Hearing protection for people with hearing aids
Don't forget, never share headphones without protection or you may get hearing aids... Sorry, couldn't resist.
Hearing aids are a particular problem when it comes to wearing hearing protection as the aid bungs up the lughole so a plug can't go in, while behind-the-ear ones can also make wearing an ear muff nigh-on impossible. As well as that, in-ear ones can get interference or feedback issues with the muff covering them up.
Physical fit is not the only problem though, with the another problem being that basic types of hearing aid simply amplify the volume of sounds. This means if an ear muff is worn which reduces the noise level by say 25dB, the hearing aid can just add that back on again meaning the wearer is then still subject to noise levels which can cause further hearing loss. If the background noise is 90dB, the ear muff reduces it to 65dB, but then the hearing aid adds that back in again so the wearer is back at 90dB and at risk of developing more hearing loss.
A second complication is that a lot of people with some form of hearing loss can still have their hearing made worse by excess noise. For example, if their hearing loss is due to a transmission issue on the auditory nerve then their cochlea is probably still perfectly fine, which means it can be damaged by excess noise in exactly the same way as anyone else with normal hearing. This is critical in that not only can their hearing be made worse by excess noise, there is a good chance that the impact of that loss is disproportionately greater in them than it would be for someone with normal hearing. For example, a 20dB loss of hearing ability in someone with good hearing is not massively noticeable generally, but an additional 20dB loss in someone who is already 60dB down is very important as that could be the difference between hearing normal conversations and not.
In many cases the duty to ensure hearing is protected is even stronger in someone with existing hearing loss than it is for people with normal hearing.
So, what are the options:
Hearing aids as hearing protection
To be unambiguous on this, which I've come across a few times over the years, a standard hearing aid is not hearing protection so just switching it off but leaving it in and also then not wearing hearing protection is not an acceptable option. Unless the hearing aid has been specifically designed to double up as hearing protection this route is not possible. If an individual does claim their hearing aid is also hearing protection then the same requirements for assessing the effectiveness of that protector kick in as they would for standard hearing protection. This means the employer needs to see some form of proof that the hearing aid is a hearing protector in the form of at least HML data and preferably full APV data so they can make sure the level of protection is suitable for the noise risk present. Without this, the hearing aid is not a hearing protector.
In-ear hearing aids without an upper volume limit
If the hearing aid is a basic 'amplify everything' type and not one which has an upper volume limit, then the hearing aid should be taken out and hearing protection worn. If this means the individual concerned can't hear anything then, unfortunately, so be it. The alternative is to wear the hearing aid and probably suffer further hearing loss arising from their work, and end up hearing even less in life generally. So as much as it is horrible to be the person in that situation, continuing to wear the hearing aid under the muff is not a solution.
There is a question that the noise under the muff could be similar to normal everyday noise which the hearing aid is then also amplifying, which is true, but we are only concerned with workplace noise. There are no noise regs for daily life, only for people who are at work, so different standards do apply at work.
In-ear hearing aids with upper volume controls
In this case, if the in-ear hearing aid has limits on the upper volume levels set at the correct levels for the user then it is OK to wear under the hearing protection as it is prevented from going loud enough to cause a problem. Most modern hearing aids these days fall into this category. This would be my recommended route to someone with hearing loss and a need for hearing aids as it means they can still wear them at work under ear muffs.
It is important to note that this can only apply to in-ear style hearing aids where the ear muff can still get a good seal around the ear. If the hearing aid is behind-the-ear or otherwise prevents the muff getting a good seal then it has to be taken out and the hearing protection used.
Behind the ear styles and ear muffs
These prevent an ear muff sitting properly so cannot be used in high noise environments, no matter how fancy they are, unless they are also certified as hearing protection which would be highly unusual.
Hearing which cannot be made worse by noise
Not all forms of hearing loss can be made worse by noise and this does offer some hope to people who suffer from this type of loss. If the damage is to the cochlea then excess noise may not be able to cause further harm as the person is incapable of hearing it at the cochlea anyway. In this case, hearing protection is pointless as it is offering no benefit. For this route to be followed, as an employer I would want to see, and keep on file, a letter from the employee's GP stating that their hearing loss is such that it cannot be made worse by high noise levels. In these cases it would be OK for the individual to just not wear hearing protection.
Sensear have a type of muff advertised as designed to work for people with hearing impairments. This page gives more information on the issues and also links to details about these muffs. It is American but the principles remain the same - for OSHA read HSE, and where they talk about a limit of 90dB(A), that's the same type of measurement as our 85dB(A) limit here.
There is also a case where the employee can offer to turn the hearing aid's volume down when wearing hearing protection, then turn it back up again afterwards. I would be skeptical of this as in reality, even with the best will in the world it's not going to happen every day, month after month, year after year.
Most modern hearing aids do have some form of volume limit built into them and are clever enough to amplify loud sounds less than quiet sounds, so as an employer, ask the employee to let you have some form of information confirming that. It could be the instruction manual for the aids themselves, or simply a letter from whomever provided them with their hearing protection confirming the absence of additional risk to the person from wearing the hearing aid under an ear muff. In these cases, wearing it under the muff is fine. Most cases of someone needing to wear an in-ear hearing aid at work should fall into this category.
If the aid just amplifies everything then it should not be worn under the hearing protection.
If the aid sits behind the ear and means an ear muff cannot fit over it, then even if it is a smarty-pants all-singing fancy one with volume limits, it should still be removed as a hearing aid is not hearing protection.
The only hearing aids which can be classed as hearing protection must come with some form of proof of that, including HML or APV data so the employer can ensure the level of protection is suitable for the noise risk, as they would for any other hearing protection.
The employee also has the option to provide some form of letter from their GP stating their hearing cannot be made worse by the loud noises present in their workplace and in this instance, as the risk is then absent hearing protection has no use and can be omitted. It would be like putting safety glasses on someone with no eyes.