Under OSHA’s hearing conservation standard, audiometric testing can be performed by an audiologist, an otolaryngologist, another physician, or a technician who meets the standard’s qualification criteria and works under the supervision of one of those three professionals. That short list is the full answer to who can perform audiometric testing under OSHA, and the practical question for most employers is which category their testing personnel fall into and what the supervising professional is responsible for.
The Professionals OSHA Names Directly
29 CFR 1910.95 identifies three professionals who can personally administer audiometric tests, review problem audiograms, and decide whether an employee needs a referral for further evaluation: an audiologist, an otolaryngologist, or another physician.1Occupational Safety and Health Administration. 29 CFR 1910.95 – Occupational Noise Exposure
A licensed audiologist is the professional most closely associated with diagnostic hearing evaluations. Every state requires audiologists to hold a license, and the credential is typically a Doctor of Audiology (Au.D.) with a supervised clinical externship and passage of the Praxis examination in audiology. Their scope covers the full range of testing, including bone conduction, speech recognition, and vestibular assessment.
Otolaryngologists (ear, nose, and throat physicians) combine medical diagnostic authority with specialized training in hearing disorders. Other licensed physicians can also administer audiometric tests under their general medical practice authority. OSHA does not rank these three; any of them can serve as the qualified professional for a workplace hearing conservation program.
Technicians and How They Qualify
Most workplace audiometric tests in the United States are not performed by audiologists or physicians. They are performed by technicians, and OSHA’s standard is more flexible about technician qualifications than many employers realize.
A technician can be qualified to perform audiometric tests under 29 CFR 1910.95 in any one of three ways:1Occupational Safety and Health Administration. 29 CFR 1910.95 – Occupational Noise Exposure
- Certification by the Council for Accreditation in Occupational Hearing Conservation (CAOHC).
- Demonstrated competence in administering audiometric examinations and maintaining the equipment.
- Operation of a microprocessor audiometer, which under the regulation does not require certification at all.
CAOHC certification is the most common pathway, and technicians holding it are often called Occupational Hearing Conservationists. Initial certification requires a 20-hour training course covering audiometric technique, equipment calibration, and hearing conservation program fundamentals, followed by an examination. Recertification is required every five years through an eight-hour course. Certified technicians come from varied backgrounds, including occupational health nursing, safety, and industrial hygiene.
What the Supervising Professional Is Responsible For
Every technician who performs audiometric tests must work under the supervision of an audiologist, otolaryngologist, or physician.1Occupational Safety and Health Administration. 29 CFR 1910.95 – Occupational Noise Exposure Supervision does not mean the professional has to be present for each test. It means they carry defined responsibilities for the program: reviewing problem audiograms, deciding whether an employee needs further evaluation or medical referral, and overseeing the hearing conservation program as a whole.2Occupational Safety and Health Administration. Hearing Conservation
One category of test result is worth flagging because it triggers the supervisor’s involvement. When an annual audiogram shows a Standard Threshold Shift (an average hearing change of 10 decibels or more at 2,000, 3,000, and 4,000 Hz in either ear compared to the employee’s baseline), the supervising professional reviews the audiogram and determines whether a referral is needed.1Occupational Safety and Health Administration. 29 CFR 1910.95 – Occupational Noise Exposure That decision is not the technician’s to make.
The Limits of Technician Testing
A technician’s authority under the standard is limited to pure-tone air-conduction screening at specific frequencies, used to monitor workers’ hearing thresholds over time. That covers the baseline audiogram taken when an employee first enters the hearing conservation program and the annual audiograms that follow. The purpose is narrow: detect whether workplace noise is affecting hearing, not diagnose the cause of any hearing loss.
Anything beyond that scope, including bone conduction testing, speech recognition, vestibular evaluation, or diagnostic interpretation, falls outside what a technician is authorized to do. Those procedures are the audiologist’s or physician’s territory.
What Happens if Testing Is Done by the Wrong Person
Using unqualified personnel to perform audiometric tests is a serious violation of the noise exposure standard. Penalties can reach $16,550 per violation, and willful or repeated violations can reach $165,514 per violation.3Occupational Safety and Health Administration. 2025 Annual Adjustments to OSHA Civil Penalties OSHA adjusts these figures annually for inflation. Smaller employers receive percentage reductions based on workforce size, but even a company with ten or fewer employees still faces 20 percent of the maximum for serious willful violations.
Beyond the fines, audiograms performed by unqualified personnel can be invalidated. That can force an employer to retest every affected employee at its own expense, and if a hearing loss that a valid test would have flagged goes undetected in the meantime, the liability exposure grows from there.
The rule at the center of all of this is straightforward. Audiologists, otolaryngologists, and other physicians can test directly. Technicians can test if they meet one of OSHA’s three qualification routes and work under a qualifying professional’s supervision. Anyone outside those categories should not be running the audiometer.