Who to include in an audiometric testing programme
The requirement is that if you have anyone who is routinely exposed to noise levels averaging over 85dB(A) then the employer needs to implement a programme of health surveillance. That word 'routinely' is important as it means not everyone who is exposed to high noise has to be put through an audiometry programme.
This being health and safety, there is no actual definition of 'routinely' but you can apply some common sense here. For example:
- A receptionist occasionally enters a production area to find someone and isn't there long or often. They would not have to be included.
- A sales rep occasionally takes a customer into the production area but not all that often. They are there for maybe a couple of hours. That would not need to be included.
- A sales rep takes customers into the production area say twice a week every week for a couple of hours each time. That's more borderline and can depend on the actual noise levels - for example if it is only say 86 or 87dB(A) in there then their exposure is very low and you could omit them, whereas if it is 96 or 97dB(A) in there then they can get a good noise dose in a short time so include them.
If you have agency staff there is a separate guide on how the health surveillance parts of the Noise Regs apply to them here.
Many employers just include everyone and treat it as a perk for those who work in quiet areas, with the distinction being that if someone works in a high noise are then they have to attend for a hearing test, while if someone works in a quiet area the choice to whether to take up the offer or not is up to them.