SCREENING AUDIOMETRY
On-site audiometric testing

To non-noise nerds this sounds like the same thing but it is very different.

Hearing screening

This is the basic hearing testing. Doing the tests, getting the results and us making any recommendations based on those.

This can be a one-shot process, and can be done for anyone, whether they work in high noise or not.

This is the initial stage covered by our on-site testing and report.

Health surveillance

This is the above, plus a doctor’s review of all problem cases, with feedback to the client on management of individual cases.

It is an ongoing process of repeat testing and is what is required specifically for people who work in a high noise area.

If you have people exposed to a noise risk at work then the law requires health surveillance.

We can help with this as well. We can refer directly to an Occupational Physician for you, or can refer to one of your chosing, or you can choose to arrange that yourselves if preferred.

Audiometry referrals generally come up in Category 3 and Category 4 cases although you can also have people with specific issues in Categories 1 and 2 as well.

We do the screening tests and identify those with an issue. Our Nurse may decide that their hearing issue is known or is not related to noise issues and that a further medical review is not needed. We may give advice on managing their wider safety at work if needed but tis will be the end of the process for them.

Conversely, people with an issue which could be noise related should then have a doctor’s review of their results.

PEOPLE WHO WORK IN A NOISE RISK

You, as the client, then have options for this.

Use our recommended provider.

We have contracts in place with some physicians and can send referral case to them. The advantage is that from the client’s side it is seamless so gets it done with minimal hassle, and we also have great pricing from the physicians for it as we can send a lot of work their way. That means even clients with a small number of referrals still benefit from a bulk discount.

Clients can choose any other occupational physician or doctor.

There is no obligation to use our provider. If you have another physician you prefer or already have contacts with you can use them.

Not use an occupational physician

We can’t force a client to use a physician at all and if the client chooses this route they are free to do so, but we would make clear that this is against our advice and would mean the client is not compliant with the health surveillance requirements of the Noise Regs.

Choosing the route

We will ask you which route you will prefer when booking in.

PEOPLE NOT WORKING IN A NOISE RISK

The requirement for the doctor’s review applies to people who have an occupational noise risk. if you have tested everyone in the company, including office staff for example, then these people are not facing a noise risk and they fall outside the HSE’s requirements for health surveillance. The company then has no obligation to arrange this doctor’s review for ‘fails’ in this group.

We may still make recommendations on their wider safety if we have concerns, for example their hearing is so poor they may struggle to hear fire alarms.

The Noise Regs say that people who fail, either due to poor hearing or due to a new identification of what could be noise damage (even if long-standing) or noise damage which is getting worse, must be reviewed by a ‘doctor’. The accompanying guidance says ‘e.g. Occupational Physician’.

In the past the first point of referral was often to a G.P., especially in smaller companies, but the HSE’s stance now is that this must be to an Occupational Physician, not a G.P.

Although referring to a G.P. was fine for a good two decades, the HSE’s stance on this changed late-2023. They no longer recognise the ‘e.g.’ in front of ‘occupational physician’ and are now taking a very strong stance that it must be an Occupational Physician.

We can arrange this for you via agreements in place with Occupational Physicians. This is subsequent to the prices of the main screening tests.

Of course, clients can choose any route they prefer - the Occupational Physicians we use, any other Occupational Physician or a GP, or even none at all. The Occupational Physician requirement is in that ‘e.g. Occupational Physician’ part of guidance in L108, but the HSE often don’t understand the difference between Guidance and Law so be prepared for an argument if you do choose to use a GP.

Firstly, they are not a new examination and do not need the individual to attend anywhere, and can be a desktop / paperwork exercise. In rare cases the Physician may want to speak to the individual by phone but this is uncommon.

In most cases, the testing notes, health history, test results (both current and any historical ones) are sent to the Physician and they conduct a review and make recommendations. A report is sent back for that person.

If there is a concern or problem the Physician will then typically refer into the NHS via G.P.’s. locally to the individual concerned.

The Noise Regs require anyone who is regularly exposed to high noise levels. Put simply, if someone needs to regularly wear hearing protection at work then they should be given a hearing test. This applies even if they don’t always work in the high noise area but regularly go into it.

(And no, the HSE are not helpful enough to define ‘regularly’…)

Hearing aids

If you have someone with hearing aids or who is ‘deaf’ then it is more important they are included in the audiometric testing programme than anyone else as a small change in their hearing could have a dramatic impact on their life.

We have more information on this here:

Link: Who to include in audiometry screening

There is the basic requirement, but this can be over-ridden by individual results.

Year 1
A person is tested once, this is year 1 and tells us how good their hearing is.

Year 2
The Noise Regs require that a second hearing test is done a year later and this tells us whether their hearing is stable.

Ongoing
Then the maximum period allowed in the Noise Regs is every three years. BUT, it says ‘unless needed more frequently’, which then applies to Category 2, 3 or 4 people.

From this point forwards it can get more variable. The basic system is that after their second test, Category 2 people should be tested two years later, and Category 3 and 4 people tested one year later.

But, the Regulations also say that more frequent testing shall be done as determined by the results and review process, so for example a nurse or doctor may even recommend a test in six months, or that a Category 2 person is done in one year rather than two.

Blanket retesting frequency programmes

We do see companies who have a policy of just testing everyone every two or three years. This is not compliant with the Regs and be aware this could get you a spanking from the HSE should they pick up on it.

Don’t over-test either

One wee bit of advice, as much as we like the extra work and sales, don’t test too frequently… It won’t make you non-compliant, but could cause you unnecessary issues to deal with.

If you have some people who are due in three years time and you decide to test them anyway as you are having a session done, you are more likely to end up with ‘fails’ than if you just leave them alone. Hearing is not fixed and people get low results from things such as transitory ear infections (for example).

If you tested someone in 2022 and 2023 and they were a Cat 1 both times, they’re not due again until 2026. If however you then retest them in 2024 as you were having some others done, they could have a non-work issue and fail, but that means their next test is now 2025 rather than 2026, and as a bonus you could end up with the costs of a doctor’s review as well. You’ve incurred two additional costs from the actual screening and the costs of a doctor’s review which you didn't need to.

The HSE updated their Categorisation system in L108 Rev 3.

The HSE’s system in L108 Rev 3 is now:

Category 1

Everything is normal for their age and sex (as we get older women have better hearing, and higher targets, than men) and there are no signs of any noise damage.

Category 2

Still a ‘pass’, but getting towards the lower end of what is considered normal for them. Basically a ‘head’s up to be careful’.

Or, this now can be someone with excellent hearing but who has a bit of a drop which is probably noise related, which is known about and which is stable. They could still have excellent hearing overall and the drop be trivial.

Category 3

A ‘fail’, hearing is weaker than it should be.

Or, in the new system, this could be someone with otherwise excellent hearing but who has a bit of a noise-related drop from their time as an exuberant youth 20 years ago, but that drop in hearing hasn’t been previously identified. Even with that, their hearing could still be excellent for their age.

Category 4

This one is a bit different as it is not a level of hearing ability at all but is an indication of fast deterioration. Category 4 means their hearing has got significantly worse since their last test. That doesn’t automatically mean their hearing is bad, just that it is better last time. It is possible to have Category 4 hearing that is still good overall.

Unilateral

You may also see something saying this, for example ‘Category 3 unilateral’. This means one ear was significantly worse than the other. Good hearing should be balanced in each ear so one being low is a sign of a potential issue. In cases like this where one ear is Cat 1 and one Cat 3, the overall result will be ‘Category 3 unilateral’.

Comments on this system

In the new system, anyone with any sign of NIHL cannot be Category 1, even if their hearing would still put a bat to shame. If it has never been identified (or more likely, it has but was in a previous job or something and the attendee forgot the details) then they are Category 3.  Some NIHL is common in most people - most people had an active social life as a youth before work and a loss of hopes and dreams took over, and they probably have a wee bit of noise damage as a result, but it is trivial and has no impact on their life.

How big are the changes?

BIG. No company can now use comparison of current performance against previous numbers per category as a means of verifying their noise safety programme, and no company will be able to do for several years to come until a decent body of data is built up.

For example, we took a sample job of 109 results from December 2023 and assessed them under both the old and new systems.

Old system: Cat 1 81%, Cat 2 14%, Cat 3 3% and Cat 4 4%.

New system: Cat 1 39%, Cat 2 9%, Cat 48%, Cat 4 4%

That goes from Cat 1 being the majority by far, to Cat 2 being the largest group. This was because we had been there before, if this was new testing then most of those Cat 2s would have been Cat 3.

Also, there is a massive problem which is unaddressed in the Noise Regs which is people changing job. By way of an example. I am a bloke in his 50s and have some noise-related hearing losses dating back to my late-teens and early-20s, my hearing is perfectly good, just with a nice noise-notch but still normal for my age. A lot of nightclubs and concerts and time as front-stage security as a student for hundreds of bands. If I get a job in a factory and have a hearing test, that will show a noise-loss so the employer is obligated to arrange for a doctor’s review as it is newly identified as they have no previous records of it. If I then change jobs after a couple of years and have a test at my new place, again it is new to them so back it goes to a doctor’s review again. And again when I change jobs. And again.

This can mean the same people repeatedly going through the doctor’s review process because they changed jobs, even though in my case, my hearing is absolutely fine and has been so for 30 years.

A two-step testing and review process.

THE TESTING

Every test is undertaken by trained in-house personnel who also hold 3rd party certification of competence to administer the tests. We train them for a minimum of a month in-house, then send them on external courses to validate their competence.

All testing is done according to a rather lengthy in-house procedure which governs every step of the testing process.

All testing is done using calibrated audiometers, in purpose-built mobile clinics where the testing environment can be managed.

Every result is then reviewed in-house to validate the test’s findings and any recommendations arising from it.

THE REVIEW PROCESS COMPETENCY

Our costs include a two-stage in-house review system. All jobs follow this.

First Review: RCN Registered Nurse review

All reports will first be reviewed by an in-house Occupational Health Advisor (registered nurse, Occupational Health Diploma).

This focuses on the people identified as having a problem and reviews the results the draft recommendations made by the Technician. This will confirm or amend the recommendations.

Second Review: The Boss

This second review is done as double-check to ensure consistency across all testing and that we consistently meet the standards we need to.

This second review will be done by someone who has competence for this by:

Anatomical knowledge

Holds a degree in biology, giving excellent understanding of the ear, its anatomy and impacts of noise on it.

Procedural knowledge

Trained specifically in screening audiometry, both in the UK and USA. Gives the technical knowledge specifically for how to do hearing tests and interpret results.

This person is also a member of the British Society of Audiology, (BSA).

BSA membership also means access to the latest studies into hearing and audiometry, including impacts of noise exposures. We stay current on the very latest developments in the field.

Impacts on health and safety

As well as three decades of experience in a huge variety of workplaces, our final reviewer holds the NEBOSH Diploma so understands the health and safety side of it.

This means our Nurse gives a review from a health perspective, while this final review can act as a double-check on wider health and safety issues.

Experience

This person has worked in screening audiometry for over 30 years, undertaken over 90,000 hearing tests personally, and reviewed and overseen around 3/4 million screening hearing tests.

DOCTOR REVIEW

For compliance with the health surveillance requirements all results which show a problem must be reviewed by a doctor. We have Occupational Health physicians we have contact with and which we recommend clients use, although clients can choose their own if they prefer.

Qualifications for the Physicians we use are MBChB, MFOM.

This is an area of audiometry which can get into a right old knot.

As a basic principle, remember where this is coming from: If you have assessed your hearing protection as being suitable for the noise risk and people comply with wearing it, then the risk they face is pretty trivial to non-existent and you are not going to make them deaf in the coming months. The audiometry is the safety-net check that things are working OK, not the primary safety control measure.

It is a cost balance decision for the client

We can come and do tests as regularly as you like, but in the real non-idealistic world the realities of finance have to be taken into account when looking at small numbers of people outside of your main sessions. If we come and do one or two tests that is going to be hellishly expensive as it has to be charged at our full day rate as it stops the van working elsewhere. We can happily come and do it but it is not cheap.

This goes back to that basic principle

So our advice, as much as we love selling more sessions, providing the hearing protection stipulations above are in place and working, don’t worry about it and catch them in the next planned audiometry session. To be clear, this is not what the HSE would want to see and you could have an argument on your hands justifying it as they want to see everyone tested exactly as a doctor’s frequency recommends. But cost and practicality does play a part.

Importantly, make sure nobody becomes a serial non-attendee, that new starters are definitely covered in a planned session rather than missed, and if you have someone identified as especially at risk from previous audiometric testing make sure they are available and attend.

Employees cannot refuse to attend a hearing test provided by their employer as part of their duties under the Noise Regs, as long as the test is taking place in the employees' normal working hours and it is being provided because the employee works in a noisy area - i.e. their exposure levels are over 85 dB(A). If this is the case then attendance is not optional.

The Noise Regs say the employer must provide it AND that the employee must attend.

This is specifically stated in the Noise Regs, covering it in the regulation itself rather than merely in guidance. This is in Regulation 9 of the Noise Regs. and the employee is under the same duty to attend the test as the employer is to provide the test.

Refusal to attend

If someone refuses to attend then it should be treated within the disciplinary procedures for the company as they would any other non-compliance. This may vary from company to company depending on how issues are generally enforced.

Can employees signing exemption disclaimers and opt-out of the hearing tests?

Sometimes this is suggested as a route but it is not possible. The employee is under the same legal duty to attend as the employer has to provide the audiometry and disclaimers cannot remove regulatory requirements.

Signing a disclaimer is effectively saying to an employer ‘yes, this is a legal thing but I will sign this which means you don’t have to comply’. If that was allowed, every dodgy employer in the country would be leaning on employees to sign disclaimers for everything from PPE to wearing fall protection when working at heights.

Simply not allowed I’m afraid.

Employers making hearing test attendance optional

For employers, if they have a workplace noise level which is sufficient to trigger the audiometric testing requirements of the Noise Regs then they cannot then allow employees in high noise areas to choose to attend or not - this is very naughty.

Where there is a noise risk at work, it is not sufficient for the employer to merely make appointments available and then leave it up to the employees as to whether they attend or not.

If people are included in the audiometry programme who do not routinely work in high noise areas (i.e who do not regularly go into areas over the 85 dB(A) limit) then it is perfectly OK for their attendance to be optional.

This is covered in the HSE's L108, Controlling Noise at Work where Regulation 3 states:

“..Regulation 9 (health surveillance) shall not extend to persons who are not his employees”.

The Guidance accompanying Regulation 3 then covers the meaning of this in more detail, a summary of the key elements of which is:

People who are not your employees: Sometimes your activities may cause employees of other employers to be exposed to noise… Regulation 3(2) places duties on all the employers involved and each will have a responsibility to their own employees.

This responsibility applies to all the duties under the Noise Regulations except health surveillance (regulation 9), which you do not have to provide for anyone other than your own employees, while you only need to provide information, instruction and training (regulation 10) to the employees of others in relation to the specific job they are doing for you.

This makes it clear the host company is not responsible for providing audiometric testing. The general screening requirements of Regulation 9 for an employer then apply to the Agency and require the Agency to undertake audiometric testing for any of their employees who may be in high noise areas.

Paragraph 18 also makes clear:

In most cases employers will need to exchange information and collaborate to ensure they fulfil their duties without confusion or unnecessary duplication.

Paragraph 19 then refers to contracts:

Where contractors and sub-contractors are involved it is usually best for responsibilities to be set out in the contractual arrangements.

It is the responsibility of the individual's employer to provide the necessary hearing tests, and for an Agency this is the Agency and not the host employer. The Agency is the employer of the individuals.

As the host employer you do still need to have a risk assessment in place and train and inform the Agency staff on the noise risks present, but the Agency remains the 'employer' for the staff they provide and responsibility for providing audiometric tests for those people rests with them. As the host employer, check with the Agency that this is indeed being done and make it a provision in any contracts with them.

Additional cost implications of testing agency staff

As well as the cost of the hearing test, if someone fails you then have the follow-on process of a doctor’s review and you could be looking at £100 per person for that. If you don’t need to do the tests as they are not your staff, don’t do it.

GDPR issues

An employer could choose to go beyond the basic requirements of the Noise Regs and provide testing for Agency staff anyway, or get the Agency to tell them the results of their own testing, but GDPR pretty much prohibits this.

As Agency staff are the employee of the Agency, there is an issue with the host employer seeing the hearing test results for Agency staff. As established, the legal responsibility for the audiometric testing rests with the Agency. As there is no direct relationship between the individual and the host company, informing the host company of the Agency person’s result is effectively the same as transferring data to the third person, for which consent is needed. That consent must be informed consent, not presumed, and be from each individual rather than a top-level agreement between the two companies. The same would go for referral information.

It would be hard for the host company to argue ‘legitimate interest’ in seeing individual results, especially without consent. The host company cannot choose to receive results, referral information, etc. from Agency staff, with or without the agreement of the Agency, without the explicit consent of each Agency employee individually.

As a note, from experience, Agency staff in a host company can originate from a variety of countries and in a significant number of cases their understanding of English can be very poor. This will make the notion of ‘informed consent’ difficult without translation of documents into several languages. As each result is different the content of the document could change from person to person, making the provision of translated documents, and therefore informed consent, very difficult.

Recommended route for audiometry (and spirometry) in Agency staff.

When setting up the Agency supply agreement, ensure that it contains provision for the Agency to supply staff who are suitable for working in environments with identified risks, such as noise. This is a requirement under the Health and Safety at Work Act (HASAWA) so should already be done anyway for all risks such as machinery, manual handling, dusts, CoSHH, etc. The host employer needs to inform the Agency of the nature of risks to which its employees may be exposed - a standard HASAWA requirement.

Regarding noise specifically, use something along the lines of: “The working environment will include risks from high noise (levels of 85 dB(A) and above) and the Agency must provide personnel who can safely work in these areas. We require you to comply with your obligations under the Control of Noise at Work Regulations to provide health screening (audiometric testing) to any staff you may provide who work in these high noise areas. We may ask for confirmation that this is undertaken by various means, including asking for details of your audiometric testing programme, example test dates of selected Agency employees supplied to us, etc.. We will not ask for personal medical information including type of result, referral status, etc. without the explicit consent from individuals.” If you do this you have confirmation the necessary audiometric testing (or other screening) is being done generally, with a date-check to do sample-testing on individuals to confirm it is happening as it should be, without the need for transfer of any individually-identifiable medical data.

(This is guidance text only and the final wording and approach should be confirmed by any company working with Agency staff).

It remains the responsibility of the host company to inform individual Agency staff of the nature of the noise risks, train them, provide hearing protection and monitor and enforce its use.

As much as we love the extra work, don’t do it. Companies can have the best of intention in covering everyone but it can come back and bite you on the bum, and it can be unhelpful generally.

Extra costs

As well as the cost of the screening test you can have the costs of a doctor’s review for anyone who fails. People who work in quiet areas often still have a bit of a ‘noise notch’ (see another bit of the FAQ for info on what that is) and could then end up with the doctor’s review and costs associated with that.

It messes up your trends

The HSE want to see a pattern of long-term anonymous trends which confirm the noise safety programme in the workplace is doing its job. If you include a lot of people who don’t have a noise risk it can skew your results.

So our recommendation, as much as it hurts our bank balance, is no, don’t test people who are office based or warehouse workers, etc (unless you have a specific concern such as they have poor hearing) as there is no business-benefit and you could find yourself with extra cost and extra hassle for it.

Well here is a controversial one, especially given some of the standards relating to this, but no, it is not quite as definitive as is sometimes made out.

(NIHL means Noise Induced Hearing Loss).

Notches are not automatically indicative of noise

Reference: British Society of Audiology, International Journal of Audiology 201; 49:: 95-98.

To summarise this, the study concluded that “The high frequency notch without excessive noise exposure or any other known factor is common. It is neither diagnostic of, nor invariable with NIHL unless a convincing history of hazardous noise exposure is elicited from the history”.

The study goes into depth on this, but the take-away is that about a third of people have a notch with no history of serious noise exposures. The notch is their natural pattern of result.

This doesn’t mean a notch shouldn’t be used to identify NIHL, but that it must be read alongside that person’s history of noise exposures before a link to noise is made.

Notches can be caused by noise exposure, but are not automatically indicative of workplace exposures

As well as the issue whereby that for some people a dip at the higher frequencies could just be their normal result, for many people they have have very significant non-occupational noise exposures. They may use headphones a lot, they may be into DIY, they may go out socialising a lot, they may ride a motorbike (especially on motorways), and so on.

And to complicate it, they may have a quiet life now where a wild night is a new episode of Midsomer Murders and a glass of red, but they had more exposures many years ago.

For example, the poor soul writing this now has a nice chunky ‘noise notch’ but has never regularly worked in excessively loud environments. What he did do was ‘have a life’ in his late-teens and 20s, with a normal frequenting of clubs, music gigs, etc. 30 years later the notch is still there and always will be, but he is also a perfectly fine Category 1 with normal hearing for a bloke in his 50s.

A hearing test can indicate that noise damage is possible but it cannot determine what caused it - all noise has the same impact, be it headphones a few times a week or an angle grinder, going to nightclubs or using a spindle moulder.

Therefore getting a result back showing someone has a possible noise-related loss is not automatically saying it is occupational. It can however indicate someone who is more at risk in a high noise environment as their hearing is already weaker at the same frequencies which would be damaged further by noise.

Ears can change their sensitivity to noise if subjected to excess noise, which could have an impact on someone’s audiometry result by making them non-responsive to quieter tones.

Testing before a shift

This is not practical as you would effectively only be testing one or two people a day, every day.

Noise-free periods before a test and hearing protection

The Noise Regs require anyone exposed to high noise to have hearing protection which is assessed as being suitable for the noise risk present. They also require the employer to monitor and enforce its use.

This means that nobody should be exposed to harmful noise anyway, so the timing of when they do their hearing test becomes immaterial as there is no noise exposure.

There is a guide in L108 that employers should ensure attendees are wearing hearing protection on the day of their hearing test, but employers should be doing that anyway, every day, not just because hearing tests are planned.

The screening units are based on long-wheelbase vans and as such are limited in width. There are three steps to enter and leave, and the internal door is necessarily narrow to fit between the wheel arches. As such a wheelchair will not fit through it. Wheelchairs will also not fit into a standard audiometry booth. People will need to be able to negotiate those steps to get in.

If you let us know in advance about attendees who may not be able to get into the van, let us know when booking in and when the schedule is being drawn up we can make allowance for time to remove the key equipment from the van and set it up in a meeting room or office on your site and conduct the test there. Please let us know at the point of booking as we need to give a good half-hour for removing the equipment and setting up, and then the same again to pack it away after the test.

Technically no, but in reality, for most situations yes.

Audiometry done as health surveillance under the Noise Regs has to be done in a quiet environment and some companies may indeed have a meeting room which is quiet enough, but it must be free from sounds such as telephones, speech, music, machinery noise, etc.

Noise reducing headsets

These are commonly used in hearing screening and we ourselves use them, but to be honest they’re a bit crap. (I tried to think of a more technical way to phrase that but failed). They don’t fit everyone all that well, and can even have a ‘seashell’ type effect and make some noises be perceived as louder.

They have a small benefit, hence are pretty much standard now, but aren’t great and shouldn’t be relied on as the primary external noise control measure.

Audiometry booths

To be clear, there is no such thing as a ‘soundproof booth’, they simply don’t exist.

Booths reduce sound but no booth is soundproof. Even the overlords at the HSE get that one wrong when talking about booths in L108 where they use the term ‘soundproof’.

Booths reduce noise levels considerably and are effective, but you still need to start off with the booth being somewhere reasonably quiet.

Booth are most effective at reducing noise levels at the frequencies being tested, and at eliminating reverberating sounds inside the booth, effectively ‘deadening’ the noise.

They would be far better described as ‘noise deadening’ or ‘noise reducing’ rather than ‘soundproof’.

You can do it yourselves if you get someone properly trained to administer them, but renting a kit and having people test themselves is not compliant.

There are a few ways in which tablet-based audiometry kits are not compliant with either the British Society of Audiology standards or British Standard for these hearing tests:

1. No pre-test on-site daily calibration verification.

2. No otoscope - no visual inspection of the ear canal.

3. Attendees fit their own headphones (this is bad as they do it for comfort rather than accuracy of the speaker) and so on.

4. After the test everyone gets the same bland meaningless ‘your result is this which means this’ - everyone is different. A Category 3 can be a potential major issue, or a mild and frankly trivial bit of reduction, or can be unexpected or entirely normal for them, depending on the attendee.

You can rent a kit, stick it in a meeting room and get some self-operated results, but they are hopelessly non-compliant with the two main standards governing these.

Add to this, all health surveillance hearing test results should be reviewed by an Occupational Health Advisor and fails by an Occupational Physician. You will still need to arrange this.

(Note, kit providers often refer to ‘HSE standards’ - the HSE do NOT define the standards for undertaking screening audiometry, that is relevant British Standard or the British Society of Audiology’s procedure for it. Claiming ‘HSE standards’ is a bit of smoke and mirrors).

Very occasionally, an attendee complains that a hearing test has damaged their hearing or hurt their ears, usually with varying claims of effect ranging from tinnitus to pain in their ears, or even a dull sensation afterwards, but can a hearing test actually damage hearing? Put simply, no.

The hearing test is a series of tones, played very quietly to determine the lower limit of their hearing.

The tones are between 500Hz and 8kHz. This is far from the entire range of human hearing and these are the frequencies commonly found in speech - the test is focused on testing the sounds critical to speech.

This means the test is giving the attendee the exact same sounds they get in normal conversation, or in music, just that in normal speech the frequencies are all mixed up and a wide range are covered at once whereas in a hearing test they get them one at a time. But, they are the same sounds they get in normal speech - nothing different.

As we are trying to find the lower limit of their hearing the sounds they get are lower than they would experience in normal life, including when listening to speech or to music. Quiet sounds do not damage ears.

An audiometric tests is just testing speech sounds

The sounds people experience in a hearing test are EXACTLY the same ones they get in speech and music but just presented individually rather than grouped into one noise, and at a lower volume than when listening to people talk or listening to music.

Unless hearing someone talk normally causes the recipient to suffer hearing damage or causes tinnitus, then no, a hearing test cannot damage hearing.

Why do people claim a hearing test has caused pain or discomfort or another effect?

After three decades of doing workplace audiometry, on the handful of occasions when someone has claimed the test hurts their ears or causes tinnitus, it is always someone who didn’t want to have their hearing tested in the first place. Or who is that one complainer in a factory - the one who is most likely to raise an issue about pretty much anything.

In almost all the screening jobs we do, employees have no issue with the test, but every so often you come across one site where someone plays up either before the test, during it or after, and this is always when claims are made that the test hurts their ears or has some other impact.

Complaining a test has hurt their ears or causes tinnitus is a way to kick back against having to do something they don’t want to, for whatever reason.

Summary

A hearing test is the EXACT same sounds found in speech and in music, nothing special, except in the hearing test they are much quieter than in normal life and are presented as single tones rather than as one mass of noise. If they can listen to people talking without it causing pain or tinnitus then they can do a hearing test without it causing any problems as it is the same sounds, except much much quieter.

We test our own hearing at the start of every day as part of the verification checks on the audiometer so if there were any issues with a hearing test we would be the first to experience it.

As employers may receive feedback on individuals, such as from a doctor’s review, it is important that client companies have a good system for holding and storing it.

The key elements for storing your reports securely are:

One nominated person

There should be one nominated individual within the employer's company who holds the information securely. This information may not be seen by anyone else, other than an employee looking at their own record or where an employee gives permission for someone else to see it.

Talking to other managers

If there are issues which need to be discussed with another manager in the company, then this should be done with the employee’s consent, otherwise the person managing the programme should simply tell their manager about a specific action which is needed but in such a way that does not reveal personal information.

Where to store it

The data must not be kept with HR records, much to the chagrin of many HR departments.

If the information has been provided electronically, have an encrypted folder on your computer or hard drive, and store it there. Only the person managing the audiometry programme should have that password, nobody else.

Do not share that password with anyone such as IT.

If you have paper records, these should be secured in a locked filing cabinet with restricted access.

Employee access to the audiometry data

If an employee requests it, you should provide them with access to their own result but care must be taken not to provide access to the results for any other individuals.

Insurer access to audiometric testing data

Clients should be careful with bodies such as insurers. Letting them view anonymous data which confirms trends and that the audiometric tests have been taking place is perfectly fine, but they have no legal basis for seeing individual personal audiometry results purely on an ‘auditing’ basis.

HSE access to audiometric testing data

As the HSE are accessing data for regulatory compliance then access to the full report can be given however we would still recommend a discussion takes place first to determine if the HSE inspector concerned is happy to see anonymous data confirming the audiometry programme is in place rather than handing over personally identifiable information immediately. If they want to see it all then that is OK, but it's worth asking the question before handing it over.

Other personnel in the company

Only the person responsible for the audiometry programme should have the password to access any results. This mean NOBODY else in the company, no training departments, no production managers, no senior managers, etc. It should also be one person within a department, not the entire department.

Firstly, we do not keep any paper records, everything is electronic.

All data resides on a computer to which only one person has access, via secure login of either a long alphanumeric password or biometrics.

(In terms of volume we don’t have a massive data-load, the entire company’s data only amasses to 54.1GB as of now, and most of that is PDFs of quotes, invoices and all the other admin gubbins. That’s why we don’t need dedicated servers).

That data sits on a hard drive which is fully encrypted, using 128bit AES.

(Even if someone stole the laptop, there is the secure login without which it is inaccessible, and if they took the hard drive out and connected it to another computer to access it would be an unreadable blob of data).

An onsite backup of that data is kept, which is again entirely encrypted using 128bit AES and requires password logon when connected to a computer, otherwise it is unreadable.

An off-site continual backup is maintained. Data moves there via a secure fully encrypted tunnel, again using 128bit AES. This allows for disaster recovery in the event of fire, etc.

The people going onto sites to conduct tests only have data on their laptops which is in active use. Data is transferred to their laptop ahead of the job (if needed, for example historical results for use in comparison) using a fully encrypted 128bit AES transfer. It is not emailed.

(It is dropped into a folder on the main computer which is shared with them via an encrypted link. Anything put in there is automatically encrypted and shows up on their laptop, having got there via an encrypted tunnel).

When they have finished a job and the report is ready to review the data is removed from their laptops by the same means. The reports and data are never emailed and only ever moved via these secure connections.

When the small amount of data they are working on is sitting on their laptops, those laptops have whole-drive 128bit AES encryption in place with password-protection. Again, even if they lost a laptop it would be inaccessible, or if a hard drive was removed it would be an unreadable block of data.

As soon as they finish a test the data is saved into that transfer folder, meaning it immediately zips, again via a secure 128but AES protected tunnel, back to the main store, both on that computer and into the off-site backup to make sure we don’t lose data. If their hard-drive dies we should therefore have every result secured in an encrypted means up to the one they are actually working on.

Reports sent to clients are all encrypted and password-protected. Every client has a different password.

Basically, no data is ever stored or transferred in an unencrypted state, it is never emailed within the company, continual backups are kept to guard against loss (including versioning) and those are also encrypted.

We administer hearing tests according to the British Standard for Pure Tone Audiometry and the British Society of Audiology (BSA) recommended procedure for screening audiometry, then classify the results according to the HSE’s system detailed in L108.

For non-noise nerds, the British Standard and the BSA say how a hearing test should be administered, while L108 says how the HSE want the results classified.