OSHA Audiometric Testing: Who Can Give the 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 is OSHA audiometric testing?

OSHA audiometric testing is the hearing test program 29 CFR 1910.95(g) requires for every employee whose noise exposure equals or exceeds an 8-hour time-weighted average of 85 decibels, provided at no cost to the employee. Each employee gets a valid baseline audiogram within 6 months of first exposure at or above the action level (within 1 year when a mobile test van is used), then a new audiogram at least annually under 1910.95(g)(6). Under 1910.95(h)(1), each test is a pure tone, air conduction hearing threshold exam covering at least 500, 1000, 2000, 3000, 4000, and 6000 Hz, with each ear tested separately, given in a room that meets Appendix D under 1910.95(h)(4). The rest of this post covers the part employers most often get wrong: who is allowed to give the test.

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

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. Under 1910.95(g)(7)(i), the comparison of the annual audiogram to the baseline to check for a Standard Threshold Shift may be done by a technician, but under 1910.95(g)(7)(iii) an audiologist, otolaryngologist, or physician has to review problem audiograms and decide whether further evaluation is needed. Employers who conflate "the technician who ran the test" with "the professional who reviewed the problem audiogram" 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

What does OSHA audiometric testing require?

A baseline audiogram within 6 months of an employee's first exposure at or above an 85 dB 8-hour time-weighted average (1 year with a mobile test van), then a new audiogram at least annually. Each test is a pure tone, air conduction threshold exam at 500 through 6000 Hz in each ear, in a room that meets Appendix D, given by a person qualified under 1910.95(g)(3).

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?

Partly. Under 1910.95(g)(7)(i) a technician may compare the annual audiogram to the baseline to check for a Standard Threshold Shift. Review of problem audiograms, and the decision on further evaluation, belongs to an audiologist, otolaryngologist, or physician under 1910.95(g)(7)(iii).

Sources

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