OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 4, 1983

Maurice Miller, Chairperson
Council for Accreditation in
Occupational Hearing Conservation
Lenox Hill Hospital
100 East 27th Street
New York, New York 10021

Dear Mr. Miller:

Your letter of May 17, 1983, to Assistant Secretary Thorne Auchter, regarding the certification of microprocessor audiometer technicians was referred to this office for reply.

You expressed concern in your letter that the statement in the noise standard that microprocessor technicians need not be certified, might allow untrained, unsupervised technicians to be part of the hearing conservation program. However, this is not really the case.

The hearing conservation amendment recognizes two methods for persons to become trained in administering audiometric tests. The first is to complete a training course certified by your organization, the Council for Accreditation in Occuptional Hearing Conservation (CAOHC), or another recognized training organization. The second method involves demonstrating, to the satisfaction of the professional supervising the audiometric testing program, that competence has been achieved in (1) administering audiometric exams, (2) obtaining valid audiograms and (3) properly using, maintaining and checking the calibration and proper functioning of the particular type of audiometer being used. Microprocessor audiometer technicians, like all other audiometric technicians, need not be certified if they meet the requirements outlined in this second method.

At the time the hearing conservation amendment was formulated, OSHA was not aware of a certified training course that specifically covered microprocessor audiometers. The intent was that audiometric technicians show competence in performing tests with the particular type of audiometer they would be using, rather than with audiometers in general. Requiring certification for microprocessor audiometer technicians when no certification course was available would have effectively banned the use of microprocessor audiometers. This was not our intent, and the sentence stating that microprocessor audiometer technicians need not be certified was added to clarify this fact.

As noted above, microprocessor audiometer technicians, or any other audiometric technician, need not be certified if they can demonstrate their competence to the satisfaction of the audiologist, (word unreadable), or physician supervising the hearing conservation program. The professional in charge of the program is responsible for the competence of the technicians working under his or her supervision. Technicians are permitted to perform only those duties that the professional in charge fines them competent to perform. As you note, frequently the audiometric technician issues personal protection equipment and assists in employee education, among other things. Any technician assigned to perform such tasks would have to be acceptable to the professional in charge of the program.

I hope this information has helped to clarify the audiometric technician certification requirements for you. If you have any further questions, please do not hesitate to contact us.


R. Leonard Vance, Ph.D.
Health Standards Programs