Who Can Legally Perform an OSHA Audiometric Test?

A safety manager who just failed an audit finding often asks the same question first: was the person running our audiograms even qualified to do it? OSHA's noise standard answers that directly. Under 29 CFR 1910.95(g)(3), an audiometric test must be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is either certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC) or who has satisfactorily demonstrated competence in administering the test, obtaining valid results, and maintaining the audiometer. Two paths, not one, and employers routinely assume only the first one exists.

What does OSHA actually require of the person giving the hearing test?

The technician has to be qualified under one of two routes written into 1910.95(g)(3): CAOHC certification, or demonstrated competence to a supervising audiologist, otolaryngologist, or physician. Either path satisfies the standard on its own. CAOHC certification comes from completing an approved course and exam; demonstrated competence is a judgment call the supervising professional makes and documents. OSHA does not rank one above the other, and an inspector asking "who gave this test" is satisfied by evidence of either path, not a search for a CAOHC card specifically.

What does CAOHC certification involve?

CAOHC certification requires completing a 20-hour council-approved course covering ear anatomy, audiometer calibration checks, test administration, audiogram interpretation basics, and recordkeeping, per the council's own OHC certification guidance. The credential is called Occupational Hearing Conservationist (OHC) and runs for five years before an 8-hour recertification course is due. It is the more durable qualification because it travels with the technician across employers and equipment, and it is the credential OSHA names explicitly in the regulatory text, which makes it the easiest to defend during an inspection without additional documentation.

What counts as "demonstrated competence" instead?

Demonstrated competence is the standard's second, less-defined path: a technician who hasn't completed CAOHC coursework can still administer tests if a supervising audiologist, otolaryngologist, or physician has evaluated and documented that the person can run the specific audiometer correctly, obtain valid thresholds, and perform the required daily functional and periodic calibration checks. OSHA's 2017 standard interpretation on technician training requirements confirms this path exists independently of CAOHC and does not require a fixed course length, only that the supervising professional's sign-off reflects real evaluation. The risk is that "demonstrated competence" with no supporting documentation is functionally unprovable later, which is why most employers default to CAOHC certification rather than build and defend their own competence file.

CAOHC certification vs. demonstrated competence

Factor	CAOHC certification (OHC)	Demonstrated competence
Who determines qualification	CAOHC exam and course completion	Supervising audiologist, otolaryngologist, or physician
Duration	5 years, then 8-hour recertification	No fixed term; tied to the supervising professional's documentation
Portability	Travels with the technician across employers	Typically specific to one employer's equipment and sign-off
Audit defensibility	Single credential document, easy to produce	Requires the underlying competence evaluation record

Does a microprocessor audiometer change who can operate it?

Yes, and this is the exception that trips up the most employers. Under 1910.95(g)(3), an operator of a microprocessor audiometer, meaning an automated instrument that presents tones and records thresholds without a technician manually tracking the exam, is not required to hold CAOHC certification at all. The standard treats the automation as reducing the skill the operator needs to exercise during the test itself. That exception does not remove every requirement: someone still has to perform and document daily functional checks and periodic exhaustive calibration, and an audiologist or physician still has to review the results. It only removes the CAOHC-or-demonstrated-competence gate for the person pressing the buttons.

Who reviews the results once the test is administered?

Administering the test and reviewing the result are two different roles under the standard. The technician's qualification covers running the audiometer and getting a valid threshold; a separate review by an audiologist or physician is required to determine whether a Standard Threshold Shift occurred and what follow-up the employee needs. A CAOHC-certified technician is not automatically qualified to make that clinical call, and most OHC training explicitly stops short of it. Employers who conflate "the technician who ran the test" with "the person who decided the result was fine" are describing two steps the standard keeps separate.

How Foster handles this

Every technician on our mobile testing teams holds current CAOHC OHC certification, and we track each person's five-year renewal individually rather than certifying a crew once and losing track of who's actually still current. We run mobile hearing testing and on-site testing across Ohio, Kentucky, and Indiana out of Cincinnati, and because our audiometers go through calibration on the same cycle CAOHC training covers, the technician administering the test and the equipment producing the result are both verifiably current at the same time. We don't rely on the microprocessor exception to skip certification; our techs are trained on the specific instruments they run, which matters when a result gets challenged and someone asks who administered it and how they were qualified. A test that gets flagged later for a possible threshold shift, covered in our post on standard threshold shift calculation, is only as defensible as the qualification behind the original test.

Frequently asked questions

Can a technician without CAOHC certification legally give an OSHA hearing test?

Yes, if a supervising audiologist, otolaryngologist, or physician has evaluated and documented that the technician has demonstrated competence in administering the test and maintaining the audiometer. CAOHC certification and demonstrated competence are parallel, not sequential, requirements under 1910.95(g)(3).

Does CAOHC certification expire?

Yes. OHC certification is valid for five years and must be renewed through an 8-hour CAOHC-approved recertification course before it lapses.

Do microprocessor audiometer operators need any qualification at all?

They're exempt from the CAOHC-or-demonstrated-competence requirement specifically, but someone still has to perform and document daily functional checks, and an audiologist or physician still has to review the results for a possible threshold shift.

Can the technician who gives the test also be the one who reviews it for a threshold shift?

No. Administering the test is a technician-level qualification; determining whether a Standard Threshold Shift occurred is a review step reserved for an audiologist, otolaryngologist, or physician.

Sources

• 29 CFR 1910.95: Occupational Noise Exposure (OSHA, current)
• OSHA Standard Interpretation: Occupational noise exposure training requirements for technicians (2017-10-13)
• Why You Need an Occupational Hearing Conservationist (CAOHC)