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OSHA 1910.95 is explicit on one point most employers underestimate: audiometric testing alone does not constitute a compliant hearing conservation program. A Professional/Licensed Health Care Professional — the PLHCP — must review audiograms, determine Standard Threshold Shifts, assess work-relatedness for OSHA 300 log purposes, and make medical referral decisions. Software can flag a threshold change. Only a licensed PLHCP can determine what it means clinically and legally.
Soundtrace includes professional audiologist (PLHCP) review with every audiometric testing program — built in, not bolted on. Every audiogram receives documented PLHCP review before results are finalized.
OSHA 1910.95(g)(3) requires that audiograms be reviewed by a physician or other qualified professional. 1910.95(g)(7) requires that the professional determine whether an STS represents an OSHA-recordable case. An employer who conducts audiograms without a PLHCP relationship has a hearing testing program — not a compliant hearing conservation program under 1910.95.
OSHA 1910.95 defines the professional supervisor as “a physician or other licensed health care professional whose scope of practice permits them to provide or direct the audiometric testing requirements of this section.” In practice: audiologists (Au.D. or Ph.D.) are fully qualified; occupational medicine physicians and ENTs are fully qualified; general practice physicians are qualified; nurse practitioners or PAs are state-dependent; CAOHC-certified OHCs are not PLHCPs; and non-licensed safety managers are not PLHCPs regardless of experience.
Core required PLHCP functions: review annual audiograms vs. baseline; determine Standard Threshold Shifts; determine work-relatedness of any STS for OSHA 300 log purposes; determine whether medical pathology is indicated by the audiogram pattern; recommend follow-up actions; and review baseline audiograms for quality. These functions cannot be performed by software alone, the OHC, or the employer.
Automated STS calculation software can flag when the mathematical threshold for an STS is met. It cannot determine whether the shift is clinically meaningful, whether it is attributable to occupational noise or another cause, whether the pattern suggests a non-noise medical condition requiring referral, or whether the baseline was contaminated by TTS. These determinations require a licensed professional.
| Function | OHC (Technician) | PLHCP (Professional) |
|---|---|---|
| Credential | CAOHC certification | State professional license (audiologist, physician, or qualifying scope) |
| Conduct audiometric test | Yes — primary OHC function | Yes, but typically delegates testing to OHC |
| Review audiogram results | Administrative review only | Required clinical review |
| Determine STS exists | Can perform calculation; cannot make clinical determination | Required — clinical judgment applied to threshold data |
| Determine OSHA 300 recordability | Cannot — requires PLHCP work-relatedness determination | Required under 1910.95(g)(7) |
| Recommend medical referral | Cannot — outside scope of practice | Required when audiogram pattern indicates pathology |
An employer who uses an OHC to conduct testing and treats the OHC’s administrative review as the required professional review has a fatal compliance gap. When OSHA inspects, the absence of documented PLHCP review is a Serious citation. When a worker files a WC claim, the absence of PLHCP-documented review means no professional clinical documentation of what the audiometric record showed.
When an annual audiogram shows threshold change at the STS frequencies, the PLHCP evaluates whether it represents a genuine STS or a testing artifact. Considerations: did the worker complete the 14-hour quiet period (TTS can produce apparent shifts that resolve on retest); is the shift pattern consistent with NIHL; is the shift symmetric or asymmetric; has there been a change in exposure conditions? The PLHCP either confirms the STS or determines retesting is appropriate within the 30-day OSHA window.
Recordability requires two conditions: (1) the STS is work-related — occupational noise is the predominant cause rather than age, medical conditions, or non-occupational exposure; and (2) the worker’s average threshold at 2000/3000/4000 Hz in the affected ear is 25 dB HL or greater. Work-relatedness is a clinical judgment only the PLHCP can make — and it requires access to the worker’s noise exposure history and prior audiometric records.
For the PLHCP to correctly determine work-relatedness, the employer must provide the worker’s TWA noise exposure data, prior audiometric records, and information about any known non-occupational exposures or medical history relevant to hearing. PLHCP review without this context cannot support a valid work-relatedness determination.
Beyond the standard STS action sequence, the PLHCP should recommend medical referral for: sudden sensorineural hearing loss; significant asymmetric loss not explained by asymmetric noise exposure; low-frequency loss inconsistent with NIHL; progressive loss despite documented noise controls; and patterns consistent with Meniere’s disease, acoustic neuroma, or other ENT conditions. The employer provides this referral at no cost to the employee; the employer receives only a written opinion about risk and HPD limitations.
The PLHCP relationship does not satisfy the employer’s independent obligations: notify the worker within 21 days of confirming an STS; ensure the PLHCP has access to the exposure and audiometric records needed for valid determinations; retain PLHCP review documentation in the audiometric file; act on PLHCP recommendations; and record confirmed work-related STSs on the OSHA 300 log when the recordability conditions are met.
| Failure | Why It Creates Liability | Correction |
|---|---|---|
| No PLHCP relationship at all | 1910.95(g)(3) Serious citation; STS determinations have no legal standing | Establish written agreement with qualified audiologist or physician for all program audiograms |
| OHC review treated as PLHCP review | Same as no PLHCP — OHC is not licensed to make clinical determinations | Separate OHC testing from PLHCP review; document each separately |
| PLHCP review conducted without exposure data | Work-relatedness determination is invalid for 300 log purposes | Provide PLHCP with TWA data, prior audiometric history, and occupational history for each review |
| PLHCP review not documented in writing | Undocumented review is legally non-existent | Require written PLHCP review documentation for every audiogram, retained in the audiometric file |
| STS confirmed but 21-day notification missed | Employer violation of 1910.95(g)(8) | Automated STS flagging and employer notification workflow; document notification date |
Every audiogram in the Soundtrace platform receives documented audiologist review with the full exposure and audiometric context needed for valid STS and work-relatedness determinations.
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