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CAOHC certification gets mentioned constantly in hearing conservation — in vendor proposals, OSHA standards, and audiometric testing company marketing. But most employers don’t know exactly what it requires, when it’s legally mandatory, and when OSHA explicitly doesn’t require it. Here’s what matters for your program.
Soundtrace’s platform operates under OSHA’s microprocessor audiometer framework, with built-in professional supervision by licensed audiologists — ensuring certification requirements are met without requiring employers to independently source and manage technician credentials.
CAOHC — the Council for Accreditation in Occupational Hearing Conservation — is the non-profit organization that develops standards and administers certification programs for hearing conservation professionals. Founded in 1973, its certifications are the most widely recognized credentialing system in the field.
CAOHC offers two primary certifications relevant to employer programs: the Occupational Hearing Conservationist (OHC), a trained technician certified to conduct audiometric testing; and the Certified Professional Supervisor of Audiometric Monitoring (CPS/A), an audiologist or physician certified in occupational hearing program oversight. CAOHC also certifies Course Directors who teach OHC training courses.
▶ Bottom line: CAOHC certification is the industry’s credentialing standard for hearing conservation technicians — but it exists alongside, not as a replacement for, the OSHA-required professional supervision structure.
Under 29 CFR 1910.95(g)(3), audiometric tests must be performed by: a licensed or certified audiologist; an otolaryngologist or physician; a CAOHC-certified technician; or a technician who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using and maintaining audiometers.
That fourth option — “demonstrated competence” — is not a loophole. It reflects OSHA’s recognition that CAOHC coursework is one pathway to competence, not the only one.
The critical exception follows immediately in the standard: “A technician who operates microprocessor audiometers does not need to be certified.” This exception is significant. Automated microprocessor audiometers walk employees through the test without requiring real-time technician intervention — the automation ensures protocol adherence. Operators of these systems do not need CAOHC certification under federal OSHA.
The microprocessor exception eliminates the operator certification requirement — not professional oversight. OSHA still requires a licensed audiologist, otolaryngologist, or physician as professional supervisor of the overall program regardless of audiometer type or technician credentials.
▶ Bottom line: The microprocessor exception doesn’t remove professional oversight from your program. It removes the certification requirement for the person pressing the button.
The most common program structure error is conflating the testing operator with the professional supervisor.
The OHC role is the day-to-day testing function: preparing equipment, preparing employees, administering the test, performing basic audiogram review, and documenting results. CAOHC certification for this role is required for manual audiometer operators and optional for microprocessor audiometer operators under federal OSHA.
The Professional Supervisor role is filled by a licensed audiologist, otolaryngologist, or physician. This person oversees the entire program, reviews problem audiograms, makes STS and recordability determinations, and is ultimately responsible for the clinical validity of every audiogram produced. This role cannot be filled by an OHC technician — it requires a licensed professional.
The CPS/A designation is a voluntary additional credential for professional supervisors indicating advanced training in occupational audiometric program management. Not all professional supervisors hold CPS/A certification, but the credential signals deeper program oversight expertise.
▶ Bottom line: Your OHC tests. Your professional supervisor decides. Every hearing conservation program needs both functions covered — and they cannot be the same person unless that person is a licensed audiologist or physician who also conducts the tests.
| Scenario | CAOHC OHC Required? | Notes |
|---|---|---|
| Manual audiometer (conventional) | Yes (or demonstrated competence) | Technician must be CAOHC-certified or equivalent |
| Microprocessor (automated) audiometer | No under federal OSHA | Explicit exception; professional supervisor still required |
| Washington state programs | Yes regardless of audiometer type | WA L&I plan is stricter than federal OSHA |
| Oregon state programs | Yes regardless of audiometer type | OR OSHA plan requires certification for all operators |
| MSHA-covered mining operations | Consult 30 CFR § 62.150 | Different from OSHA 1910.95; verify applicable rules |
| FRA-covered transportation | Yes | Federal Railroad Administration programs require CAOHC |
Washington and Oregon are particularly important for multi-state employers. Both operate state OSHA plans with stricter requirements: CAOHC certification is required for technicians operating microprocessor audiometers, eliminating the federal OSHA exception. Employers with facilities in these states must ensure their in-house operators meet this higher standard regardless of audiometer type.
▶ Bottom line: Always verify requirements against the specific OSHA plan governing your facilities. The microprocessor exception applies under federal OSHA — state plans in Washington and Oregon require certification regardless.
OHC certification expires exactly 5 years from date of issuance. Renewal requires completion of a CAOHC-approved update course (minimum 8 hours), taken before the certificate expires. If already expired, a full re-certification course is required — not just the update.
This expiration structure creates a compliance risk that multi-site programs frequently miss. An OHC whose certification expires mid-year and continues conducting manual audiometric tests after expiration is conducting tests without required credentials. The audiograms may be invalid, creating retroactive compliance gaps requiring retesting of every employee tested after the expiration date.
Maintain a credential tracking system with automatic alerts 60–90 days before any OHC certificate expires. For programs using microprocessor audiometers under the federal OSHA exception, operator certification tracking is not required — but professional supervisor licensure still needs active tracking.
▶ Bottom line: An expired OHC certificate can retroactively invalidate every audiogram that person conducted after expiration — requiring retest of all affected employees. This is an HR issue with material OSHA compliance consequences.
Employers need clear answers to four questions about their program:
1. What type of audiometer does your program use? Manual or microprocessor? The answer determines whether CAOHC certification is required for operators under federal OSHA rules.
2. Which OSHA plan governs your facilities? Federal OSHA applies in most states, but Washington, Oregon, and five other states operate their own plans. Know which rules apply at each location.
3. Who is your licensed professional supervisor? Non-negotiable under OSHA regardless of audiometer type. Do you know who this person is, and can you document that relationship with credentials on file?
4. How are you tracking credentials and renewals? Whether OHC certifications for manual testing operators or professional supervisor licensure, credential expiration tracking needs an owner in your organization.
Programs using integrated digital hearing conservation platforms typically have professional supervision built into the service agreement — the provider maintains the audiologist network, eliminating the need for employers to independently source and contract a professional supervisor.
Soundtrace programs include licensed audiologist oversight, automated compliance tracking, and microprocessor audiometer technology — so certification requirements are handled without employers needing to independently manage technician credentials.
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