Every occupational hearing conservation program requires two distinct roles that many employers conflate: the technician who administers audiometric tests, and the licensed professional who reviews results and makes clinical determinations. Understanding the difference between these roles — what CAOHC certification is, when it is and isn’t required under OSHA, and how the professional supervisor requirement works — is fundamental to running a compliant hearing conservation program.
Soundtrace satisfies both roles in every program: competency-trained operators administer tests using certified microprocessor audiometry equipment, while licensed audiologists serve as professional supervisors reviewing every audiogram for STS, work-relatedness, and clinical flags.
The most common hearing conservation compliance failure is not failing to conduct audiograms — it is conducting audiograms without a licensed professional supervisor reviewing results. A program coordinator or safety manager who reviews software alerts without PLHCP oversight has an audiometric testing program, not an OSHA-compliant hearing conservation program.
What CAOHC Certification Is
The Council for Accreditation in Occupational Hearing Conservation (CAOHC) is an independent organization that certifies occupational hearing conservationists (OHCs). CAOHC certification requires completing an approved training course that covers audiometric testing techniques, equipment operation, noise measurement, hearing protection, and basic audiogram interpretation for referral purposes. Certified OHCs recertify every 5 years.
CAOHC certification demonstrates competence in audiometric test administration — not in clinical interpretation. An OHC is trained to conduct tests reliably; they are not licensed to determine whether a threshold shift is clinically significant, work-related, or requires medical referral. Those determinations belong to the professional supervisor.
What OSHA Actually Requires
OSHA 1910.95(g)(3) states that audiometric tests must be performed by a licensed or certified audiologist, otolaryngologist, or other qualified physician, or by a technician who is “certified by the Council for Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining, and checking calibration and proper functioning of the audiometers being used.”
Two things are notable about this language. First, CAOHC certification is one path to qualification, but not the only one — demonstrated competence is an alternative. Second, this provision addresses who can conduct tests, not who can review and interpret them. Review and interpretation require a professional supervisor under 1910.95(g)(7).
Microprocessor Exception: When CAOHC Is Not Required
For programs using microprocessor audiometers (Type 4 audiometers), OSHA 1910.95(g)(3) provides additional flexibility. The regulation recognizes that microprocessor audiometers automate many of the test administration functions that CAOHC certification addresses — tone generation, response recording, threshold determination — reducing the skill requirement for the test operator. For these systems, an operator who has demonstrated competence in operating the device and documenting test conditions satisfies the standard without CAOHC certification.
Microprocessor Audiometer (Type 4)
OSHA recognizes reduced operator skill requirement
Demonstrated competence standard applies (not CAOHC required)
Soundtrace operates Type 4 microprocessor audiometers; operators are competency-trained per 1910.95(g)(3)
Professional supervisor review still required for all results
Conventional Pure-Tone Audiometer
Higher operator skill required — manual tone presentation, response assessment
CAOHC certification or equivalent demonstrated competence required
Operator must manage test validity, masking, and response reliability manually
Professional supervisor review still required for all results
The Professional Supervisor: Always Required
Regardless of what type of audiometer is used, and regardless of whether the test administrator is CAOHC-certified, a professional supervisor must review audiograms under 1910.95(g)(7). This review requirement cannot be satisfied by software flags, threshold calculation algorithms, or program coordinators reviewing reports — it requires a licensed physician, audiologist, or equivalent professional.
An employer who conducts annual audiograms using a microprocessor audiometer operated by a trained technician, but who has no relationship with a licensed physician or audiologist to review results, has a testing program — not an OSHA-compliant HCP. OSHA 1910.95 requires the professional supervisor to confirm STSs, determine work-relatedness, and make referral decisions. Software cannot do this. An OSHA inspection that reveals no PLHCP involvement is a citation regardless of how many audiograms were conducted.
OHC vs. PLHCP: Summary
| Function | OHC / Test Administrator | PLHCP / Professional Supervisor |
|---|---|---|
| Conduct audiometric tests | Yes — core function | Can, but not required to conduct tests directly |
| Confirm STS determination | No — not authorized | Yes — required by 1910.95(g)(7) |
| Determine work-relatedness | No — not authorized | Yes — required by 1904.10 |
| Make medical referral decision | No — not authorized | Yes — required by 1910.95(g)(8) |
| Credential required | CAOHC cert or demonstrated competence | State license as physician or audiologist |
| Can work remotely? | Yes (for remote audiometer monitoring) | Yes — OSHA does not require physical presence for review |
Frequently asked questions
Both Roles Built Into Every Soundtrace Program
Soundtrace provides competency-trained test administration AND licensed audiologist PLHCP review as standard — not separate add-ons. Every audiogram receives documented professional supervisor review before results are finalized.
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