When your hearing conservation vendor returns the annual audiogram results, what comes back is not just a set of numbers — it is a PLHCP report containing clinical language that directly determines your specific OSHA obligations for each worker. Safety managers who can parse these findings accurately know exactly what follow-up is required. Safety managers who can’t are at risk of missed notifications, undocumented referrals, and OSHA 300 Log entries that were never made. This guide translates every common PLHCP finding into plain-English employer obligations.
Soundtrace provides PLHCP-reviewed audiometric reports with findings translated into specific employer action items — so the compliance step is never in question.
The PLHCP reviews audiometric results and provides findings. They determine whether an STS occurred, whether it appears permanent, whether it appears work-related, and what follow-up is recommended. The employer is responsible for the compliance actions that follow. A PLHCP recommendation is not self-executing — the 21-day notification clock, the HPD refitting, and the 300 Log entry are employer obligations.
Who Is the PLHCP?
Under 29 CFR 1910.95, the Professional Licensed in Health Care Practice (PLHCP) is the physician or audiologist responsible for reviewing occupational audiometric test results and providing the employer with specific findings and recommendations. The PLHCP may be a licensed physician, otolaryngologist, or certified audiologist. The occupational hearing conservationist (OHC) who conducts testing is a different person — the OHC administers the test, the PLHCP provides the official findings the employer must act on.
What the PLHCP Reviews and Determines
For each audiogram, the PLHCP evaluates: STS status (did a 10 dB or more average shift occur at 2000/3000/4000 Hz?); work-relatedness (is the loss attributable to occupational noise, affecting OSHA 300 Log recordability?); need for medical referral (does the audiogram show asymmetric loss, sudden changes, conductive components, or low-frequency patterns requiring physician evaluation?); and baseline revision recommendation (should the baseline be updated upward or downward?).
Anatomy of a PLHCP Report
A standard PLHCP report contains five sections: (1) STS finding — whether a shift occurred and whether it appears permanent; (2) work-relatedness determination — affects 300 Log recording; (3) medical referral recommendation — required after confirmed STS, recommended for unusual patterns; (4) baseline revision recommendation — employer’s decision to execute; (5) additional clinical notes — asymmetry, low-frequency involvement, conductive findings.
Finding Decoder: Common Results Translated
| PLHCP Language | Plain English | Mandatory Actions | Timeline |
|---|---|---|---|
| “No STS. Within normal limits.” | Hearing unchanged from baseline | None | File in record |
| “STS confirmed. No revision recommended.” | Permanent 10+ dB shift; PLHCP not recommending baseline update | Notify; refit HPDs; evaluate 300 Log | Notify within 21 days |
| “STS confirmed. Baseline revision recommended.” | Confirmed permanent shift; PLHCP recommends updating baseline | All STS actions + execute revision if chosen; document | Notify within 21 days |
| “STS confirmed. Medical referral recommended.” | Confirmed shift with audiogram pattern warranting physician evaluation | All STS actions + arrange physician referral | Notify within 21 days; referral promptly |
| “Apparent STS; recommend retest.” | Shift detected but may reflect TTS or variability | Notify; refit HPDs; retest within 30 days | Notify within 21 days; retest within 30 |
| “STS resolved on retest.” | Original shift was TTS or variability, not permanent | No 300 Log required; file retest; consider HPD review | File and document |
| “Asymmetric sensorineural loss. Medical referral advised.” | One ear significantly worse; raises concern for non-noise causes | Arrange physician/otolaryngologist evaluation; document outcome | Promptly |
| “Low-frequency hearing loss noted. Medical referral recommended.” | Low-frequency loss suggests non-noise cause requiring evaluation | Medical referral; document; determine work-relatedness after evaluation | Promptly |
| “Conductive component present. Refer for medical evaluation.” | Middle ear pathology (treatable, not NIHL) needs physician review | Refer to physician/ENT; document; do not count as noise-related STS until cleared | Promptly |
| “Work-relatedness cannot be determined without further evaluation.” | Physician evaluation needed before employer can determine 300 Log recordability | Refer to physician; defer 300 Log entry until determination made | Within reasonable time |
| “Consistent with noise-induced pattern. No current STS.” | 4 kHz notch visible, but no shift from baseline yet | No immediate OSHA action; review HPD program; monitor closely | Program review |
STS Findings in Detail
Four STS variants: (A) Confirmed permanent — notify within 21 days, refit HPDs, evaluate 300 Log, refer if shift persists; (B) Apparent STS, retest recommended — notify within 21 days (still required), refit HPDs, retest within 30 days; (C) Confirmed + medical referral — all Variant A actions plus required physician referral promptly; (D) Confirmed but non-work-related — notify within 21 days and refit HPDs still required, but no 300 Log entry, document PLHCP determination.
Medical Referral Findings: Required vs. Recommended
OSHA requires referral when an STS is confirmed on the 30-day retest or no retest is conducted. PLHCP-recommended referrals (for asymmetric loss, conductive components, low-frequency patterns) are not strictly required by OSHA but should be treated as effectively required: ignoring a written recommendation in the audiometric file creates documented liability if the worker later develops a related condition or files a WC claim.
If a PLHCP recommends medical referral in writing and the employer does not act, a documented recommendation sits in the audiometric file with no corresponding action. In a WC claim or OSHA investigation, that gap is visible and damaging. Treat every written PLHCP recommendation as a required action until documented as complete.
Non-Work-Related Determinations
A non-work-related determination eliminates the 300 Log recording obligation only. The STS notification (within 21 days), HPD refitting, and retraining obligations apply regardless of work-relatedness. The PLHCP’s clinical reasoning must be documented — a bare “non-work-related” notation without reasoning is harder to defend in an OSHA review or WC claim.
Baseline Revision Recommendations
The PLHCP’s recommendation does not automatically revise the baseline. The employer must make a deliberate decision and document it. Revision upward (confirmed PTS) resets the STS calculation reference; revision downward (improvement confirmed on retest) corrects a previously contaminated baseline. See the baseline contamination guide for the downstream consequences of each option.
Employer Action Matrix
| PLHCP Finding | Notify worker | Refit HPDs | 30-day retest | Med. referral | 300 Log eval |
|---|---|---|---|---|---|
| No STS | — | — | — | — | — |
| STS confirmed | ✓ 21 days | ✓ | Optional | ✓ if persists | ✓ |
| Apparent STS, retest recommended | ✓ 21 days | ✓ | ✓ 30 days | If persists | After retest |
| STS + medical referral | ✓ 21 days | ✓ | Optional | ✓ required | ✓ |
| STS, non-work-related | ✓ 21 days | ✓ | Optional | If noted | ✗ no entry |
| Asymmetric loss, no STS | — | — | — | ✓ recommended | — |
Documentation Requirements
The audiometric file must contain: worker name, job classification, and noise exposure data; all audiograms; PLHCP written findings for each audiogram; records of all employer actions taken in response (notification dates, HPD refitting dates, referral dates and outcomes); baseline revision documentation; and OSHA 300 Log entries for recordable cases.
Every PLHCP finding creates a documentation obligation. Notify: document the notification date. Medical referral recommended: document the referral and outcome. Baseline revision: document the decision and basis. The audiometric file should allow a third party to reconstruct exactly what the PLHCP found and exactly what the employer did in response, with dates.
Frequently Asked Questions
PLHCP-Reviewed Results with Clear Action Items
Soundtrace provides audiometric results reviewed by licensed audiologists, with each finding translated into specific employer actions.
Get a Free Quote- NIHL: The Occupational Employer Guide
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