By Daniel Morgan-Williams, Founding Director, Visualise Training and Consultancy Ltd.
Picture a woman with hearing loss working alone in a small office at the end of a corridor. Her hearing aids are out because her ears were sore after a long morning. The door is closed. In the main office, the fire alarm sounds and everyone starts to leave. Each person assumes someone has told her. Nobody has.
It is the kind of gap that rarely appears in a risk assessment until it matters. Most workplaces rely on a sound to say that the building must be evacuated, and a sound only works if the person can hear it. For an employee who is deaf or has hearing loss, the question is simple and uncomfortable: how would they know?
What the guidance says
The Home Office guide, Fire safety risk assessment: means of escape for disabled people, first published in March 2021 and updated in September 2023, applies to England and is supplementary guidance to the Regulatory Reform (Fire Safety) Order 2005. It makes the problem plain. Where there is only an audible alarm, a deaf person may not hear it or public address announcements. It describes visual alerts such as flashing beacons and paging systems as the preferred approach, and notes that for lone or out-of-hours working, a visual alarm system or vibrating pager system may be imperative. Vibrating pagers can alert people who are deaf or hearing impaired and can also indicate which direction to travel. Any such equipment needs to be tested regularly.
The guide is just as direct about people. A buddy may be the most suitable way to alert a deaf person, but it warns against doing this informally, in case everyone assumes someone else has given the warning. Staff who alert deaf colleagues should have deaf awareness training. Fire wardens should not expect a shout to be enough, and should physically check areas such as single offices, toilets and changing rooms, where it is safe to do so. Raising the voice is unlikely to help, and a written note or sign may be needed.
RNID’s health and safety guidance for employers, last updated in May 2026, adds practical points. It advises flashing alarms in all areas, including private and quiet spaces such as toilets, locker rooms and prayer rooms, and working with each employee to choose a desk position where they can see the alarm light. It suggests telling fire marshals which employees are deaf, have hearing loss or have tinnitus, and giving marshals deaf awareness training. It also notes that an employee with tinnitus may need advance notice of fire drills, so they can leave the building beforehand. For lone workers and large sites, it describes critical alert paging systems.
Everyone should have the chance of a personal plan
The Home Office guide recommends that all staff are given the opportunity to have a personal emergency evacuation plan at induction. The conversation should cover the alert systems available, how to raise the alarm and contact the control room, and the evacuation routes and assembly point. Information should be in plain English, with pictograms if helpful, and some deaf people may prefer instructions explained through a British Sign Language interpreter. The guide also recommends that disabled people are consulted about their own plan, and that their opinions and experience are sought and respected.
That last point matters. Someone who has lived with hearing loss for years knows exactly where the weak points are: the meeting room where the alarm cannot be seen, the evening they were alone on the floor, the day the hearing aids were in the drawer. The employer who asks will learn more than any checklist can say.
The legal picture, in brief
In England and Wales, the Fire Safety Order requires the responsible person to carry out a fire risk assessment that takes account of everyone likely to be on the premises, including disabled people, and to have an emergency plan. Scotland and Northern Ireland have separate fire legislation. The Equality Act 2010 also places a duty on employers to consider reasonable adjustments. The Home Office guide goes further and says that restricting a deaf employee’s working hours because evacuation provision is inadequate may amount to unlawful discrimination. Whether any individual arrangement is adequate depends on the building, the person and the circumstances.
Questions to ask in your own building
For health and safety teams, a few questions turn a vague worry into a check. Does every area, including toilets, small offices and meeting rooms, have a visual alert as well as a sound? Is there a named person responsible for alerting each employee who would not hear the alarm, and is it written down? Who covers when that person is absent? Are pagers or other devices tested and recorded? What happens out of hours, or when a person is working from a different site?
For HR and occupational health, the questions are about knowing and asking. Does the induction process offer everyone a personal evacuation plan, and does it say how someone can request one? Do fire marshals know who needs to be alerted, with that person’s agreement? Is a change in hearing noticed and followed up, so the plan changes with it?
Where a workplace assessment fits
A specialist workplace assessment looks at the person’s role, their environment and their equipment together. For a person with hearing loss, that can include where they work, how they would be alerted in an emergency and what would help them in the way the building is used. It gives the employer concrete, individual recommendations to act on, which sit alongside the building’s fire risk assessment rather than replacing it.
This article is general information, not legal advice or fire safety advice. A competent fire risk assessment of the premises remains the responsibility of the person in charge, and what is adequate depends on the circumstances.
If you or someone in your team is deaf or has hearing loss and would like expert, tailored support to stay productive and comfortable at work, visit our hearing loss workplace assessment page to arrange a hearing loss workplace assessment.
Frequently asked questions
How will a deaf employee know the fire alarm has gone off?
Government guidance describes flashing beacons, paging systems and vibrating pagers as ways to alert deaf people, and a named buddy where appropriate. The right combination depends on the person, the building and when they work.
Does an employee with hearing loss need a personal emergency evacuation plan?
The Home Office guide recommends that all staff have the opportunity to have one at induction, and that disabled people are consulted about their plan. Whether it is needed in a given case depends on the person and the premises.
Are flashing alarms needed in toilets and small rooms?
RNID advises flashing alarms in all areas, including toilets, locker rooms and prayer rooms, so that staff with hearing loss are alerted wherever they are. The fire risk assessment should confirm what is adequate for the premises.
Can an employer rely on colleagues to tell a deaf employee about an alarm?
Not informally. The Home Office guide says a buddy system should not be left informal, in case everyone assumes someone else has given the warning. It should be a named person with a named cover.
Related resources
- Communicating with Deaf Employees and Employees with Hearing Loss: Everyday Tips for Managers and Colleagues
- Accessible Meetings for Deaf Employees and Colleagues with Hearing Loss
- Tinnitus at Work: What Managers Should Know, Say and Do
Sources
- Home Office, Fire safety risk assessment: means of escape for disabled people (first published 2 March 2021, updated 12 September 2023; applies to England)
- RNID, Supporting your staff who are deaf or have hearing loss: health and safety (last updated 26 May 2026)
- Regulatory Reform (Fire Safety) Order 2005, legislation.gov.uk
- Equality Act 2010, section 20 (duty to make reasonable adjustments)
Photo by Sartori Holdings LLC on Unsplash.