Record keeping

Keep records to prevent noise-induced hearing loss.

Keeping accurate and complete records is more than a legal requirement; it's good business.

Have we documented what has been done to prevent noise-induced hearing loss?

  • Hearing Loss Prevention Program

    When employers document how and when they implemented each of the elements of a Hearing Loss Prevention Program (HLPP), they are better abled to demonstrate compliance with Physical Agents (Noise) Directive 2003/10/EC.

    In addition, good records may provide evidence to help an employer accurately track employees' hearing over time and, if necessary, record cases of work-related noise-induced hearing loss and/or respond to worker compensation claims.

Key Takeaways

    • Proper documentation of the steps taken to prevent noise-induced hearing loss (NIHL) benefits both the employer and the noise-exposed worker.
    • Complete and accurate records are needed to determine whether hearing threshold shifts are work-related.
    • Physical Agents (Noise) Directive 2003/10/EC require employers to document outcome of appropriate risk assessment including exposure measurement along with details of health surveillance.
    • Good recordkeeping makes it easier for employers to evaluate the effectiveness of their HLPP.

Getting Started with Recordkeeping

  • Many companies adopt a philosophy of, “document everything” while others keep records of only what is required. Despite the extra effort required to document all the actions that have been taken to reduce employee exposure to hazardous noise, doing so may help to strengthen the employer's ability to demonstrate the effectiveness of its hearing conservation program in the event of an inspection, audit, or program evaluation.

  • Consider whether hearing conservation program records will be maintained electronically or on paper or both and whether records will be held in a central database or at each location. A well-defined process that is consistently followed helps to reduce the likelihood of missing records and may increase the usefulness of the data.

  • For each type of information that is included in HCP records, the employer needs to decide who is responsible for capturing the data and who will be able to view the records once they are saved. Limiting access to records to those who have a need to review data for program management purposes helps reduce the possibility that records are compromised in some way or that data are inadvertently modified or deleted.

  • Since hearing conservation program records may include confidential health information, it is recommended that these records be protected to help protect the privacy of individual workers and assure that only those who have the proper credentials have access to sensitive data. In addition, there may be applicable data or health privacy regulations governing the storage, access to, or transmission of information, so make sure to contact your legal advisor and ensure full compliance with any such rules and regulations.

What is required?

Generally speaking, records of health surveillance for individual worker should be kept in accordance with national law or medical practice. Example of what should be considered include:

  • Up-to-date summary of any previous health surveillance records
  • Availability of data for future reference
  • Ensuring strict confidentiality between employee and medical practitioner
  • Accessibility of personal data to whom it relates

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

Basics of Recordkeeping

The benefits obtained when employers carefully record what they are doing to prevent hearing loss are, in large part, proportional to the accuracy, completeness and accessibility of the documents.

  • Accuracy

    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 programme. 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.

  • Completeness

    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 change in hearing threshold, the employer may wish to conduct follow-up actions. 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.

  • Accessibility

    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.

Beyond the Basics

  • Record Retention

    Typically, records of noise exposure measurements and hearing test records are retained for indefinite period.


    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 (where relevant)


  • Health Information Privacy

    National laws define how health information must be protected and how employers and health care providers may share confidential health information. Always consult your national law for data protection guidelines.


    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.

Have You Considered?

    • Conducting periodic audits to identify gaps in program records?
    • Creating a central database of HLPP documents from all locations within your company to allow accessibility to key people?
    • Establishing a document request system to allow those who need to review key records to obtain access to them?
    • Securing the audiometric data with routine back-ups and long term storage and accessibility?


This information is based on selected current national requirements. Other country or local requirements may be different. Always consult User Instructions and follow national regulations. This website contains an overview of general information and should not be relied upon to make specific decisions. Reading this information does not certify proficiency in safety and health. Information is current as of the date of publication, and requirements can change in the future. This information should not be relied upon in isolation, as the content is often accompanied by additional and/or clarifying information. All applicable national laws and regulations must be followed.

Contact your local 3M office for further information.