Who to include in health surveillance for noise exposures (hearing testing)
The UK’s Noise Regs require anyone who is regularly exposed at work to a daily noise level of 85 dB(A) or above, or who meets the 137 dB(C) peak limit or above, to be included in a hearing health surveillance programme, or as it often more colloquially called, workplace hearing testing. Getting the right people involved is important.
Headlines of a hearing health surveillance programme for noise at work
Applies to anyone regularly meeting either of the 85 dB(A) or 137 dB(C) exposure limits.
Basically, if someone needs to wear hearing protection at work as a normal part of their job then they need to be included in a health surveillance system.
It is critical to make sure the right people are included, which means everyone who is at risk from noise but importantly specifically not including people who do not have a regular exposure to noise.
Don’t under-do it but also don’t over-do it. Covering everyone who works there irrespective of where they work is not only of no benefit to safety but is actively detrimental
(I keep taking about ‘limits’ in this as that is what most people call them so I use that for clarity, but for accuracy the 85 and 137 figures are the ‘upper exposure action values’).
The people who should be included in a programme of health surveillance for noise
Anyone who is ‘regularly and frequently’ exposed to a noise level of 85 dB(A) or above, or who hits the 137 dB(C) peak exposure level, should receive health surveillance.
Don’t forget, this means they have an average of 85 dB(A) or more over their working day, not that they occasionally have an exposure to that kind of noise level.
The ‘regularly’ there is doing some heavy lifting and no, ‘regularly’ is not more tightly defined. Once a year every year would be ‘regular’ but irrelevant. Balance it with the ‘and frequently’ part. If you take the combination of that phrase to mean once a week you won’t be far wrong.
There are a couple of other groups to include as well if they work in an area which may be noisy at times, or who may occasionally have a hefty noise exposure, even if not regularly exceeding the limits.
You may be notified that some individuals have a health issue which makes them more susceptible to noise damage - there are some health issues which mean a noise which would otherwise be OK can now cause a problem.
You could have individuals who already have a critical hearing loss and for whom a small additional change in their hearing could have a disproportionately large impact on their lives. As the outcome is more severe for them, if they may be occasionally exposed to a high noise level then they should be included.
Extract from the HSE’s L108, Controlling Noise at Work.
The HSE’s guidance on who to include in a hearing health surveillance programme. (‘Upper EAV’ means the upper Exposure Action Value, i.e. the 85 dB(A) average or a peak of 137 dB(C) or over).
Risks of exceeding the peak dB(C) noise limit
One point of clarification here which may not be immediately obvious. The main focus tends to be on the average noise level, the one we compare to the 85 dB(A) limit, but there is also the peak limit of 137 dB(C).
In this peak limit the duration of the exposure doesn’t matter - the noise is so loud it can cause damage straight away. ‘Peak’ in this meaning is referring to instantaneous bangs, no matter how short. For example, someone whacking a metal skip with a sledgehammer to loosen debris may not exceed the daily average if they only do it once but they are likely to exceed the peak limit for that instant, as will anyone else close to them.
If you have someone who occasionally goes into a high noise area and there is a risk of this dB(C) peak limit being exceeded from a single bang, then they should be included in the health surveillance no matter how short their exposure is to the noise.
Exceeding the dB(C) peak limits is possible in workplaces but is generally far less common than breaching the dB(A) average limit. Your noise assessment should tell you if this is a risk.
If they routinely wear hearing protection, they probably should be included
Your noise assessment should identify exactly which jobs or positions should be included but the good rule of thumb is that health surveillance applies to people who routinely have to routinely wear hearing protection for a good proportion of their work.
That is people who frequently need to wear it for a proportion of their normal job, not someone who just puts it on to go into a higher noise area occasionally and not on any kind of routine.
The people you should not include in hearing health surveillance
This is as important as knowing who to include and companies should not take a blanket approach of just including everyone in the hearing testing.
The results of hearing testing at work are anonymous
Employers do not get to see individual results and the HSE say that the results should be anonymously grouped and then analysed to look for trends. So for example, are more people than would be expected being found to have poor hearing which could be as a result of noise exposures, or are a larger number of people showing a faster rate of deterioration in their hearing than would be considered normal.
Take an example of a company which has 50 people in the higher noise production area, but then another 50 who work in quieter areas, stores, yards, offices, etc.
If only the 50 who work in a high noise area are included in the hearing health surveillance, the trends of how many have weaker hearing than would be expected, or what proportion have deteriorating hearing, are focused just on those with a significant noise exposure. This can highlight a developing issue in the noise control systems in the workplace which needs to be looked at.
If the other 50 who do not work in a noisy area are also included, the overall trends are likely to be skewed towards showing no significant changes. Any patterns of developing losses will be buried among people who are perfectly fine but who also have no occupational noise risk. That can lead to exposure risks going unnoticed and more ongoing hearing damage to people.
Extract from the HSE’s L108, Controlling Noise at Work.
States that an employer should only see anonymised grouped statistical data and not individual results.
Specific examples of people not to include in hearing health surveillance
These are some types of job where the person should probably not be included in a hearing health surveillance programme.
A manager or office person who never goes into the higher noise area.
A manager or office person who goes into the high noise area occasionally, usually for relatively short periods. In these cases they do not meet that key phrasing of ‘regularly exposed’.
A stores person who either never goes into a high noise area or who only does so infrequently.
A sales person who occasionally takes clients into the production area to show them around.
Bear in mind the requirement for inclusion is not just that someone has a bit of noise over 85 dB(A) but that their average for the day exceeded it and regularly does so.
If it was indeed the case that anyone is included in hearing testing who has any kind of noise exposure over 85 dB(A) at any time in their working day, no matter how short or infrequent, then everyone who uses a hand dryer in the loo at some point during the day would need to be included. They are loud, well over the 85 dB(A) limit, and the noise exposure is occurring at work, but the exposure duration is short and occasional and trivial in terms of an average noise level over a day.
I would however refer back to the dB(C) peak exposure comment towards the start of this.
Agency staff in hearing testing programmes
A subtle but important one - the ‘employer’ is responsible for the provision of health surveillance, and for Agency staff the Agency is the employer, not the host company in which the individuals are working.
This means the Agency are responsible for health surveillance.
Why is this important? By way an example, I have a client who has around 19 of their own staff working in a high noise area, but over the course of a year over 300 different Agency staff also work in there. The client has no control over which individuals work there - they ask the Agency for a set number of people and that is how many they send. A person could be there for a week, a month, several months, that is down to the Agency, not the host company. The Agency knows where they are sending their staff and has them on longer-term employment, the host company cannot provide health surveillance for people who may change every week, but the Agency could.
Extract from the HSE’s L108 Controlling Noise At Work.
This makes it clear that an employer should only provide health surveillance for their own employees.
Summary of who to include in a workplace hearing health surveillance programme
The noise assessment should identify them for you.
It is people regularly exposed to either an average of 85 dB(A) over their working day or who regularly meet or exceed the 137 dB(C) limit.
A good rule of thumb is to include people who have to routinely wear hearing protection for a normal and fairly significant portion of their job.
People who occasionally go into a higher noise area do not meet that definition of ‘regularly’ or meet the average limit for a day. Individual short periods exceeding 85 dB(A) do not fall into the mandatory requirement.
If they have a risk of meeting or exceeding the dB(C) peak limit then include them.
Office staff, stores personnel, sales people, etc. usually would not be included.
Blanket policies of including all staff in a hearing health surveillance programme are detrimental to overall safety, not an improvement.
About the author
I have over 30 years of experience in workplace noise assessments including 20 of those as a specialist working in noise safety consultancy and now working solely in industrial noise assessment. I have also undertaken many thousands of workplace hearing tests in the past for workplace noise risk management. I hold certification in workplace noise assessment from the Institute of Acoustics, the NEBOSH Diploma and am a member of the British Society of Audiology.
