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Every OSHA 1910.95 audiometric testing program requires a Professional Licensed Health Care Professional — a PLHCP — to supervise it. But many employers running hearing conservation programs cannot identify who their PLHCP is, what they are required to do, or whether the person filling that role actually qualifies. This guide covers the PLHCP definition, exactly what the role requires, how liability flows from PLHCP decisions, common program failures, and what employers need to verify.
Soundtrace audiometric testing programs include licensed audiologist PLHCP review of every audiogram — providing the professional supervisory oversight OSHA requires, built into the platform.
OSHA 1910.95 defines a PLHCP as an individual whose legally permitted scope of practice allows them to provide or supervise the provision of audiometric testing services. PLHCP status is determined by two factors simultaneously: the professional’s credentials, and the state in which they practice. Employers operating across multiple states need to verify PLHCP qualification in each jurisdiction.
| Profession | Qualifies? | Key Requirement |
|---|---|---|
| Licensed Audiologist (Au.D. or M.S.) | Yes — primary PLHCP for most HCPs | Active state licensure in the state of practice |
| Physician (M.D. or D.O.) | Yes | Active medical license in state of practice |
| Otolaryngologist (ENT) | Yes — specialist qualification | Active medical license with ENT specialty |
| CAOHC-Certified OHC | No — not a PLHCP | Can conduct testing under PLHCP supervision; cannot serve as the supervising PLHCP |
| Safety Manager / EHS Professional | No | Not a licensed health care professional |
| Nurse Practitioner (NP) or PA | Depends on state scope | State scope must cover audiometric supervision; verify before assuming qualification |
An OHC is a CAOHC-certified technician who conducts pure tone audiometric testing. What OHC certification does not confer is a professional health care license. An OHC who is not also a licensed audiologist or physician cannot serve as the PLHCP. They can conduct the testing; they cannot review the results in the capacity OSHA requires of the professional supervisor.
Many programs have a CAOHC-certified OHC who conducts testing and manages the program — but no licensed PLHCP who reviews the audiograms. Without PLHCP review, the program is non-compliant under 1910.95(g)(3), and any STS determination made without professional review is not OSHA-compliant. This is a common finding in OSHA inspections of mobile van programs.
Required PLHCP duties: review audiograms that show STSs or other clinically significant patterns; make STS work-relatedness determination for OSHA 300 log purposes; make medical referral recommendations when patterns warrant; inform employees about their results; and supervise the overall audiometric testing program for adequacy. These duties cannot be delegated to non-licensed staff or replaced by software.
When age correction is applied to reduce an apparent STS, the decision involves professional judgment about whether the shift pattern is consistent with presbycusis or NIHL. Programs that apply age correction automatically without PLHCP review are cutting corners on a clinical decision.
The PLHCP must evaluate whether a detected STS is clinically meaningful and attributable to occupational noise exposure. This determination has direct OSHA 300 log implications — a confirmed work-related STS at total average threshold ≥25 dB HL is recordable. Software can flag an STS; only the PLHCP can determine whether it is work-related for recordkeeping purposes.
The PLHCP identifies audiogram patterns requiring medical evaluation beyond the standard STS action sequence: sudden unilateral sensorineural hearing loss (urgent ENT within 72 hours); significant asymmetry between ears; rapid threshold deterioration inconsistent with noise exposure rate; low-frequency or flat patterns inconsistent with NIHL; and patterns consistent with ototoxic chemical effects. A program without active PLHCP review will systematically miss these referral triggers.
Beyond individual audiogram review, the PLHCP is responsible under 1910.95(g)(3) for: verifying testing environments meet ANSI S3.1 ambient noise standards; confirming audiometer calibration per ANSI S3.6; ensuring OHCs are trained and certified; reviewing overall STS rates and audiogram trends; and advising the employer when trends suggest the program is not adequately protecting workers.
Common OSHA inspection findings: no identified PLHCP; PLHCP holds CAOHC OHC certification but not a health care professional license; batch review without clinical engagement; automated platforms replacing clinical judgment; no defined referral pathway; PLHCP not informed of worker exposure context. Each represents a documentable compliance gap.
Employers should answer yes to all of these: Can you name the specific licensed professional serving as PLHCP? Is that person’s license current and in the correct state(s)? Does their scope of practice specifically cover audiometric supervision? Are they reviewing individual audiograms, not just batch summaries? Do they receive worker job title and noise exposure context? Is there a defined referral pathway? Are PLHCP review records retained with the audiometric records?
Soundtrace integrates licensed audiologist review into every audiogram — individual clinical evaluation, STS work-relatedness determination, referral documentation, and credential records retained for 30 years.
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