Hearing aids and hearing protection in high noise areas
One of the fairly common issues in a noise assessment concerns people who wear hearing aids but who also work in a high noise area so fall into the requirements for hearing protection to be worn.
Hearing aids do not mean someone is ‘deaf’
Before diving into it, it is important to flag up that having a hearing aid does not mean someone is deaf, indeed the vast majority of hearing aid users still have some hearing, and in a lot of cases can still have quite decent hearing, just not quite as good as it should be.
That means most people with hearing aids can still have their hearing made worse by excess noise exposure.
As a very very rough guide to how hearing works, when you lose hearing most of the time it is not a case of everything getting quieter - it’s not like wearing an ear plug and reducing the volume of everything. In a lot of people it is the part of the ear which senses quiet and sharp sounds which goes first and that has quite an impact as this is where a lot of the clarity in speech is. It is still there though, just not quite as sensitive as it was.
Too much noise damages those parts of the ear which hear quieter and sharp sounds first - noise takes away the person’s ability to hear speech clearly, especially when there is other noise around, and excess noise hits the quieter sounds and speech areas first. That means that even though someone is already weak in this region, they can still have their hearing made worse.
Over-selling of hearing aids
A sub-issue to this is that a LOT of people with hearing aids don’t actually need them at all. Up to October 2024 I also did hearing tests at work and had a team of staff who did them. We covered around 300 workplace hearing tests a week on average and I’d done that for 20 years, that’s a lot of ears and over 1/4 million hearing tests.
Without fail, every couple of weeks in the more recent years we would get someone who came in for a hearing test wearing hearing aids who pronounced themselves ‘deaf’ before we’d even started. They would then take the hearing aids out and proceed to have an entirely normal conversation - warning sign number 1. We would then stick them in the booth and do a hearing test and they came out as absolutely fine for their age. Almost inevitably they were a 40 or 50 year old with the normal hearing of a 40 or 50 year old.
When you questioned them, the story was always the same. They were concerned about their hearing (usually missing speech when there is other background noise around, which is so common it is verging on normal as you get older) so went to get a hearing test on their local high street. The person there dutifully showed them a graph of their result and showed them how much worse their hearing is now compared to the perfect hearing of a teenager, and proceeded to tell them how a hearing aid would make it better. Which technically it would, but as it would for about two thirds of the entire population.
So they went to a high street shop, paid £25 or whatever for a hearing test, and ended up being recommended to spend anything from £2,000 to £4,000 on hearing aids which the shop helpfully sorted out for them. What a coincidence…
Hearing aids and their impact on noise exposure
Hearing aids do not block out noise to a level which is certified as hearing protection - I.e. to EN352.
That is important as it means if a person wears hearing aids in a loud environment of say 90 dB(A) without hearing protection, the hearing aids don’t block that out and they still get a noise level of 90 dB(A) reaching their ears.
As the vast majority of people with hearing aids can still hear something, if they still have hearing at the higher frequencies then the excess noise can and will make their hearing worse.
Not wearing hearing aids or hearing protection in a high noise area
There are broadly two groups of people here, those who can have their hearing made worse by high noise levels and those who cannot. Very few fall into that latter group.
Standard approach is that hearing protection still has to be used
The basic approach has to be that hearing protection must be worn.
This is because if you take the approach of letting someone not wear hearing protection who has a hearing aid, chances are they still have some level of higher frequency hearing and the excess noise will make that worse. Already-poor hearing does not make them invulnerable.
Indeed, the duty of care to ensure someone is wearing hearing protection who also has hearing aids is arguably higher than it is for someone with normal hearing. If a person with normal hearing loses say 20dB of high frequency hearing then the impact on their life will be negligible, they probably wouldn’t even notice it. If someone with already-poor hearing loses 20dB it could be the difference between being able to hear some speech and not being able to hear speech at all, far more significant.
Hearing aids worn under hearing protection
This is one possible route to controlling it. If the hearing aid is small enough that it can be worn under the hearing protector then there is no reason why that can’t be permitted.
The risk to people from excess noise is the noise coming from the workplace, not the hearing aid, especially as most are volume-limited or tuned to that person’s hearing. If the hearing protection blocks out the dangerous element of the workplace noise then the hearing aid will not add it back in.
What I mean by way of an example: If a factory is at 90 dB(A) and the ear muff knocks that down to 65 dB(A), that is roughly the same as an office. If the hearing aid is under the muff, as far as the hearing aid is concerned the noise level it is working in is the same as an office, so it should just adjust the noise levels for the wearer exactly the same as it would in an office or at home. The fact it is under an ear muff doesn’t mean the hearing aid will increase the noise levels back to the same as it is in the factory outside the muff.
Hearing aids which cannot be worn under an ear muff
If the design of the hearing aid is such that it cannot be worn under the ear muff or stops the muff getting a good fit and seal, then the hearing aid has to come out and the hearing protection be worn. If that means someone can barely hear anything then so be it, but it doesn’t negate the need to protect them from the high noise and the potentially severe impact of further hearing loss. That potential loss is possibly life-changing and permanent so cannot be set aside in favour of just permitting hearing protection not to be worn.
In cases like this, you need to look at your risk assessment(s) for that job or person. Can they still hear things like fire alarms or do you need visual warnings or a something like a buddy system. Can they still hear moving vehicles in their work area if there are any, and if not do you need to provide a barrier or locate them somewhere away from the vehicles, etc.
People who cannot have their hearing made worse
A small percentage of hearing aid users will indeed have hearing which cannot be made worse by noise. These are usually people who cannot hear a thing when the hearing aids are taken out.
If someone has hearing which falls into this, then if they provide a written confirmation of the fact noise cannot make their hearing worse from a doctor, G.P. or audiologist, then it is OK for them not to wear hearing protection as it does nothing in their case. Frankly the only real function their ears are providing is keeping glasses straight.
But employers must have that in writing, you need some kind of proof that noise cannot impact someone’s hearing and their word on it is not enough. A lot of people dislike wearing hearing protection and over the years of this job I’ve heard a hundred times ‘I have bad hearing so I don’t need to wear hearing protection’ from people who really don’t have a clue what their hearing level actually is, they just don’t like wearing PPE.
Apple AirPods Pro 2 as hearing aids and hearing protection
Apple are in the process of rolling out a hearing aid function for the Air Pods Pro 2, where they can act as a hearing aid, amplifying speech. It is currently US and Canada only but will no doubt land in the UK incoming months. Just to add to the misery, they are also marketing it as a ‘hearing protection’ function.
No doubt other headphones and ear bud manufacturers will follow suit soon.
Being both a noise-nerd and a tech-nerd, I used a spare phone set to the US and tried the beta pre-release of the software and it is quite good actually - as a sufferer of noise induced hearing loss myself it genuinely does help make speech clearer in a noisy background.
But, me choosing to use Air Pods Pro 2 as hearing aids does not make them hearing aids, i.e. it is not a prescribed thing for an independently measured hearing loss, it is a personal choice to use them that way. Pretty much everyone has some form of hearing loss - as you get older it is normal, so someone doing a hearing test on their phone and choosing to use Air Pods Pro 2 as hearing aids does not mean they have a clinically-recognised hearing loss.
That means someone cannot argue that they need them as ‘hearing aids’ in the workplace to get around the ban on use of them as hearing protection.
Also, despite Apple using the term ‘hearing protection’ liberally in the marketing, they are not certified to EN352 and are therefore not hearing protection for use at work.
