Audiogram Review: Who Qualifies as a Reviewing Professional?

Who is qualified to review an audiogram under OSHA rules?

29 CFR 1910.95 allows four types of professionals to review problem audiograms: an audiologist, an otolaryngologist (an ear, nose, and throat physician), another physician, or a Certified Occupational Hearing Conservationist (COHC) working under the supervision of an audiologist or physician. A technician who administers the hearing test is not automatically qualified to review it — the review step exists specifically to add a second, more credentialed set of eyes on any audiogram that shows a problem. Employers should confirm which category their reviewing professional falls into and keep that credential on file, since an inspector checking program validity will ask who signed off on flagged results and under what authority.

Which audiograms actually require professional review?

Not every audiogram needs to go to a reviewing professional. The trigger is a standard threshold shift (STS) — an average 10 dB or greater worsening at 2000, 3000, and 4000 Hz in either ear compared to the baseline — or any audiogram the testing technician otherwise flags as abnormal. A clean annual test that shows no shift and no unusual pattern typically doesn't require referral; the review requirement is built to catch the results that suggest either noise-induced hearing loss in progress or a non-occupational condition that needs medical attention. Programs that route every audiogram to a reviewing professional regardless of result aren't wrong, just spending more than the standard requires.

What does the reviewing professional actually check?

The reviewer's job is to determine whether the STS is work-related, whether it could be caused by something other than occupational noise (a medical condition, an outside injury, or normal aging), and whether the employee needs additional testing or referral for otologic or audiologic evaluation. This review pulls in more than the numbers on the audiogram — the reviewer typically wants exposure history, the employee's prior audiograms, and any medical history relevant to hearing. A reviewing professional who only sees a single audiogram in isolation, without baseline comparison or exposure context, can't reliably make that call, which is why employers need a process for getting the right records to the reviewer, not just the test result.

Reviewer type	Scope of authority	Typical role in the process
Audiologist	Full audiogram review and referral authority	Reviews STS cases, determines work-relatedness, refers for further evaluation
Otolaryngologist / physician	Full audiogram review and referral authority	Same as audiologist, plus direct medical evaluation if needed
COHC	Review under supervision only	Screens results and flags cases per protocol set by the supervising audiologist/physician
Testing technician	No independent review authority	Administers the test, flags obvious problems for referral

What happens after a professional confirms a standard threshold shift?

Once the reviewing professional confirms a work-related STS, several things follow: the employer must notify the employee in writing within 21 days, and unless the reviewing professional determines the STS is not work-related or not likely to worsen, the employer has to ensure the employee is fitted with (or refitted and retrained on) hearing protectors, and evaluate whether those protectors need to be adjusted or replaced. A recordable STS also gets logged on the OSHA 300 log if it meets the 1904.10 recording criteria — a 10 dB shift from baseline at the specified frequencies, averaged, in either ear. None of these downstream steps happen without the reviewing professional's sign-off, which is why a program with no clear review pathway ends up sitting on unresolved STS cases.

How does Foster route audiograms for professional review?

Foster's testing technicians flag any audiogram showing a potential STS or an otherwise abnormal pattern at the point of testing, rather than leaving that determination for a batch review days later. Flagged results, along with the employee's baseline and prior-year audiograms, go to the supervising audiologist for review, and the employer gets the outcome — confirmed STS, not work-related, or needs further evaluation — back in time to meet the 21-day notification clock. For employers who want documentation of who reviewed what and when, Foster keeps the reviewing professional's credentials and sign-off on file alongside the test records, so that piece of the audit trail doesn't have to get reconstructed after the fact.

What does an inspector ask about the review process?

An OSHA inspector auditing a hearing conservation program typically asks two things about audiogram review: who is doing it, and can the employer produce evidence of that person's qualification (license, certification, or documented supervision arrangement for a COHC). The second thing an inspector checks is timing — whether STS notifications went out to employees within the 21-day window, since a confirmed shift with no documented notification is a straightforward citation. Employers who can't identify their reviewing professional by name, or who can't show the review actually happened for a specific flagged audiogram, have a program gap that shows up quickly under inspection.

Frequently Asked Questions

Can the same person administer the test and review it?

No — the technician administering the test is not a substitute for the reviewing professional; even a COHC review must happen under the supervision of a qualified audiologist or physician, not as a standalone function of the testing tech.

Does every STS have to go to an audiologist or physician, or can a COHC handle it?

A COHC can review under supervision per the protocol the supervising professional sets, but the ultimate determination of work-relatedness and any referral decision needs to trace back to that supervising audiologist or physician.

What if the reviewing professional determines the STS isn't work-related?

If the reviewing professional documents that the shift is not work-related or not likely to progress, the employer isn't required to provide the follow-up notification and hearing-protector actions that a confirmed work-related STS triggers — but the determination and its basis should still be documented in the employee's record.

Foster Special Instruments provides on-site audiometric testing and hearing conservation program management, including audiologist-supervised review of flagged results. See the baseline audiogram rules for how the reference point behind every STS determination gets set. Request a quote for program setup.