HEALTH SURVEILLANCE (HEARING TESTING) IN A NOISE RISK ASSESSMENT PROGRAMME
The Noise Regs say that anyone who is exposed to a noise risk level of over 85 dB(A) in a noise assessment, without taking the effect of hearing protection into account, should then be included an ongoing health surveillance programme. What that means is an ongoing programme of regular on-site hearing tests.
Who needs to be included in a hearing testing programme?
A good noise assessment should identify this nice and clearly for you and list the job functions who should be included.
The basis for this is what the HSE say in L108, which is that anyone who is regularly exposed to noise levels over the 85 dB(A) point is included in health surveillance. That ‘regularly’ is doing a lot of work there as it means hearing testing programmes don’t automatically apply to every single person who goes into the higher noise risk area.
For example, if an office person occasionally goes in to speak to someone or to look at a machine and they need to wear hearing protection for that, they still do not ‘regularly’ exceed the daily exposure limits so would fall outside of the need for hearing testing. Same with any other manager or warehouse staff who only go into a high noise area occasionally or for short periods.
But, your noise assessment should make it nice and clear who needs to be included.
Health screening vs health surveillance
The two terms are used interchangeably by normal people, but do have slightly different meanings. Health screening means undertaking a hearing test and looking how that person compares to normal results for their age and sex. Health surveillance is that but with medical oversight and importantly as part of an ongoing programme.
The Noise Regs require health surveillance, so mean it is an ongoing programme, not a one-off, and with some form of medical oversight.
As a side note, I have seen some companies using a self-completed questionnaire asking employees about any hearing issues and then considering this to be ‘health surveillance’ but this is not sufficient. Health Surveillance includes an actual hearing test and with someone with sufficient medical knowledge of the issues overseeing it.
What will on-site health surveillance entail?
Someone will come to your site, usually in some form of mobile clinic, and do the testing there for you. Your people go to their van, go through a hearing health history review, get an otoscopic examination (visual check of the ear drum) and then have the ‘hear beep press button’ audiometry test. The result will then be explained to them.
The client then gets a report of who is OK and who needs any follow-up action. That may be a further doctor’s review, or a recommendation to see their own GP if the issue is nothing to do with noise, etc.
Pitfalls to watch out for
Self-testing kits
There are companies out there offering to rent employers a ‘hearing test in a box’ but they are crap, frankly, and non-compliant with the British Standard for hearing testing or the British Society of Audiology’s procedure for screening audiometry.
There is no on-site daily verification check (that is different to the annual calibration, this is a check before the start of every session).
There is no otoscopic (visual) examination of the ear so it could be blocked, infected, etc.
People put their own headphones on. It sounds silly but this is a real no-no, people position headphones for comfort rather than ensuring the speaker is placed properly and directly over the ear canals and that can have a big impact on the results.
There is no oversight of the test as it runs and people do get it wrong, every day, from the random button pressers to the overly hesitant.
Everyone gets the same meaningless ‘a Category 2 result means this’ nonsense statement rather than having the result explained in terms of their own medical, occupational noise and social noise exposure history.
Office-based testing
Conducting hearing tests in an office or meeting room, either with a self-test kit or done by a Technician, is often pretty poor. If you can hear any music, telephones, speech, etc. then the test will be interfered with as those are precisely the tones being tested.
Often companies talk about noise-reducing headsets but that’s tosh, they don’t do much and every hearing testing company uses those as standard anyway these days.
Recommended hearing testing / health screening provider
I don’t provide health screening services but if you are looking for someone I recommend Aardvark Occupational Health. They are a GP-owned occupational health provider covering all areas of the UK.
More information on hearing health screening
Common questions about health surveillance for noise safety are based around how often it needs to be done and what it all actually means.
The hearing test results categories - what do they mean?
The results will be Category 1, 2, 3 or 4, and sometimes with a ‘u’ as well. Categories 1 to 3 are levels of hearing, Category 4 means a fast rate of change, and ‘u’ means one ear only.
How often does hearing testing have to be done at work?
It cannot just be ‘everyone every two years’ or similar and repeat testing frequency depends on the results.
Link: How often does hearing testing have to be done at work?
Who should be arranging hearing tests for agency staff?
Hearing health surveillance FAQ
Quick questions and answers on hearing testing at work as part of a noise risk management programme
Can we do a set of hearing tests and then be compliant?
No, ‘health surveillance’ means an ongoing programme, overseen by someone with relevant expertise. Repeat testing is needed as part of what is being assessed is rate of change, not just level of hearing.
Can we (the employer) have all the results data?
This is where what is useful digresses from what the HSE say. The HSE say the employer should have anonymous results only so no, not the full audiometry results. Frankly this is an asinine waste of everyone’s time but it is what it is. Read more on this here.
Can we do hearing tests ourselves in-house?
Yes, you can, provided you have the right training and equipment. You can get training from Amplivox in workplace audiometry, and get an audiometer from Amplivox or GM Instruments, etc. and then make your own arrangements with an Occupational Health Physician for oversight of any ‘fails’. (And in this instance, you can also then have all the results, just to show up the HSE’s stance on the previous question to be even more utter nonsense than it already is).
Is attendance at a hearing test compulsory?
They should be provided in working hours, and then yes, it is compulsory for the employer to provide it and it is equally compulsory for the employee to attend and co-operate with the process.
How long does a hearing test take at work?
Different providers work at different speeds and I have seen everything from 10 to 30 minutes per person. Personally, 15 minutes is a nice relaxed pace, anything shorter is probably cutting corners, and anything longer is dragging it out longer than it needs to be.