OSHA 29 CFR 1910.95(g)(3) establishes the “demonstrated competence” standard for audiometric testing operators. For microprocessor audiometers — automated instruments that present tones and record responses without per-test clinician involvement — this means the operator can correctly administer the test, maintain the environment, and ensure protocol compliance. CAOHC certification is not required. According to CDC/NIOSH, approximately 22 million U.S. workers require annual occupational audiometric surveillance, and understanding what OSHA actually requires for testing personnel determines who can legally administer these tests.
Demonstrated Competence: What OSHA Actually Says
OSHA 1910.95(g)(3) allows audiometric testing to be “administered by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC), or who has demonstrated competence in administering audiometric examinations.”
The critical language: “or who has demonstrated competence.” CAOHC certification and demonstrated competence are parallel paths, not sequential requirements. An employer can use a non-CAOHC-certified operator who has demonstrated competence in the specific audiometric equipment and protocol being used.
The demonstrated competence standard applies to audiometric test administrators — the people who run the test sessions. It does not apply to the Professional Supervisor, who must be a licensed audiologist, otolaryngologist, or other physician regardless of what testing equipment is used or how the test was administered. CAOHC certification does not qualify a person to serve as Professional Supervisor; only a professional license does.
What Demonstrated Competence Requires
Soundtrace training satisfies the demonstrated competence standard. For operators of Soundtrace’s Type 4 automated microprocessor audiometer, competence documentation includes:
- Training on proper test setup and worker instruction
- Correct administration of the daily biologic check
- Verification that the test environment meets ANSI S3.1-1999 requirements before testing
- Ability to identify and address test environment issues that might invalidate results
- Understanding of record retention and transfer requirements
Regardless of the competence path used — CAOHC certification or employer-documented demonstrated competence — maintain records of operator training and qualifications. In OSHA inspections and WC proceedings, the operator’s qualifications may be questioned. Training records showing what the operator was trained on, by whom, and when provide the documentation trail to establish competence.
Frequently Asked Questions
Demonstrated Competence Training + Licensed Audiologist PS Review
Soundtrace training satisfies OSHA’s demonstrated competence standard for microprocessor audiometer operators — with Dr. Rivka Strom, licensed audiologist, serving as Professional Supervisor for all result reviews.
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