Every occupational hearing conservation program needs someone responsible for making it actually run: scheduling audiometric testing on the 12-month cycle, managing enrollment as new workers are hired, coordinating with the professional supervisor on STS cases, maintaining records, and ensuring training is delivered on schedule. This coordinator role is not defined as a specific position by OSHA — but the functions it encompasses are all legally required, and when no one owns them, they fall through the cracks.
Soundtrace automates the most time-consuming coordinator functions — scheduling notifications, STS flags, 300 Log tracking, and training reminders — so that the coordinator can focus on the human judgment aspects of program management.
When HCP coordination is treated as a peripheral responsibility rather than a defined function with clear ownership, audiograms slip past their 12-month window, STS notifications are delayed, enrollment gaps accumulate, and training records become unreliable. The coordinator role is not a formality. It is the operational spine of the program.
The Coordinator Role: Scope and Authority
The HCP coordinator is the operational hub of the hearing conservation program. They do not make clinical determinations — that is the PLHCP’s role — but they manage every process that makes clinical determinations possible: ensuring workers are enrolled, tested on schedule, notified when required, equipped with hearing protection, trained annually, and that all of this is documented in a way that would survive an OSHA inspection or workers’ compensation discovery request.
Coordinator vs. PLHCP: Different Responsibilities
The most important boundary in the HCP coordinator role is the line between operational coordination and clinical determination. The coordinator does not make STS determinations, does not assess work-relatedness, and does not make medical referral decisions. These are PLHCP functions that require a license.
| Function | Coordinator | PLHCP (Professional Supervisor) |
|---|---|---|
| Schedule audiometric tests | Yes — core coordinator function | No (unless also conducting tests) |
| Confirm STS determination | No — PLHCP only | Yes — required by 1910.95(g)(7) |
| Send STS notification to employee | Yes — after PLHCP confirms STS | No |
| Determine work-relatedness | No — PLHCP only | Yes — required by 1904.10 |
| Enter 300 Log hearing loss cases | Yes — based on PLHCP determination | No |
| Manage HPD inventory and dispensing | Yes — core coordinator function | No |
| Deliver or schedule annual training | Yes — core coordinator function | No |
| Maintain audiometric records | Yes — core coordinator function | No |
Managing Enrollment: Who Is In and Who Should Be
The coordinator maintains the enrollment roster and ensures it reflects the current workforce. Enrollment is required for all workers exposed at or above 85 dBA TWA. Key enrollment management tasks include: new hire enrollment with baseline scheduling within 6 months; tracking workers moved from low-noise to high-noise roles; and knowing whose HCP program covers contractors and staffing agency workers in noise-exposed areas.
Audiometric Testing Scheduling: The 12-Month Window
Every enrolled worker must receive an annual audiogram within 12 months of their previous audiogram. The coordinator must track individual testing dates, generate reminders before windows expire, and reschedule workers who miss their testing appointment before their window closes.
A worker tested on March 15 has until March 15 of the following year for their next audiogram — not the end of the calendar year. Coordinating multiple workers across different original test dates requires systematic tracking rather than a calendar-year approach. Missed windows are a citation item.
Hearing Protection Management
The coordinator manages the HPD program: ensuring adequate supply of approved devices, maintaining dispensers, coordinating fit testing, and tracking which device each enrolled worker is using. When a worker receives an STS notification and requires HPD refitting or upgrading, the coordinator ensures this happens within the 21-day window and documents the response.
Training Administration
OSHA 1910.95(k) requires annual training for all workers enrolled in the HCP. The coordinator must ensure every enrolled worker receives training each year, maintain records of completion, and have documentation available for OSHA inspection. Training content must cover the effects of noise on hearing, the purpose of audiometric testing, HPD selection and use, and HCP program requirements.
STS Follow-Up Coordination: The 21-Day Clock
Recordkeeping
The coordinator maintains the audiometric records required by OSHA 1910.95(m): employee audiograms (retained for employment duration plus 30 years), noise exposure measurements (retained for 2 years), and other program records. The recordkeeping system must support employee access to their own records within 15 working days of a written request.
Frequently asked questions
Automate the Operational Burden of HCP Coordination
Soundtrace handles audiometric scheduling, STS flagging, PLHCP review routing, and training reminders automatically — so your coordinator spends time on program quality, not manual tracking.
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