Why workplace hearing testing (health surveillance for hearing) is broken
I have done workplace hearing tests (audiometry) for over 30 years now, and for 20 of those worked as a supplier of them to client companies all over the UK, however in 2024 time was called on it, with me now just focusing on workplace noise assessments and another company took on the audiometric testing side of the business. My reason for this is that the UK’s system for hearing testing at work is now fundamentally broken and I believe no longer fit for purpose.
HSE changes to how they want hearing tests interpreted
The HSE changed their standard for how the results of hearing tests are to be interpreted, published in L108 Revision 3. It is important to recognise here that despite HSE inspectors seeing no difference between law and guidance, the law just says hearing testing will be done while the actual detail on how it should be done is in guidance. Guidance means an employer is free to follow it or do it another way, it is not law. But, as the HSE treat them as one and the same there is no point trying to argue otherwise with an inspector, especially if you get one who is about 12 years old, has H&S qualifications up the eyeballs but who hasn’t actually worked in industry.
The current system now says that someone who has a hearing test for the first time and who shows signs of potential noise damage must be a Category 3, no matter how good their hearing overall. This may be their first test, or they may have had them before but changed employers, or it may be ongoing but there no historical data to compare to, or old results are ‘expired’.
Category 3 is the bad one, that is the ‘fail’ and is the one where employers then have to arrange for a doctor’s review of the case, by which the HSE mean an Occupational Physician.
This takes no account at all of their overall hearing - any potential noise damage at all and they are a ‘fail’. They could still have hearing which is good enough to navigate by sonar, but under the revised system they are a fail and there is no allowance for leeway on that.
But how widespread is noise damage in hearing?
This is the nub of it, is what the HSE seem oblivious to, and is what has turned hearing health surveillance from a genuinely useful thing for both employers and employees and made it into something of no use to anyone. I am sorry to say it is now pretty much just a cost to keep the HSE happy rather than a protective measure for people in noisy environments.
In the current system the HSE have entirely ignored people’s normal lives, normal hearing patterns and even studies into what is ‘normal in hearing.
A notch is not diagnostic of noise damage
Quick background info for non-noise people: you will see ‘notch’ mentioned, this means a dip in the higher frequency hearing and it is this the HSE take as a sign of noise induced hearing loss (NIHL). If there is a notch in the result then as far as the HSE are concerned, that may be noise damage and the follow-up investigations are now needed.
This is what the ‘notch’ looks like - that dip at the right side of each graph.
If someone does a hearing test at work and sees a notch like that, then L108 now says that they must be a Category 3 if it is their first test, a fail. That notch is taken as noise damage. However, in 2010 the International Journal of Audiology published a very interesting (honestly) study which included:
“It is a common misconception that high frequency audiometric notches are diagnostic of noise induced hearing loss”.
And “A total of 39.6% had notches not attributable to noise (occupational or recreational or any other known risk factor)”.
And “This study concludes that high frequency notch without excessive noise exposures or any other known factor is common. It is neither diagnostic of, nor invariable with NIHL unless a convincing history of hazardous noise exposures [is present]”.
To unpack that:
The study found almost 40% of people who have no history of high noise exposures, socially or at work, still had a high frequency notch in their hearing.
So they have the notch but no noise exposure to cause it, the dip in the high frequencies is therefore perfectly normal hearing for them.
The study explicitly says the use of a notch is not diagnostic of excess noise exposure.
For anyone reading this who wants more on this study, the reference is International Journal of Audiology 2010; 49: 95-98, authors Victor Osei-Lah of the Queen Alexandria Hospital in Portsmouth, UK, and LH Yeoh of Epsom and St. Helier University Hospital, UK.
What that study is saying at heart is that 40% of the population have a high frequency notch in their hearing, despite no history of excess noise. Effectively that pattern of result is entirely normal for over a third of the population. However, if they have a hearing test, under the current HSE’s rules, they ‘fail’ no matter how good their overall hearing and the employer has arrange follow up Occupational Physician reviews, another cost.
The other problem is their own personal history of noise
As a personal example, I work in noise assessments now but my weekly average noise exposure is quite low - only a very small proportion of my working time is actually in a high noise place as there is a lot of report writing, travel, etc. And I always wear hearing protection. I am also a bloke in his 50s who hates gatherings of loads of people so my social noise exposure is negligible now.
However, in my late teens and into my 20s I spent a lot of time in nightclubs and loud gigs. I worked in the student union nightclub for three years, meaning being in nightclub noise pretty much six nights a week every week, including front stage for bands like the Prodigy where I couldn’t hear anything for two days after. I loved it. But it had an impact and now I have a good solid notch at the high frequencies in both ears even though my hearing overall is absolutely fine for a bloke in his 50s. Under the HSE’s older system I would have been an easy Category 1, by some margin. My hearing is perfectly normal for my age.
If I was to go and get a proper job now and that employer did hearing tests, under the most recent system I would now be a fail as there is noise damage there. The employer would have to arrange a doctor’s review, and pay for it, only to be told not to worry or more likely, some utterly useless arse-covering nonsense such as ‘wear double hearing protection’ would come back. All this despite the noise issue being some 30 years ago so a waste of everyone’s time and a waste of the employer’s money. Nobody has benefitted.
Under the older system we would have done the hearing tests, listened to their exposure history, seen that overall the hearing is still good for my age, talked about noise exposures now and seen there really is very little, and sent me on my way again. Future retests would confirm stability and all would be good. My history would support the pattern and that would have been the end of it. We trusted the people doing the tests to know what they were on about.
My own sample of hearing test results - how prevalent the ‘noise notch’ is
When I still did hearing tests I kept a tally of results and built up a sample size of a whisker over 5,000 hearing tests, cross-industry. That gave a notch rate of around 72% of attendees having some form of notch present in their hearing, so knocking on the door of 3/4 of all attendees having a notch and being a ‘fail’.
The critical comparison though is how many of those actually had a problem which would be beneficial to get checked out further? And the answer was somewhere around 4 to 5%.
So 5% of people would benefit from a deeper review of their hearing, but under the current system almost 75% are falling into it. 70% of them are a complete waste of time and money.
For quite a lot of companies, even in 2024, when we did a batch of hearing tests it was the first ones they had done which meant all the Year 1 gubbins about any notch being a Category 3 ‘fail’ and Physician follow-up review applied. We were getting companies with 100% fail and referral rates. Every single person was perfectly normal for their age - yes they had a bit of a dip but as we have already established, for 1/3 of them that’s their normal result anyway, and for the rest they’d had a slightly vigorous youth decades ago, or worked in mildly high noise jobs again decades ago. All would have been a Category 1 and very much normal for their age overall under the old system, but under the current audiometry system every single one was a fail.
The Occupational Physician Review side of it
This was another area where my displeasure grew. The HSE stress about the results being reviewed by an Occupational Health Physician (OHP).
In the old system we would tell people to go see their GP. The GP has their full medical history and can do their own hearing checks, and if they feel the need they can refer them on within the NHS for more detailed examination.
Now they are referred to an OHP. The OHP looks at the result and pretty much always comes back with exactly what the Tech or Nurse said originally anyway, except with some nonsense added on top to justify their own invoice. Often this is gubbins about ‘wear double hearing protection’ which really grinds my gears, no workplace needs people to wear both ear plugs and ear muffs together. They’d even come out with this nonsense statement when I myself had done a noise assessment on the site and the main issue with the PPE was that it was too strong for the noise risk already!
If the OHP thinks there may be an issue with the person’s hearing, what do they do? They tell the person to go see their GP. Why the hell not just go there in the first place then rather than pushing e-paper around for a while generating invoices for precisely nothing at all?
The HSE decided going via a GP was not sufficient on the basis that a GP doesn’t know about workplace safety, and they’re right actually, they don’t, but on the evidence of many years of experience, OHPs are no better, they don’t either.
Retesting is also often unrealistic cobblers now
Large employers are fine, they have a lot of people so can have hearing testing pretty much ongoing, but for smaller companies not so much.
Retesting is not just set as ‘once every X years’ but should be based on the results, which can be in a few weeks or a few months.
If a company has say 30 employees, they may end up with one or two who are then recommended to be retested say in 12 weeks. Maybe a person had a cold at the time and their result was a little off, maybe they’d been listening to loud music all day the day before, there are 101 reasons for this. I spoke to two HSE inspectors and they confirmed they would expect that employer to retest one or two people in line with that.
That is absolute nonsense! For a small employer the costs of hearing testing are not insignificant and now as well as the main batches of tests they are expected to do one person again because they had a sniffle at the last test? No hearing test provider is going to be able to pop out and do one or two tests at a cost which remotely in-keeping with this. They have to charge a decent rate as they have staff to pay, vehicles to maintain, and need to be profitable, so companies can end up paying hundreds of pounds for one or two tests.
This is hopelessly out of balance with the risk - frankly if the company has done a noise assessment and has assessed and provided hearing protection which deals with the noise and staff are safe, then what is the actual noise risk? None really - the employee is not going to be made deaf if they are just left to the next main batch of tests. The two inspectors I spoke to however were adamant, they would expect all these interim tests to be done. That’s just nuts and completely out of whack with the risk and what is ‘reasonably practicable’.
So I gave up on workplace hearing testing
I’m a bloke in his mid-50s now and have about a decade left in me of bothering people about noise. The impact of Revision 3 of L108 broke the hearing testing side of it so completely that I am not about to spend that last decade doing precisely nothing of any value other than generating costs and reports which do nothing for anyone. Under the new system I was doing very little more than pushing data around for the sake of it and not benefitting anyone.
Interestingly, I do come into contact with a lot of large organisations during my work and on many occasions, and getting increasingly common, I hear comments along the lines of ‘we’ve just stopped doing hearing tests now, it’s useless. The HSE will probably visit at some point and we’ll just do another session then when we get a rap on the knuckles, but that’s probably years off and we’ll save a lot of money in the meantime without anything detrimental to our staff’s health’. And you know what? Despite decades doing hearing tests and caring about people’s hearing, I have nothing in response to these comments, I don’t blame them.
As an aside, when I spoke to those two HSE Occ Health inspectors about workplace hearing testing, throughout the entire conversation their focus was on the process, the OHP reviews, the procedure, retests, and not once was the accuracy of actual tests considered. My takeaway was very much that the process is more important than the result.
