Hearing aid users and hearing protection in high noise areas
One of the fairly common issues in a noise assessment concerns people who wear hearing aids but they also work in a high noise area so fall into the requirements for hearing protection to be worn.
There is a video for those who prefer it, or all the text below explains the issues for people who prefer reading.
A review of the ways to deal with people who wear hearing aids and who also have a need for hearing protection at work.
What the HSE say about it"?
To establish the starting point for the issues around this, there is no exemption from the requirement to wear hearing protection for people who have hearing aids. This is what the HSE say about it in L108, the document outlining their rules for noise safety at work:
Extract from L108 on the use of hearing protection for people with medical issues
The key part there is that “a medical condition does not exempt a worker from wearing hearing protection where the risk assessment has shown that hearing protection is required”. That applies equally to hearing loss (so hearing aid users), infections, feelings of irritation in the ears, etc.
There is some good sense behind this and it comes down to the fact that already-poor hearing does not make them invulnerable to further damage from noise. Indeed, the duty of care to ensure someone is wearing hearing protection who also has hearing aids is arguably higher than it is for someone with normal hearing.
If a person with normal hearing loses 20dB of high frequency hearing from noise damage then chances are the impact on their life will likely be negligible, they probably wouldn’t even notice it in most cases. If someone with already-poor hearing loses another 20dB due to excess noise though it could be the difference between being able to hear some speech in normal conversations and not being able to hear speech at all, a far more significant deterioration and impact.
If there is a noise risk then the baseline is that hearing protection still has to be worn. The HSE say there is no exemption for hearing aid users, and the potential impact of more hearing loss can be worse for people with hearing aids than for those without them.
What kinds of people need hearing aids?
Hearing aids are increasingly common as more people get access to them, and as they become smaller and more discrete more people are happy to wear them, but hearing is not a binary ‘deaf / not deaf’ issue and just because someone has a hearing aid does not mean they are deaf. This is important as it means noise can still damage their hearing for most people.
Hearing aids do not mean someone is ‘deaf’
The vast majority of hearing aid users still have some hearing, and in a lot of cases can still have quite decent hearing, just not quite as good as it should be and that means most people with hearing aids can still have their hearing made worse by excess noise exposure.
As a very very rough guide to how hearing works, when you lose hearing most of the time it is not a case of everything getting quieter - it’s not like wearing an ear plug and reducing the volume of everything. For a lot of people it is the part of the ear which senses quiet and sharp sounds which goes first and that has quite an impact as this is where a lot of the clarity in speech is. It is still there, just not quite as sensitive as it was, and everything now sounds rather muddy and indistinct, a big mush of noise.
The key risk is that that too much noise also damages those same parts of the ear which make things sharp and clear. That means that even though someone is already weak in this region and has a hearing aid for it they can still have their hearing made even worse by too much noise.
Over-selling of hearing aids
A sub-issue to this is that quite a lot of people with hearing aids don’t absolutely need them - they are a comfort and convenience rather than a necessity.
Up to October 2024 I also did hearing tests at work and had a team of staff who did them. We covered around 300 workplace hearing tests a week on average and I’d done that for 20 years, that’s a lot of ears and over 1/4 million hearing tests overseen.
Without fail, every couple of weeks in the more recent years we would get someone who came in for a hearing test wearing hearing aids who pronounced themselves ‘deaf’ before we’d even started. They would then take the hearing aids out and proceed to have an entirely normal conversation with us - warning sign number one that they may not be as deaf as they thought they were. We would then stick them in the booth and do a hearing test and they came out as absolutely fine for their age. Almost inevitably they were a 40 or 50 year old with the normal hearing of a 40 or 50 year old.
When you questioned them the story was always the same. They were concerned about their hearing (usually finding it hard to hear speech when there is other background noise around, which is so common it is verging on normal as you get older) so went to get a hearing test on their local high street. The person there dutifully showed them a graph of their result and showed them how much worse their hearing is now compared to how it would have been when they were younger and proceeded to tell them how a hearing aid would make it better. Which technically it would, but as it would for about two thirds of the entire population.
So they went to a high street shop, paid £25 or whatever for a hearing test, and ended up being recommended to spend anything from £2,000 to £4,000 on hearing aids which the shop helpfully sold to them. No conflict of interest at all there then…
What to do about people with hearing aids in high noise areas
Looking at each of the options in turn.
Route 1: Use of hearing aids as hearing protection
Hearing aids do not block out noise to a level which is certified as hearing protection - i.e. to EN352.
That is important as it means if a person wears hearing aids in a loud environment of say 90 dB(A) without hearing protection, the hearing aids don’t block that out and they still get a noise level of 90 dB(A) reaching their ears.
If there is a noise risk then the employer has a legal obligation to provide hearing protection and ensure it is used, and that means protection certified to EN352 and with an assigned SNR number, etc. Hearing aids do not have this so are not hearing protection, so cannot be used as protectors in a high noise area.
Using the hearing aid as protection is therefore not an option.
Route 2: Taking the hearing aids out and also not wearing hearing protection in a high noise area
As a general rule, again, no, this is not an option, although not quite so clear-cut this time.
There are broadly two groups of people here, those who can have their hearing made worse by high noise levels and those who cannot. The vast majority of people with hearing aids do fall into the first group where hearing can still be made worse by excess noise therefore no, simply not wearing either a hearing aid or hearing protection is not a permissible option.
The one exception to this and a possible solution for some
The one exception to this is the small percentage of hearing aid users who fall into the second group and have hearing which cannot be made worse by noise. These are usually people who cannot hear a thing when the hearing aids are taken out, total silence.
If someone has hearing which falls into this, then if they provide a written confirmation of the fact noise cannot make their hearing worse from a doctor, G.P. or audiologist, then it is OK for them not to wear hearing protection as it does nothing at all for them. Frankly the only real function their ears have is keeping glasses straight and they are providing no hearing function.
But employers must have that in writing, you need some kind of proof that noise cannot impact someone’s hearing and their word on it is not enough. A lot of people dislike wearing hearing protection and over the years of this job I’ve heard a hundred times ‘I have bad hearing so I don’t need to wear hearing protection’ from people who really don’t have a clue what their hearing level actually is, they just don’t like wearing PPE.
Route 3: Hearing aids worn under hearing protection
This is one possible route to controlling it. If the hearing aid is small enough that it can be worn under a hearing protector then there is no reason why that can’t be permitted and most hearing aid wearers do fall into this.
The risk to people from excess noise is the noise coming from the workplace, not the hearing aid, especially as most are volume-limited or tuned to that person’s hearing. If the hearing protection blocks out the dangerous element of the workplace noise then the hearing aid will not add it back in.
What I mean by way of an example: If a factory is at 90 dB(A) and the ear muff knocks that down to 65 dB(A), that is roughly the same as an office. If the hearing aid is under the muff, as far as the hearing aid is concerned the noise level it is working in is the same as an office, so it should just adjust the noise levels for the wearer exactly the same as it would in an office or at home or anywhere. The fact it is under an ear muff doesn’t mean the hearing aid will increase the noise levels back to the same as it is in the factory outside the muff.
This is the ideal approach.
Route 4: Hearing aids out, hearing protection on
If the design of the hearing aid is such that it cannot be worn under the ear muff or stops the muff getting a good fit and seal, then the hearing aid has to come out and the hearing protection has to be worn.
If that means someone can barely hear anything then so be it, but this still doesn’t negate the need to protect them from the high noise and the potentially severe impact of further hearing loss. That potential loss is possibly life-changing and permanent so cannot be set aside in favour of just permitting hearing protection not to be worn.
In cases like this, you need to look at your risk assessment(s) for that job or person. Can they still hear things like fire alarms or do you need visual warnings or a something like a buddy system. Can they still hear moving vehicles in their work area if there are any, and if not do you need to provide a barrier or locate them somewhere away from the vehicles, etc.
Noise-cancelling headphones as hearing protection
This is not a solution which can be used. Normal noise-cancelling headphones are not hearing protection so fail to meet the need for certified hearing protection to be used.
Even if someone uses in-ear buds to help with clarity in normal life, that doesn’t mean they are any different to the hearing aid issue so cannot be used in place of hearing protection.
What about someone who says no type of hearing protection is good and none of the options above will be followed?
You could have a situation where someone has a hearing aid and cannot or will not provide any kind of medical confirmation that their hearing cannot be made worse by noise, but they also refuse to either put an ear muff over it or to remove the hearing aid in the high noise workplace and wear hearing protection.
In this instance the employer is then effectively in the same situation as they would be for any other employee who refuses to wear hearing protection in a high noise area.
That means relocate them to a job which is outside of any noise risk (as per the HSE extract at the top of the page), or if there is no such possibility then employment has to be terminated.
An employer cannot knowingly allow someone to work knowing they are at risk which they would be in high noise with no hearing protection, whatever the reason for not wearing it, and if there is no other quieter job available then that employment cannot continue.
It goes back to the HSE’s statement above - medical conditions do not exempt someone from a need to wear hearing protection.
A style of ear muff worth trying out
What an employer should do is try a few styles of ear muff and see which a hearing aid wearer gets on best with, but both the employer and employee have to acknowledge that something has to be worn and just saying no to everything to carry on not wearing protection is not a solution. Sooner or later either a style has to be chosen or the ‘hearing aid out, hearing protection on’ route chosen.
Honeywell’s Verishield range of ear muffs have a particularly deep cup so are often worth trying for hearing aid users. They have a wide range of SNRs so can over most workplaces. The VS110 is a good SNR, has a deep cup and quite a soft cushion and I’ve seen it used favourably by a few hearing aid wearers.
