October 13, 2017

Ms. Dina D'Arcangelo
Occupational Health and Wellness Unit
Washington Gas
6801 Industrial Road
Springfield, VA 22151

Dear Ms. D'Arcangelo:

Thank you for your June 5, 2017, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs. You requested a clarification of the provisions of OSHA's Occupational Noise Exposure Standard, 29 CFR 1910.95 (Noise standard) regarding who can conduct training in hearing conservation. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. Your specific question is paraphrased below, followed by OSHA's response.

Background: Your letter addresses the issue of whether a registered nurse, who is certified by the Council for Accreditation in Occupational Hearing Conservation (CAOHC), may provide training to her colleagues in lieu of them receiving formal training in hearing conservation. After speaking to a member of my staff by telephone, it was clarified that the formal training you are inquiring about is training to conduct audiometric testing and the performance of other aspects of the hearing conservation program.

Question: May a registered nurse who is certified by CAOHC provide training to her colleagues, including those who are also registered nurses, in lieu of them receiving formal training in hearing conservation? In addition, can the Medical Director of our Occupational Health and Wellness Unit approve of the person conducting the training?

Response: Section 1910.95(g)(3) of OSHA's Noise standard states: "Audiometric tests shall be performed by a licensed or certified audiologist, otolaryngologist, or other physician, or by a technician who is certified by the Council [for] Accreditation in Occupational Hearing Conservation, or who has satisfactorily demonstrated competence in administering audiometric examinations, obtaining valid audiograms, and properly using, maintaining and checking calibration and proper functioning of the audiometers being used. A technician who performs audiometric tests must be responsible to an audiologist, otolaryngologist or physician."

Based on the language of the standard, an individual can perform audiometric tests if they qualify as a technician. Section 1910.95(g)(3) recognizes two methods for technicians to become trained in administering audiometric tests. First, a person can complete a training course offered by CAOHC, or a course given by another recognized organization, and receive certification upon completion of the course. The second method involves demonstrating, to the satisfaction of the professional supervisor of the hearing conservation program, that competence in test administration and audiometer use has been achieved. The intent of the standard is that technicians must be able to show competence in the proper use, maintenance, calibration and functioning of the particular type of audiometer being used, rather than audiometers in general. This on-the-job training approach provides employers substantial flexibility in staffing their hearing conservation program, while ensuring that employee audiograms are properly taken. See, the March 8, 1983 preamble to OSHA's final rule, Occupational Nosie Exposure and Hearing Conservation Amendment, 48 Federal Register 9753-54.

Under the scenario described in your letter, registered nurses can perform audiometric testing if they qualify as a technician under Section 1910.95(g)(3). A registered nurse may provide training to colleagues, provided such training enables the trainees to demonstrate to the satisfaction of the professional supervisor of the hearing conservation program that competence in test administration and audiometer use has been achieved. Please keep in mind that regardless of how an individual becomes qualified as a technician, when performing audiometric tests, such individuals must still be responsible to an audiologist, otolaryngologist, or physician. Also, technicians may not perform the duties of those sections of the Noise standard that specifically require an audiologist, otolaryngologist, or physician, such as reviewing problem audiograms, determining if further evaluation is needed, and determining work-relatedness of a standard threshold shift. See, Section 1910.95(g)(7)(iii) and (g)(8)(ii).

If your employer doesn't provide on-the-job training for technicians, individuals must obtain certification or accreditation by completing a formal course provided by a certified training provider, such as CAOHC. You should also know that some states require licensing, registering, and certification of all audiometric technicians. You should check with your State's audiology board, or your supervising audiologist or physician to find out about your state's licensure requirements.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at https://www.osha.gov. If you have further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs