Should We Modernize OSHA’s Hearing Loss Age-Correction Tables?
In a February 2024 interpretation letter, OSHA responded to an important question raised by clinicians from Premise Health: Should employers be allowed to use updated, NHANES-derived age-correction tables instead of OSHA’s outdated 1970s-era version in assessing age-related hearing loss for older workers? The answer, as OSHA laid it out, is nuanced—but undeniably significant for occupational health professionals striving for fairness and accuracy in hearing loss evaluations.
Under OSHA’s Occupational Noise Exposure standard (29 CFR § 1910.95), Appendix F provides age-correction values that employers may use when determining whether a Standard Threshold Shift (STS) in hearing is work-related. The problem? Appendix F ends at age 60—despite the modern workforce increasingly working well into their 60s and 70s. The Premise Health team noted that these outdated tables, based on limited data from the 1970s, don’t reflect current population hearing trends and risk unfairly attributing natural hearing loss to workplace exposures.
Their proposed solution was to adopt the National Health and Nutrition Examination Survey (NHANES) data, which offers more recent and statistically robust information on hearing thresholds across a broader age range. The NHANES dataset includes workers aged 61–75, allowing clinicians to better distinguish between noise-induced hearing loss and presbycusis (age-related hearing loss).
OSHA's response acknowledged the validity of NHANES data—but added critical caveats. Employers may use NHANES-derived tables instead of Appendix F only if the tables are used consistently, calculated from a single dataset, and applied equitably across all workers. A “hybrid” approach—such as using Appendix F for workers under 60 and NHANES for older ones—is explicitly disallowed.
Furthermore, OSHA emphasized that decisions to apply age correction must be made by a qualified professional (audiologist, otolaryngologist, or physician) and must account for the individual’s exposure history, use of protection, and medical background. OSHA also recommends that the same set of age-correction tables be applied beginning with each worker’s baseline audiogram, ensuring fairness and consistency.
Why does this matter? Because the implications reach beyond clinical accuracy—they impact regulatory recordkeeping. Per 29 CFR § 1904.10, employers must log hearing loss cases deemed work-related, and misattributing natural aging effects to workplace exposure can unfairly penalize employers while distorting safety performance data.
It’s also worth noting that NIOSH, in its 1998 criteria document, discourages age-correction altogether in determining STS. NIOSH advocates a shift from merely documenting loss to actively preventing it—arguably the direction hearing conservation should move.
In summary, OSHA’s letter provides a path for updating age-correction practices—grounded in modern data—but with strict conditions to preserve consistency and fairness. For employers and clinicians alike, this represents a pivotal opportunity to modernize hearing conservation efforts, ensuring older workers aren’t penalized for the natural aging process.
