ghItlh voragh:  

>At  qepHom 2015 qurgh asked Okrand about this:

>(qurgh, 11/10/2015):  I had a conversation with Marc about 'oH and ghaH 

>and animals when I was at the qepHom. He said that if you (the speaker) 

>believe you can communicate with a creature, then it's a ghaH, if you don't 

>believe you can communicate with a creature, then it's 'oH. It's down the 

>personal beliefs of the speaker, not a set formula.

Right you are!  I had this filed in my brain as a discussion of how to determine what is "language using" and what is "not language using", but Okrand is also clearly indicating that the difference between {'oH} and {ghaH} is the abillity to communicate and not whether or not it is animate.