How often does hearing testing have to be done?

One of the key elements of a noise assessment is identifying who needs to be included in what the HSE call ‘health surveillance’, a slightly Orwellian way of saying ‘hearing testing’. The noise assessment should identify everyone who is routinely exposed to a noise level over 85 dB(A) and these are the people who also need hearing tests.

Hearing tests are not a one-off thing and to meet the health surveillance needs they must be an ongoing process. The HSE outline parts of it in the Noise Regs.

Extract from L108 Controlling Noise at Work

To be clear, that comment about ‘three yearly intervals’ is not the end of it and that comment about ‘more frequent testing may be required’ is important. You cannot simply test everyone every three years to be compliant with the health surveillance needs, nor every two years for that matter.

A plainer guide to the retesting frequencies is:

• A person gets their first test, either when the hearing testing programme starts or whenever the first session is after they start work.

• The second test is then one year later. That is very clear in the HSE’s requirements above.

The first test establishes how good their hearing is against normal standards for their age and sex, and then the second test confirms rate of change by comparing the two. Subsequent tests are then based on the result of that second test.

• If the second or subsequent test is Category 1 then they are next due in three years.

• If the second or subsequent test is Category 2 they are next due in two years.

• If the second or subsequent test is Category 3 or 4 they are next due in one year.

There are other things which can change this though. For example, if the medical professional overseeing the hearing testing recommends it then a test could be required after six months for someone with a problem. E.g. if someone has a significant deterioration between two tests then the medical person may recommend a more frequent test to determine if the hearing has stabilised or improved again, or is still getting worse.

What about new starters?

An element of common sense is needed here. Technically, they should be tested as they start but that could quickly make a complete mess as people have retest dates scattered all through the year rather than in batches. For an employer that becomes a nightmare to manage, and very expensive, unless they are big enough to have in-house provision for the hearing tests.

For my own recommendation, provided you have a noise assessment in place, the hearing protection has been assessed as suitable for the noise risk and you have systems in place to ensure it is being worn, then the new starter is not actually experiencing any high noise exposures. You are not going to make them deaf in a few months. Personally I would roll them into whenever the next batch is planned, but it is important to make sure they are included and are not off work when it takes place.

If you have a lot of new starters then maybe plan an interim testing day between the main batches as it becomes more cost-effective then.

What about non-attendees or missed people?

No matter how carefully you plan a hearing testing session it is inevitable that someone will be off sick on the day, or on holiday, or simply not turn up. The answer for dealing with it is the same as new starters really, technically a catch-up should be planned but that may simply not be reasonably practicable for an employer to do for one or two people.

I would use some common sense again and look to roll them into the next session but importantly, do not let people become serial non-attenders. Also, if you have people who have a known issue, such as Category 3 or 4 on a previous test, plan the testing around their availability so you know they will be present as these are the most important to keep within the testing plan.