You’ve been tasked with setting up an audiometric testing programme for employees at work, or have inherited one which has stagnated a little and fallen out of date, and want some tips on what is needed. First tip, when someone approaches you and there is a possibiity of them saying ‘can you manage our audiometric testing screening hearing thingy’, do not make eye contact, pretend you have sudden hearing loss and walk in the other direction. Quickly. But, assuming you failed at that point and got lumbered with it, what does an audiometric testing programme entail and what do you need to do?
This is an overview of what to do, from why do it, setting an audiometric testing programme up through to what results to expect and what to do with them.
When is occupational audiometric testing needed?
First question is do you need an audiometric testing programme at all, and this comes down to your noise assessment. If the noise assessment has been done properly it should say clearly on there whether you need audiometric testing or not. If it doesn’t, the other criteria is if you have employees routinely exposed to noise levels over 85dB(A), then you need a screening programme. Occasional exposure is fine and it is the ‘routinely’ part which is important.
What is an audiometric test when done for screening at work?
An audiometric test done for work is at heart a simplified version of a hearing test, with the focus being on determining if an employee has hearing losses which potentially may be related to noise, or is at increased risk of noise-related losses. It is called ‘pure tone audiometry’ as the sounds used are clear tones, unlike some more detailed tests which an audiologist may do.
Screening audiometric testing is very much a backstop (to raise the spectre of a Brexit word even here). If you have done a noise assessment, reduced noise levels where possible and ensured everyone is wearing appropriate hearing protection, then technically there is no risk of high noise exposures and no chance of hearing losses developing. But, audiometric testing is a way of ensuring this is true as it can identify deteriorating hearing levels long before the person themselves becomes aware of it.
The results are categorised according to a system set out by the HSE, again with the focus being on identifying potential noise issues.
Important point: Results ‘expire’ after three years, meaning the HSE have set a three year limit after which the effects of natural age-related deterioration can begin to mask noise-related losses so comparisons become unreliable.
Who to include in the audiometric testing programme
It’s back to that word ‘routinely’ again, so any employees who are routinely exposed to noise levels over 85dB(A). In all likelihood that’s going to be production staff, but may also include other managers who regularly spend time in the high noise area. You may have sales people who spend a lot of time in production areas with clients.
We would also recommend considering including drivers of vans or HGVs. Here is why.
Oh, and agency staff are the responsibility of the agency, not the host company. Don’t get lumbered with the bill for testing Agency staff.
What about new starters?
A lot of companies tie themselves up in knots about new starters. We have some information on dealing with new starters in detail, but in a nutshell: If you have reduced noise levels where possible and ensured everyone is wearing appropriate hearing protection then technically there is no risk of high noise exposures and no chance of hearing losses developing. If you get a new starter who begins their employment the week after your last audiometric testing session was done, there is therefore no risk of you making them deaf in the next eleven months so best advice, don’t worry about it and just include them in the next scheduled session. There are ways to do them sooner, but even though it is more money for us, we would recommend against it.
Is attendance at an audiometric test voluntary?
If your noise levels are over 85 dB(A) then no, the employer has to provide audiometric testing and the employee has to attend. The employer cannot choose to make attendance optional and employees cannot opt-out.
What are the basic requirements for a programme?
The Noise Regs require a programme of screening audiometric testing and it is not a one-shot process, but is ongoing. We have a page explaining the frequency of audiometric testing in detail which may help.
The testing should be done according to both the British Standard for audiometry and to the British Society of Audiology’s standards. There is a page here giving you a cheat-sheet on what these are so simply make sure any supplier doing the tests meets these.
Important: Self-operated tablet based audiometry systems do not give standards compliant testing, no matter what claims they make.
The audiometric tests should identify people who are perfectly fine, and also a small number who may have some issues relating to their hearing which causes increased risk at work. Your supplier should tell you what to do about these people after the tests are done.
You must tell your employees what the programme is, why it is being done and who is going to be the person managing it within the company.
Choosing an audiometric testing provider
You have your list of employees who need an audiometric test, so now you need someone to test them. Some pointers on this:
You have the list of mandatory audiometric testing standards which screening must comply with so use that as a checklist when looking at quotes.
We also have a page here on what red flags to look out for as signs of poor audiometric testing. Use this and that list of standards audiometric screening must comply with and you won’t go far wrong.
As a minimum, make sure the providers you choose include:
Daily verification checks of the equipment in their operating procedure
Measure noise levels in the booth (or room if not using a booth)
Include an otoscopic examination of the ear (a visual inspection)
Never let the attendee put the headphones on themselves.
Important: For testing to be compliant and therefore reliable enough for employee safety and defending possible future claims you must have all these and no tablet-based system does that.
One tip: remember faster isn’t always better as there is a minimum time the actual ‘hear noise press button’ part takes, and promises of 40 tests in an eight hour session can only mean corners are being cut.
Different types of audiometric testing services
Tablet-based self-operated systems - hopeless and non-compliant and should be avoided.
Testing in an office or meeting room - can have some value if no outside space. But the environment must be silent - no audible voices or telephones for example. Even if the operator uses noise-reducing headphones this is important.
Testing in a mobile clinic - this will give you the best service. The environment is controlled, the testing can be standard-compliant, and because the clinic is specifically geared up for it, testing is often faster so you have less time away from work per person.
Costs-wise, there isn’t often much between them.
On the day(s) of testing
Ideally, there isn’t too much to do on the day. Your provider should have given you an appointments schedule so just send the people out as needed.
The audiometric testing results
When you get your results all the tests should be assigned one of four categories.
Category 1 - all is good
Category 2 - a pass but getting a bit weak
Category 3 - weaker than it should be for the person’s age and gender
Category 4 - the hearing has deteriorated significantly since their last test.
An important point is that categories 1, 2 and 3 are levels of hearing ability - good, middling and poor. Category 4 though is not a measure of how good someone’s hearing is but is a measure of rate of change, so someone could be Category 4 but still have good hearing, just that it was even better last time. Category 4 can only be assigned where this is the second or subsequent audiometric test as it uses old data to compare against.
A number of people who have a loss may be referred for further examination. We have more detail here on how we recommend employers manage referrals in our testing.
Audiometric testing confidentiality
This is an area you need to manage carefully and we have a page on employer access to audiometric testing data which may help, along with this one on storage of audiometric testing records. It is OK for the company to hold the records, indeed it is preferable that this happens as you then have it for future comparison, claims, etc. As some key points:
One person only in the company should see audiometric testing results, and this would be the person managing the tests. Nobody else should see identifiable results without employee permission. This means an entire HR department should not have access to identifiable records for example, just one person.
That one person can be anyone within the company so can be HR, H&S, Occ Health, or a Production Manager, finance person, anyone. What matters is that this person only has access. To be clear - they do not have to be a nurse, or ‘qualified in audiometry’, or H&S.
Audiometric testing records must be stored securely with access limited to the one person managing the programme.
Audiometric testing records must be stored separately from HR employee records. L108 is very specific about this.
If you have someone with problem hearing and need to talk to their manager about it, you can recommend actions to their manager (such as improved hearing protection or improved compliance with it) but must not tell the manager any medical information without the employee’s permission.
Auditors and audits
You should also be careful with internal and external audits as unless the employees have given explicit consent, in writing, the auditor may not see identifiable audiometric testing results. This applies to just about any audit, be it quality, a health and safety one such as from a parent company, financial, legal compliance, etc.
Pretty much the only inspections who can demand access are the HSE looking at it to ensure legislative compliance. More detail on auditor access to audiometric testing is here.