data contain errors or there is excessive variability, it can lead decision makers to doubt the accuracy of the records and make it difficult to confidently manage their program. To help prevent that from happening, establish a robust process for keeping records and verify that the key people in the program are following that process. Each person who has access to HLPP records should be trained to look for indications that records are not accurate or do not reflect what has been done to implement the program.  In addition, make sure to consult with your legal advisor to ensure that all applicable government rules and regulations are followed with respect to storage, access to, and transmission of personal and health information.

Records are most useful when they are complete and have been kept consistently over time. This is especially critical when it comes to audiometric test data. If the audiometric records indicate that an employee has experienced a Standard Threshold Shift (STS), the employer must conduct follow-up actions. If the STS is potentially recordable, key information is needed to determine if the hearing shift is due, at least in part, to workplace noise exposure. Missing records, inaccurate information, or gaps in the data make it very difficult for the audiologist or physician who reviews the records to make that decision, and the employer may have no other option than to assume that the hearing loss is work-related.

Although the security of records must be maintained, employers must make key records available to employees, their representatives, members of the hearing loss prevention team, and inspectors or representatives of regulatory agencies. To help maintain control of documents, establish a system in which a limited number of people who have direct access to the records can share copies of documents with others who need to view them.

Records of noise exposure measurements and hearing test records be retained for the duration of employment plus 30 years.

Consider keeping other records for the same period of time, including those related to:

• Employee training
• Hearing protector fit testing
• Noise control projects
• Otoscopic results
• Audiometric technician certification

There is health data privacy legislation in place under the Health Information Privacy Code. All health records need to be kept confidential and treated according to the requirements of this legislation.