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Hearing Protection for Employees Who Already Have Hearing Loss: Noise, Warnings and Communication

/ Employment, Hearing loss, Professionals, Support / By

By Daniel Morgan-Williams, Founding Director, Visualise Training and Consultancy Ltd.

Most guidance on hearing protection is written for people whose hearing is currently intact. The aim is to keep it that way. Far less is written for the employee who already has hearing loss, works in a noisy area, and is handed the same ear defenders as everyone else on the shift.

That employee faces a question that rarely gets asked. If protection brings the noise down to a safe level, what else does it take away? For a person who is already working hard to follow speech and catch warnings, the answer may matter as much as the noise itself.

This article is general information for employers, occupational health, HR and case managers. It is not legal advice, and it does not replace the employer’s own noise risk assessment.

What the noise regulations require

In Great Britain, the Control of Noise at Work Regulations 2005 set the framework. The Health and Safety Executive (HSE) summarises the values that trigger action. At a daily or weekly average of 80 dB(A), the lower action level, employers must assess the risk to workers’ health and provide information and training. At 85 dB(A), the upper action level, they must provide hearing protection and set up hearing protection zones. The exposure limit value is 87 dB(A), which takes into account any reduction from hearing protection, and workers must not be exposed above it. HSE also says hearing checks are required for workers regularly exposed above 85 dB(A).

Regulation 7 deals with protectors. At the lower action level, an employer must make them available on request. Where other measures cannot bring noise below the upper action level, the employer must provide them. When selecting protectors, the employer must aim to eliminate the risk to hearing or reduce it as far as is reasonably practicable, and must consult the employees concerned or their representatives.

Two parts of the risk assessment duty in regulation 5 are particularly relevant here. The assessment must consider the effects of noise on employees or groups of employees whose health is at particular risk. It must also consider indirect effects on health and safety from the interaction between noise and audible warning signals or other sounds that need to be heard.

Neither the regulations nor the HSE pages reviewed for this article address employees with existing hearing loss by name. Whether those provisions apply to a particular employee depends on the circumstances. They do give a clear basis for asking the question.

This article covers Great Britain. Northern Ireland and Ireland have their own noise regulations, which have not been reviewed here.

Why existing hearing loss changes the picture

Protectors reduce the level of sound reaching the ear. For a colleague with typical hearing, a reduced level may still leave speech and alarms comfortably audible. For an employee who already has hearing loss, there may be less margin. Speech that was only just understandable in the noise may become unintelligible, and a warning that was only just audible may disappear.

That is an inference from the principle rather than something the HSE guidance states, and it will not be true for everyone. Hearing loss varies in type, degree and pattern, and noisy environments vary even more. The point is that a protector chosen for the noise alone may not be the right protector for the person.

Many people with hearing loss also rely on things beyond sound: watching faces, reading the situation, spotting a colleague’s gesture across the floor. Protectors, helmets, visors and masks can interfere with all of these. Questions also arise about hearing aids, such as whether they can be worn with protection, and what the person can and cannot hear when they are taken out. The HSE pages reviewed do not address hearing aids. The answers depend on the individual, the equipment and the noise, and there is no general rule that could safely be given here.

The risk of over-protection

HSE guidance is explicit that more protection is not always better. It says protectors that bring the level at the ear below 70 dB should be avoided. Over-protection may cause difficulties with communication and with hearing warning signals, and users may become isolated from their surroundings, which creates safety risks. HSE also notes that over-protected workers may be tempted to remove their protectors, which then risks damage to their hearing.

For an employee with hearing loss, that last point deserves attention. If someone repeatedly pulls their defenders off in a noisy area, the reason may be that they cannot follow what is going on with them in place. That is a signal worth investigating before it is treated as a conduct issue.

HSE also says employers should offer a range of protectors so that employees can choose ones which suit them, and that training should cover why protectors are issued and how to fit them. Both points become more important when the employee has particular needs.

Warnings, signals and everyday communication

Noisy workplaces tend to run on sound. Reversing alarms, machine changes in pitch, a shouted instruction, a radio call. For an employee with hearing loss, wearing protection can make each of these harder to catch. The sensible response is to add information through other routes rather than to ask the person to listen harder.

Measures an employer might consider, depending on the site and the person, include visual alerts such as beacons or flashing lights alongside audible alarms, vibrating alerts that the person wears, agreed hand signals, a named colleague who works alongside, and layouts that keep the person within line of sight of the people they work with. Briefings can be held in a quieter area before the shift and backed up in writing or with visual task instructions, so that less has to be said in the noise itself. Where radios or other communication equipment are used, the features that matter are clarity, visual indication and compatibility with the protection being worn.

Reducing the noise at source, or reducing the time anyone spends in it, helps every worker and may reduce how much the employee with hearing loss needs to rely on protection at all. That remains the employer’s primary task under the regulations.

Employers also have a general duty under the Equality Act 2010 to make reasonable adjustments so that disabled workers are not substantially disadvantaged. GOV.UK gives an audio-visual fire alarm for a deaf employee as one example of the kind of change that may be needed. Whether a given arrangement is reasonable depends on the circumstances, and recommendations in an assessment are advice for the employer to weigh.

What a hearing loss workplace assessment can add

A noise risk assessment looks at the environment and the exposure. It rarely looks at what an individual can and cannot hear in that environment while wearing protection. A hearing loss workplace assessment looks at the second question. It considers the person’s actual tasks, how they communicate, which sounds they depend on, what they currently wear, and what would help them work effectively and safely.

The recommendations can then sit alongside the employer’s existing health and safety arrangements. They do not replace the noise assessment, health surveillance or the manufacturer’s guidance on equipment, and they do not draw conclusions about fitness for work. They give the employer, occupational health and the employee a shared, practical basis for decisions.

Visualise assessments typically take about two hours, with the written report following within ten working days. The employee is contacted within two working days of the referral, and the service covers the UK and Ireland.

What this means for occupational health, HR and case managers

Referrers are often the first to see the mismatch. A few questions are worth putting before a referral or a review meeting.

  • Did the noise risk assessment consider this employee’s hearing, and was the employee consulted about the protectors they were given?
  • Has anyone asked what the employee can still hear, and what they miss, while wearing protection in the real work area?
  • Are warnings and instructions available in a form that does not depend on hearing alone?
  • If protection is being removed, has someone asked why before any formal step is considered?
  • Is the employee’s own account of what works recorded and acted on, rather than assumed?

For income protection and rehabilitation cases, the same questions apply to a planned return. A person who is returning to a noisy site after a period away may need a different arrangement from the one they had before, and it is far easier to put that in place before the first shift than after the first near miss.

Summary

Hearing protection protects hearing. It also changes what a person can hear, and for an employee who already has hearing loss that change can affect communication and safety. HSE guidance warns against over-protection for exactly these reasons. The regulations require employers to consider workers whose health is at particular risk and the interaction between noise and the sounds people need to hear. Asking the individual, looking at the real task, and adding non-audio routes for warnings and instructions will usually do more than choosing a higher rating.

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 https://visualisetrainingandconsultancy.com/workplace-assessments/hearing-loss-workplace-assessment/ to arrange a hearing loss workplace assessment.

Frequently asked questions

Can someone with hearing loss wear hearing protection at work?

Often they can, but suitability is individual. The aim is protection from harmful noise without cutting the person off from speech and warnings. Choosing protectors, consulting the employee and checking what they can still hear in the real work area are all part of getting that right.

Does an employer have to provide hearing protection?

In Great Britain, the Control of Noise at Work Regulations 2005 require protectors to be made available on request at the lower action level (80 dB(A)). They must be provided where other measures cannot bring noise below the upper action level (85 dB(A)). This is a summary and not legal advice.

Can hearing aids be worn instead of, or with, hearing protection?

The HSE pages reviewed do not address hearing aids, so no general answer can be given here. It depends on the individual, the equipment and the noise, and it should be considered in the employee’s own assessment alongside the manufacturers’ instructions for any equipment involved.

What if an employee takes their hearing protection off because they cannot hear?

HSE notes that over-protection may lead people to remove their protectors. It is usually worth asking why, because the cause may be that the protectors are cutting off speech or warnings for that person. The answer may point to a different protector, a different way of communicating or a change to how the task is organised.

Does a workplace assessment replace the noise risk assessment?

No. The employer’s noise risk assessment, health surveillance and equipment guidance remain in place. A hearing loss workplace assessment adds an individual view of what the employee can hear and understand at work, and recommends practical support for the employer to consider.

Sources

Photo by ThisisEngineering on Unsplash.