Who to include in hearing test programmes at work
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, otherwise known as audiometry. So, clearly everyone working in the higher noise environment should be included, but that word 'routinely' is important as it means some others may or may not need to be included.
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, but basically the Agency is the employer so it is up to them to test their staff.
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.
Now here is something nobody in enforcement or health and safety advice industries likes to talk about, but what about people who drive for work? That could be truck or van drivers, but also managers, sales reps, service engineers, indeed just about anyone who does any kind of regular journey for work which is not simply to and from their main place of work (as that one doesn't count as work).
I placed a noise meter on the passenger seatbelt of my car for an hour driving down the M6, with the stereo on quietly enough to be heard but not booming away. Besides, it was Radio 4 and one does not make radio 4 boom as that would be most unseemly. After the hour I checked the result and it was around 87 dB(A), so exceeding the upper limit. That was actually artificially low as the stereo is normally on louder than that, or the window open, or any one of a few things which can make the noise higher. And it was in a Jaguar XF, so a naturally very quiet and well insulated car, certainly one which is much quieter than my previous cars. I could easily get the levels to around 91 dB(A) without trying, and at that level the driver has about two hours before they exceed their limits and run the risk of hearing damage.
I have asked the HSE twice now for information on how they manage this risk for their people but both times they've not answered me.
Clearly hearing protection while driving is nonsense, but what it does mean is that I would recommend an audiometry screening programme includes anyone who may drive regularly for work, even if that noise has not been measured. So your HGV or van drivers, deliver drivers, any sales reps, managers, engineers, etc. That way at least you have the fall-back position that their hearing is being checked and, hopefully, confirming no ongoing deterioration.