The professional supervisor — often called the PLHCP (Physician or Licensed Health Care Professional) in the broader context of OSHA health programs — is the licensed clinician who is responsible for the audiometric testing program under OSHA 1910.95. The PS reviews audiograms, makes medical referral determinations, confirms STS findings, and ensures the program satisfies the standard’s substantive requirements. According to the CDC, approximately 22 million U.S. workers are exposed to hazardous occupational noise annually — and every one of them is supposed to have their audiogram reviewed by a qualified professional supervisor. In practice, many occupational audiometric programs have PS arrangements that don’t satisfy this requirement. This guide explains who can serve as PS, what the role actually requires, and what inadequate PS oversight costs employers.
During an OSHA inspection of a plastics manufacturer, the compliance officer asked to see documentation of the professional supervisor’s credentials. The employer produced a letter from a registered nurse who had been designated to review audiograms annually. Because RNs are not licensed audiologists or physicians, and the employer had no physician oversight of the audiometric program, the PS function did not satisfy 1910.95(g)(3) — which requires a licensed or certified audiologist, an otolaryngologist, or a physician. The STS determinations made under that structure were invalid, triggering a citation for failure to properly implement audiometric surveillance.
Who Can Serve as Professional Supervisor
OSHA 1910.95(g)(3) specifies that the professional supervisor of the audiometric testing program must be one of the following:
- Licensed or certified audiologist: A clinician holding a CCC-A (Certificate of Clinical Competence in Audiology) from ASHA or state licensure as an audiologist
- Otolaryngologist: A board-certified or board-eligible physician specializing in ear, nose, and throat conditions
- Physician: A licensed physician (MD or DO) who has assumed responsibility for the audiometric testing program
The following credentials do not qualify someone to serve as PS:
- Registered nurses (RN, NP) without physician supervision of the audiometric program
- CAOHC-certified occupational hearing conservationists
- Industrial hygienists or safety professionals
- Audiometric technicians with any other certification
The PLHCP role is one of the more ambiguous parts of OSHA’s HCP framework — the standard describes the function clearly but leaves a lot of questions about who exactly can serve it and what their review must include. If you’ve wondered whether your program has the right structure, this is the section to work through carefully.
What the Professional Supervisor Must Actually Do
The PS role under 1910.95 is substantive, not ceremonial. The professional supervisor must:
- Review each employee’s audiogram for evidence of pathological conditions requiring medical referral — asymmetric loss suggesting acoustic neuroma, sudden SNHL, conductive patterns suggesting middle ear disease, rapid progression inconsistent with occupational noise
- Determine or confirm STS findings based on the audiometric data, applying age correction where appropriate and making the judgment calls that software flags but cannot decide
- Make medical referral determinations when audiometric patterns warrant evaluation beyond the occupational audiometric program
- Oversee the overall program to ensure it satisfies 1910.95’s requirements — the PS has program-level responsibility, not just individual audiogram review responsibility
What the PS is not required to do: administer audiometric tests personally. Testing can be conducted by qualified technicians; the PS reviews results. What the PS cannot delegate: the medical judgment functions above.
Common PS Arrangement Deficiencies
The most common professional supervisor deficiencies found during OSHA inspections and program audits:
- Credential mismatch: A non-qualifying credential (RN, NP, CAOHC) is listed as the PS without physician oversight of the audiometric program
- Nominal review: A qualified PS is listed but does not actually review individual audiograms — only STS-flagged cases are brought to the PS’s attention, while others are processed by staff
- Lapsed credentials: The PS’s audiologist license or physician medical license has lapsed or been restricted, but the program documentation has not been updated
- PS unavailability: A PS is designated but has no practical system for reviewing audiograms in a timely manner, resulting in weeks or months of delay between testing and PS review
Remote PS Review: What Satisfies OSHA
OSHA has consistently interpreted the 1910.95 professional supervisor requirement to allow remote review via secure digital platforms. The PS does not need to be physically present at the testing location or the employer’s facilities. What is required:
- The PS must actually review each audiogram — not just receive a summary or flag report
- The PS must have access to the employee’s audiometric history (baseline and all annual audiograms) for context
- The PS must document their review in a way that creates an auditable record that the review occurred
- The platform transmitting audiograms to the PS must satisfy HIPAA requirements for protected health information
Credential Documentation Requirements
Employers should maintain documentation of their PS’s credentials and keep this documentation current:
- Copy of audiologist license or ASHA CCC-A certificate, with expiration date noted and renewal tracked
- For physician PS: copy of medical license and specialty certification where applicable
- Written agreement between the employer and the PS that documents the scope of the PS relationship, the review obligations, and the compensation or service arrangement
- PS contact information current in program documentation
State audiologist licenses typically renew every 2–3 years. Physician medical licenses vary by state. Build credential expiration dates into your HCP calendar and establish a process for verifying renewal before expiration — not after an inspection reveals a lapse.
PS vs. CAOHC-Certified Technician: Different Functions
A common source of confusion is the relationship between the PS and the CAOHC-certified occupational hearing conservationist (OHC). These are different roles with different functions:
| Role | Credential Required | Primary Function | Can Serve as PS? |
|---|---|---|---|
| Professional Supervisor | Licensed audiologist, otolaryngologist, or physician | Medical oversight, pathology review, STS determination, referral decisions | Yes (the PS) |
| CAOHC OHC | CAOHC certification | Audiometric test administration, data collection, training delivery | No |
| Microprocessor audiometer operator | Demonstrated competence (federal OSHA) or CAOHC (OR/WA) | Automated audiometric test administration | No |
Frequently Asked Questions
Only a licensed or certified audiologist, an otolaryngologist, or a physician. No other credential — including CAOHC, RN, NP, or industrial hygienist — qualifies someone to serve as the professional supervisor under 1910.95(g)(3).
Review every audiogram for pathological findings requiring medical referral, confirm or make STS determinations, make medical referral decisions, and exercise overall program oversight. Software can flag; only the PS can decide.
No. CAOHC certification qualifies someone to administer audiometric tests, not to serve as the professional supervisor. The PS must be a licensed audiologist, otolaryngologist, or physician.
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