Opening a letter from Cal/OSHA about an employee noise complaint gets your attention fast. The clock is ticking. You need to respond. But where do you start? 

This happens more often than you might think. Manufacturing plants, glass recyclers, food processors, and other California industrial facilities face this situation every year. The good news? With the right approach, you can address the regulatory concern and often strengthen your hearing conservation program in the process. 

Here’s what you need to know. 

First: Take a Breath, Then Get Organized 

Cal/OSHA takes noise complaints seriously. So should you. But “quickly” doesn’t mean “recklessly.” 

Before anything else, gather what you know: 

• The complaint itself. What was alleged? Noise in a specific area? Missing hearing protection? No audiometric testing? 

• Your current hearing conservation program. Do you have one? When did you last update it? Does it match your current facility layout and equipment? 

• Recent changes. Have you added equipment, changed layouts, or modified operations since your last noise survey? 

• Existing data. When was your last noise survey? Do you have dosimetry records? 

This information helps a consultant scope the work properly and spot any obvious gaps. 

The Two-Phase Approach 

Experienced consultants don’t just show up with dosimeters and start measuring. They work in two phases — and understanding this helps you budget and set realistic timelines. 

Phase 1: Walk-Through and Planning 

The first step is a qualitative assessment: 

• Walk through your facility to observe operations and identify noise sources 

• Talk to employees — they know where the loud spots are and whether current conditions are typical 

• Review your documentation — hearing conservation program, past surveys, audiometric records 

• Conduct preliminary screening — using sound level meters to get a general picture 

This phase answers key questions: Which areas need detailed monitoring? Is that machine running normally or unusually loud today? What gaps exist in your current program? 

The result is a tailored sampling plan. You focus resources where they matter instead of monitoring areas that clearly aren’t a concern. 

Phase 2: Formal Monitoring and Reporting 

With a plan in place, the consultant returns with calibrated dosimeters for formal noise monitoring. This gives you legally defensible data to: 

• Determine actual employee noise exposure levels 

• Identify who belongs in your hearing conservation program per Cal/OSHA Section 5097 

• Document compliance — or develop a corrective action plan 

• Respond to Cal/OSHA with professional findings 

Hearing Conservation Program 

California employers must establish a Hearing Conservation Program whenever employee noise exposure meets or exceeds an 8‑hour time‑weighted average (TWA) of 85 dBA.  A Hearing Conservation Program consists of: 

• Noise monitoring 

• Audiometric testing 

• Employee training 

• Providing hearing protection 

When is Hearing Protection Required 

Employers are required to make hearing protection available for employees exposed to 85 dBA. Employers must require hearing protection at 90dBA for most employees, but employees  who have not completed a baseline audiogram yet or have a documented hearing loss (a standard threshold shift) must wear hearing protection at 85 dBA. The problem: Managing different thresholds for different employees is a headache. Who’s been tested? Who hasn’t? Who had a threshold shift two years ago? 

The solution: Make 85 dBA your company threshold for everyone. You meet Cal/OSHA requirements, eliminate tracking complexity, and simplify your program management. A small additional investment in hearing protection pays off in easier administration and fewer compliance gaps. 

OSHA vs. NIOSH Standards 

Your consultant may ask which measurement standard to follow: OSHA or NIOSH. 

OSHA is the regulatory requirement. Following OSHA standards means you’re measuring to the legal threshold. 

NIOSH is more conservative. The National Institute for Occupational Safety and Health recommends lower limits than OSHA requires. 

Unless your company has corporate policies requiring NIOSH, most California facilities follow OSHA. It meets regulatory requirements and provides clear, defensible documentation. 

Think Beyond the Immediate Problem 

A Cal/OSHA complaint is stressful. It’s also an opportunity. 

Once you’ve addressed the regulatory concern, consider: 

Update your hearing conservation program. If your facility has changed since your last survey — new equipment, different layouts, modified operations — your program may be outdated. Use this as a trigger to bring everything current. 

Apply findings across locations. If you have multiple facilities with similar operations, what you learn at one site can inform improvements at others. A thorough assessment at one location often leads to standardized approaches you can roll out more efficiently across your footprint. 

Build ongoing monitoring into your calendar. Annual noise monitoring catches issues before employees file complaints. Facility conditions change. Stay ahead of them. 

The Bottom Line 

A Cal/OSHA noise complaint is manageable. The keys: 

1. Gather your documentation before engaging a consultant 
2. Work with experienced professionals who understand California’s specific requirements 
3. Take a phased approach — assess first, then conduct targeted monitoring 
4. Simplify where you can — the 85 dBA standard for everyone eliminates management headaches 
5. Use this as a catalyst for broader program improvements 

Done right, you resolve the immediate issue and end up with a stronger, more defensible hearing conservation program. 

For detailed regulatory requirements, see Cal/OSHA’s Occupational Noise regulations (Article 105) and their Hazardous Occupational Noise Guide. 

Get a Free Noise Compliance Assessment 

Not sure where you stand? CDMS offers a free initial assessment for California facilities facing noise complaints or looking to strengthen their hearing conservation programs. 

We’ve helped manufacturers, distributors, and industrial facilities navigate Cal/OSHA requirements for over 35 years. We understand the urgency when that letter arrives — and we’re set up to respond quickly with technically sound results. 

Request Your Free Assessment — We’ll review your situation, identify gaps, and outline a clear path forward. 

 

CDMS provides EHS compliance services to industrial facilities throughout California. Our industrial hygiene services include noise monitoring, hearing conservation program development, and employee training.