SCREENING AUDIOMETRY
Occupational health audiometric testing

Who should be included in the screening audiometry programme

Some guidance on who to included as well as the people working in a high noise area all time.

2023 marks 30 years of our owner’s experience in providing workplace audiometry

The HSE are a little vague on this, but they do give some additional guidance on which people employers should be including in the health surveillance programme aside from the obvious.

The most obvious one is ‘anyone who has to wear hearing protection every day at work’, but there are other groups as well.

Some key people to include

The main 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, meaning audiometry. Everyone working in a higher noise environment should be included, but that word 'routinely' is important as it determines whether people 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.

People who are close to the limit but not over

L108 does contain a provision that anyone who is measured as being close to the 85 dB(A) limit should be treated as exceeding it. This is to take account of natural variances in daily working. This would mean that if you have people who are around the 84 dB(A) average exposure level then including them would be good.

It is worth noting that the ‘treat people who are close to the limit as exceeding it’ thing is in the HSE’s guidance rather than explicitly in the regulation itself.

Remember it is average exposures rather than peak values

It’s worth a reminder that when identifying people who may need hearing screening at work, we are looking at people who are routinely exposed to daily average exposures of 85 dB(A) and over. A short-duration peak of 92 dB(A) doesn’t necessarily mean someone needs to be included in the audiometry programme. For example:

  • If someone has six hours at less than 75 dB(A), but then an occasional exposure for a couple of minutes two or three times a day of 92 dB(A), then their average for the day will be well below the 85 dB(A) level so they do not need to be included. (Their daily average is about 76 dB(A) in this example).

  • If someone has six hours at less than 75 dB(A) but then continuous exposure of 92 dB(A) for another hour and a half, then they do need to be included. (Their daily average is now 85 dB(A) in this example).

People with hearing aids or who say they are deaf

The phrase ‘deaf’ when used in everyday language covers a huge range of hearing abilities, going from people who are a bit weak for their age through to people with no hearing at all. It is VERY common, and something which happens a few times every week in the people we are testing, that someone comes into the audiometry unit and says they are ‘deaf’ but then when tested their hearing is not that bad at all, just not quite as good as it should be for their age.

Who sold them the hearing aid..?

This is not helped by a trend we see more and more often where people come in for an audiometric test who say they are ‘deaf’ and have hearing aids, but when we do the test they are perfectly fine. Sure, their hearing is not what it was when they were 18, but they’re 48 now and it’s not supposed to be the same as when they were 18. When questioned about who said they were deaf it inevitably turns out that they were worried about their hearing, went for a private hearing test, and then the lovely helpful people doing the test said they do have some losses but this £400 hearing aid will sort them out. Funny how in these cases the people doing the hearing test and saying they have a problem are so often the same ones who have sold them the hearing aid…

Deafness and noise exposure

It is important to understand therefore that most deaf people can usually still hear something. It is those frequencies with some remaining hearing ability, albeit reduced, that the hearing aid is amplifying for them. In a lot of cases their remaining hearing can still be impacted by excess noise and many forms of deafness can still be made worse by excessive noise exposure.

It is usually more important these people are included in the audiometric screening than people classed as ‘normal’ as a small further reduction in hearing may have the potential to make a large impact on their life, both at work and at home.

Agency staff

If you have agency staff there is a separate guide on this site on how the health surveillance parts of the Noise Regs apply to them, but basically the Agency is the employer so it is up to them to test their staff, not the host employer.

Drivers

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 seat belt 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 an hour I checked the result and it was around 87 dB(A), exceeding the upper limit. That was 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.

I have asked the HSE three times now for information on how they manage this risk for their people but every time they've not answered me. 

Clearly, wearing hearing protection while driving is nonsense, but what it does mean is that we would recommend that an audiometric screening programme also includes anyone who may drive regularly for work, even if that noise has not been measured. So possibly think about including your regular HGV or van drivers, delivery drivers, etc. and any sales reps, managers, engineers, etc. who may also regularly drive for work. That way at least you have the fall-back position that their hearing is being checked and, hopefully, confirming no ongoing deterioration.

Other people ‘at risk’

You may have some people who exceed the 80 dB(A) lower limit but not the 85 dB(A) upper limit but who are known to be particularly susceptible to hearing damage from noise. This is very rare but can happen, for example some other illnesses or conditions can make your ears more easily damaged by noise, same with some medicines or drugs. If you are aware you have such people then they should be included in the audiometry programme.

Be careful when over-testing

Some companies just test everyone, either as a precautionary approach or because they make it available to other staff as a benefit. There is a slight negative in this in that if they are then identified as having a problem which is potentially noise-related (could be social noise from decades ago) current HSE standards then require a doctor’s follow-up review of all cases where that applies. The company has unfortunately created more work for themselves by being nice and including everyone, even though they don’t need it.

Conversely, if a group are due in three years, it is best to retest them in three years and not more frequently. The more you test the more you are likely to come up against temporary issues which impact hearing, which the company then needs to get involved in.

Over-testing is a nice thing for companies to offer people, but be careful with it.