NOISE ASSESSMENT AT WORK
Hearing protection
Hearing protection needs for people with hearing aids
Hearing can still be damaged by noise so needs to be protected
Some ways the company can manage the risk for people with hearing loss
“Thank you for the report. Very comprehensive with good, easy to understand information for us to make improvements
and changes where necessary”. QHSE Manager, Hull, 2022
Hearing aids don’t always mean a serious hearing problem for everyone
Before diving into the issues and possible ways to deal with it, it is worth clarifying that there is no set level at which hearing aids are verging-on mandatory and very often it is because someone is having a problem perceiving sounds than because they can’t hear anything at all.
If we do a day of hearing testing that is about 25 people per van. In any two days in a van we will always see someone who has hearing aids, while we see others who actually have worse hearing but don’t have hearing aids and aren’t concerned about it.
Where they get the hearing aid matters…
With my cynical head on, we do increasingly see audiometry attendees who have hearing aids and profess to be “deaf'“ but when tested they are perfectly fine, sometimes a Category 1 or maybe a Category 2. Gentle questioning usually follows the same path - that they got concerned about their hearing (it is supposed to get a bit worse over time, that’s normal) and went for a private hearing test on the high street. The provider told them they do indeed have some loss and then recommended a hearing aid. My question is then ‘did you get the hearing aid from the same place who did the hearing test"?’, and the answer is usually yes. So they paid £20-40 for a hearing test, and then that same provider then recommended they spent anything from several hundred pounds to a few thousand pounds on some hearing aids, funny that…
This is not just theoretical imaginings on our part. Just choosing the time this web page is being written, this was a good example from a recent test. This chap was convinced he was losing his hearing so he went to get it checked out, whereupon he was told he had some losses in the right ear and that he should have a hearing aid. He was indeed sold a hearing aid, at approximately £1,5000.
Yes, he is a Category 2 rather than Category 1, but there is however very little wrong with his hearing and it is still a pass, he can still hear at whispering volumes. He is quite young therefore the target for his age is high and he is still meeting that. He has better hearing than the vast majority of people we test and he did not need a hearing aid. In a few years, if his hearing remains stable this will become a Category 1.
There is a further twist, he worked in high noise and his employer had told him it was ok to wear an ear plug in the left ear only so for the right he wore nothing and just ‘turned the hearing aid down’. This means the right ear was receiving no protection at all. While it cannot be said for certain, he is starting to develop some reductions at the higher frequencies which could be down to excess noise from not wearing any protection in that ear.
So a double-whammy. Sold a hearing aid which he didn’t need, then a well-meaning employer is possibly contributing to some of the reductions which are present.
Options for dealing with the issue of hearing aids and hearing protection
The various options depend on the type of hearing aid in place, and what is done with it. In all these instances, the basis is that the hearing loss can be made worse by noise.
1. Allowing hearing aids to be used in place of hearing protection as a general blanket policy
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 an EN352 assessed SNR value 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.
2. In-ear hearing aids without an upper volume limit, worn under an ear muff
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 an ear 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.
3. In-ear hearing aids with an upper volume limit, worn under an ear muff
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 (not in place of 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 our 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.
As an employer, it would be prudent to have sight (and preferably a copy of) the hearing aid’s documentation stating there is an upper volume limit.
Style of muff / defender to try
You can try the Honeywell Verishield range which have deep cups and are designed to help with this so could be worth a go, but there is a good chance there will still be an issue. Otherwise, it is a case of hearing aid off and removed, ear muff on, even if that leaves the wearer unable to hear much at all.
4. Saying they will turn the hearing aid down when needed
Sometimes an employee offers to turn the hearing aid's volume down when wearing hearing protection or in a high noise area, 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. It is not a reliable control method and shouldn’t be used.
Hearing which cannot be made worse by noise is a possible exemption
Not all forms of hearing loss can be made worse by noise and this does offer some hope to people who suffer from these types of loss. If, for example, the damage is to the cochlea then excess noise may not be able to cause further harm as the person is incapable of receiving 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 G.P. 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 and they can use their hearing aid.
Without this external verification though, you have to proceed on the assumption that the hearing loss they suffer from can still be made worse by high noise levels, and that the impact of further losses on them can be disproportionately large.