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One of the most commonly misunderstood provisions in OSHA’s hearing conservation standard is who is permitted to conduct audiometric testing. Many employers and safety professionals assume that audiometric testing requires a CAOHC-certified occupational hearing conservationist (OHC). This is not correct — and the distinction matters significantly for how employers structure their audiometric testing programs. OSHA 1910.95(g)(3) creates two separate pathways depending on the type of audiometer used, and for microprocessor audiometers, it explicitly replaces the certification requirement with a “demonstrated competence” standard.
Soundtrace satisfies OSHA’s demonstrated competence standard through its own documented training program for its cloud-connected microprocessor audiometer, with Dr. Subinoy Das serving as the licensed audiologist professional supervisor for the program.
29 CFR 1910.95(g)(3): Audiometric tests shall be performed 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, or by a technician who satisfactorily demonstrates competence in administering audiometric examinations — with that second category applying when microprocessor audiometers are used.
OSHA’s audiometric testing personnel requirements at 1910.95(g)(3) create a tiered structure based on the type of audiometer used:
| Audiometer Type | Permitted Technician | Credential Required |
|---|---|---|
| Manual audiometer | Licensed/certified audiologist, otolaryngologist, or physician | State licensure or board certification required |
| Manual audiometer | Technician | CAOHC certification (COHC) required |
| Microprocessor audiometer | Licensed/certified audiologist, otolaryngologist, or physician | State licensure or board certification required |
| Microprocessor audiometer | Technician | Demonstrated competence only — CAOHC not required |
The distinction exists because a microprocessor audiometer automates the judgment-intensive portions of the test. In manual audiometry, the technician makes real-time decisions about tone presentation, threshold bracketing, and response validity. These decisions require the clinical training that CAOHC certification is designed to provide. In microprocessor audiometry, the equipment handles these functions automatically — reducing the technician’s role to patient instruction, equipment setup, flagging obvious problems, and escalating to the professional supervisor when needed.
OSHA’s use of the term “microprocessor audiometer” in 1910.95(g)(3) refers to self-calibrating, self-recording audiometers that automate the test presentation and threshold-determination process. Key features that characterize a microprocessor audiometer for OSHA purposes:
Cloud-connected audiometric platforms like Soundtrace’s Type 4 microprocessor audiometer meet this definition. The device presents tones, tracks responses, calculates thresholds, and transmits results to the cloud portal without requiring the test administrator to manually control each step. This is what enables the demonstrated competence pathway.
OSHA does not define “demonstrated competence” with a specific curriculum, minimum hours, or examination requirement. This is intentional — the standard recognizes that microprocessor audiometer operation is equipment-specific, and that what constitutes competence will vary depending on the complexity and design of the specific device used.
In practice, demonstrated competence for microprocessor audiometer operation encompasses the ability to:
What demonstrated competence does not require is the ability to interpret audiometric results clinically — to determine STS, evaluate work-relatedness, or make referral decisions. Those functions belong to the professional supervisor.
Because there is no third-party certification to point to, the employer’s documentation of demonstrated competence is the compliance record. This should include: a description of the training provided, the equipment covered, the date and duration of training, and a record of who completed it. Training provided by the audiometric testing vendor — and documented in the vendor’s program materials — satisfies this requirement when it covers the competency elements above.
OSHA 1910.95(g)(3) requires that the audiometric testing program be “supervised or reviewed” by a licensed or certified audiologist, otolaryngologist, or other physician — regardless of whether a microprocessor or manual audiometer is used. This is the professional supervisor (PS) requirement, and it is not waived by the use of a microprocessor audiometer or the demonstrated competence pathway.
The PS’s responsibilities in a microprocessor audiometry program include:
The PS does not need to be present at each individual test session. In a cloud-based audiometric program, the PS reviews results remotely through the program’s portal as audiograms are completed and transmitted. This is the model that makes nationwide audiometric programs scalable without requiring a credentialed audiologist at every testing location.
Several state plan states have adopted requirements that go beyond federal OSHA 1910.95 with respect to audiometric technician qualifications:
| State | Additional Requirement | Notes |
|---|---|---|
| Oregon | CAOHC certification required for technicians regardless of audiometer type | OR-OSHA has not adopted the federal demonstrated competence exception for microprocessor audiometers |
| Washington | CAOHC certification required for technicians regardless of audiometer type | WAC 296-817 requires COHC certification; the federal microprocessor exception does not apply |
| Texas | Audiometric technician registration required for private employers | Separate from CAOHC; applies under state health department rules, not OSHA jurisdiction |
Federal workplaces located within Oregon and Washington are governed by federal OSHA, not OR-OSHA or WISHA, and therefore the federal demonstrated competence pathway applies to them regardless of state plan requirements. Private employers in these states must comply with their state plan requirements, which means CAOHC certification is effectively required for technicians regardless of the audiometer type used.
For employers evaluating audiometric testing vendors, the distinction matters practically:
Neither is inherently superior from a compliance standpoint for the microprocessor pathway — a vendor whose technicians have CAOHC certification and use microprocessor audiometers is compliant, as is a vendor whose technicians have demonstrated competence through documented training on their specific equipment. The key is that one or the other applies, the documentation exists, and the PS oversight requirement is met regardless.
Soundtrace’s audiometric testing program operates under the demonstrated competence pathway of 1910.95(g)(3). The program uses a cloud-connected Type 4 microprocessor audiometer — a self-calibrating, self-recording device that automates tone presentation and threshold determination. Client facility staff who administer tests complete Soundtrace’s documented training program, which covers equipment operation, patient instruction, daily calibration verification, recognition of invalid results, and escalation procedures.
Dr. Subinoy Das, a licensed audiologist, serves as the Professional Supervisor for Soundtrace’s hearing conservation programs. All audiograms are transmitted to the Soundtrace cloud portal, where they are reviewed by the PS team. STS determinations, work-relatedness evaluations, and referral decisions are made by licensed audiology staff through the portal — not by the on-site test administrator. This division of responsibilities — demonstrated competence for equipment operation, licensed professional oversight for clinical judgment — is exactly the model OSHA’s 1910.95(g)(3) structure is designed to support.
▶ Bottom line: The CAOHC requirement applies to manual audiometry technicians. For microprocessor audiometers, demonstrated competence — documented by the testing program — is the OSHA standard. The PS oversight requirement applies regardless of which pathway is used.
Soundtrace’s cloud-connected platform satisfies OSHA’s demonstrated competence standard through documented training, with a licensed audiologist professional supervisor reviewing every audiogram through the cloud portal.
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