Health surveillance for hearing damage usually means:
• regular hearing checks in controlled conditions;
• telling employees about the results of their hearing checks;
• keeping health records;
• ensuring employees are examined by a doctor where hearing damage is identified.
Ideally, you would start the health surveillance before people are exposed to noise (ie for new starters or those changing jobs), to give a baseline. It can, however, be introduced at any time for employees already exposed to noise. This would be followed by a regular series of checks, usually annually for the first two years of employment and then at three-yearly intervals (although this may need to be more frequent if any problem with hearing is detected or where the risk of hearing damage is high). The hearing checks need to be carried out by someone who has the appropriate training. The whole health surveillance programme needs to be under the control of an occupational health professional (for example a doctor or a nurse with appropriate training and experience). You, as the employer, have the responsibility for making sure the health surveillance is carried out properly.
You must provide health surveillance (hearing checks) for all your employees who are likely to be regularly exposed above the upper exposure action values, or are at risk for any reason, eg they already suffer from hearing loss or are particularly sensitive to damage.
The purpose of health surveillance is to:
• warn you when employees might be suffering from early signs of hearing damage;
• give you an opportunity to do something to prevent the damage getting worse;
• check that control measures are working. Consult your trade union safety representative, or employee representative and the employees concerned before introducing health surveillance. It is important that your employees understand that the aim of health surveillance is to protect their hearing.
You will need their understanding and co-operation if health surveillance is to be effective.
Larger companies may have access to in-house occupational health services who may be able to carry out the programme. Where there are no facilities in-house you will need to use an external contractor. You may be able to find out about occupational health services through your trade association, or through local business support organisations.
A suitable occupational health service provider will be able to show you that they have the training and experience needed. They should be able to: advise you on a suitable programme for your employees;
• set up the programme;
• provide suitably qualified and experienced staff to carry out the work;
• provide you with reports on your employees' fitness to continue work with noise exposure.
By law, as an employer, you must assess and identify measures to eliminate or reduce risks from exposure to noise so that you can protect the hearing of your employees.
Where the risks are low, the actions you take may be simple and inexpensive, but where the risks are high, you should manage them using a prioritised noise-control action plan.
Where required, ensure that:
• hearing protection is provided and used;
• any other controls are properly used; and
• you provide information, training and health surveillance.
Review what you are doing if anything changes that may affect the noise exposures where you work.
Use the results to make sure your employees' hearing is being protected. You will need to:
• keep records of the health surveillance and fitness-for-work advice provided for each employee (but not the confidential medical records which are kept by the doctor). A health and safety inspector can ask to see the health records as part of their checks that you are complying with the Regulations;
• make employees' records available to them;
• act upon any recommendations made by the occupational health service provider about employees' continued exposure to noise;
• use the results to review and, if necessary, revise your risk assessment and your plans to control risks.
Analysing the results of your health surveillance for groups of workers can give you an insight into how well your programme to control noise risks is working. Use the results to target your noise reduction, education and compliance practices more accurately. Make this information available to employee or safety representatives.