Workplace Audiometry: When UK Employers Need Hearing Tests and How to Manage Them

If your noise risk assessment shows workers are regularly exposed at or above 85 dB(A), you need health surveillance — and in practice, that means audiometric testing. Most employers understand this requirement exists. The harder part is running the programme over years: knowing who needs testing, when they are due, what to do when results show a change, and how to keep records that actually prove compliance.

This guide covers when audiometry is legally required, how to set it up, and — the part most guidance skips — how to manage it as an ongoing operational process rather than a one-off exercise.

This guide covers employer duties for audiometric health surveillance under UK regulations. It is not medical advice. Interpretation of individual audiometry results should involve a qualified occupational health professional.

When audiometry is legally required

Regulation 9 of the Control of Noise at Work Regulations 2005 requires health surveillance for workers who:

• Are regularly exposed at or above the upper exposure action values — 85 dB(A) daily/weekly average or 137 dB(C) peak
• Are at risk for any other reason — for example, workers already known to have noise-induced hearing loss, or workers particularly sensitive to noise damage

HSE's health surveillance guidance defines this as regular hearing checks in controlled conditions, combined with record-keeping, comparison against baseline results, and medical review when deterioration is detected.

The assessment determines who needs surveillance. For how the assessment works, see How to Complete a Noise Risk Assessment. For the exposure thresholds that trigger surveillance duties, see UK Workplace Noise Exposure Limits. To estimate exposure levels for your own workers, try the free Noise Exposure Calculator.

What audiometric testing involves

Health surveillance for noise-exposed workers typically follows this pattern:

Baseline test

A hearing test when the worker first enters a noise-exposed role (or when the surveillance programme starts for existing workers). This establishes their starting hearing level — the reference point for all future comparisons.

The baseline should be done before significant noise exposure begins, or as close to the start of employment as practicable. L108 guidance recommends the test is done after a period away from noise (at least overnight) so that temporary shifts from recent exposure do not affect the result.

Follow-up tests

Regular tests at intervals to detect any hearing changes:

• Years 1-2: Annually. Early follow-up catches rapid deterioration that might indicate controls are inadequate.
• Year 3 onward: At intervals determined by the occupational health professional overseeing the programme — typically every 3 years if results are stable, but more frequently if any deterioration is detected.

Referral and action

If a follow-up test shows hearing deterioration compared to baseline:

1. The occupational health professional reviews the results and determines whether the change is clinically significant
2. If significant, the employer must: review the noise risk assessment, review control measures, consider whether the worker can continue in their current role, and consider redeployment if necessary
3. The worker should be informed of the results and what they mean
4. The assessment and control measures must be updated to reflect the finding

Setting up the programme

Choosing a provider

Audiometric testing must be carried out by someone with appropriate training, and the overall programme must be supervised by a qualified occupational health professional (typically an occupational health doctor or nurse with relevant training and experience).

Options:

• External OH provider — mobile audiometry services come to your site with calibrated equipment. Suitable for most small employers.
• In-house — larger employers may have in-house occupational health teams. Requires calibrated equipment and trained staff.
• Fixed clinic — workers attend an off-site clinic. Less disruptive to production but requires travel time.

When evaluating providers, check:

• What equipment they use (calibration certificates should be current)
• Whether they provide fitness-for-work recommendations, not just raw results
• What records they supply and in what format
• How they handle referrals when deterioration is detected

Deciding who needs testing

Start from your noise risk assessment. Every worker group identified as exposed at or above the upper action values needs to be in the programme. In the worked assessment example, that would be machine operators, bench joiners, and apprentices — but not assembly workers (below upper action values) or the administrator.

Also include:

• Workers with known pre-existing hearing conditions, regardless of current exposure level
• Workers who have transferred from a previous noise-exposed role
• Workers who report hearing difficulties or tinnitus

Scheduling

The main operational challenge is scheduling — knowing who is due, booking tests, and ensuring workers attend.

For a small employer with 10-20 workers in the programme:

• Annual batch — schedule all tests in the same week, typically when the mobile audiometry provider visits. This is the simplest approach but requires all workers to be available.
• Rolling schedule — tests spread across the year based on each worker's start date. More complex to track but avoids disrupting production for a full week.

Whichever approach you use, you need a system that tells you who is due and flags overdue tests. A calendar reminder works until someone forgets to check it.

Managing records

Regulation 9 requires employers to keep health surveillance records. These are the employer's records of who was tested, when, the fitness-for-work outcome, and any recommended actions. Confidential clinical records (the actual audiogram data) are kept by the occupational health professional.

For each worker, the employer's record should include:

Field	What to record
Worker name and role	Identifies the individual
Noise exposure group	Links to the risk assessment
Baseline test date	When the reference test was done
Most recent test date	When they were last tested
Next test due	When the follow-up is scheduled
Outcome	Fit / fit with conditions / requires review
Referral actions	If deterioration detected, what was done
Linked assessment	Which risk assessment covers this worker

These records must be kept for as long as the worker is employed in a noise-exposed role, and for at least 40 years from the date of the last entry — a requirement set by Regulation 9(4) of the Control of Noise at Work Regulations 2005 and reiterated in HSE's health surveillance guidance.

When results show deterioration

Detecting hearing loss early is the point of surveillance — but the value only materialises if you act on the results:

1. Review the assessment — is the worker's exposure correctly estimated? Have conditions changed since the last assessment?
2. Review controls — are the current measures sufficient? Is hearing protection being worn correctly? Is it the right type and attenuation?
3. Consider the worker — can they continue safely in their current role? Do they need additional protection, modified duties, or redeployment?
4. Update records — log the finding, the review outcome, and the actions taken
5. Check other workers — if one worker's hearing has deteriorated, check whether others in the same exposure group are showing similar changes. A pattern may indicate that controls are inadequate for the group, not just the individual.

Common mistakes

• Starting the programme but not maintaining it — the first round of tests gets done, but follow-ups slip because nobody tracks who is due
• Collecting results without acting on them — audiometry reports filed without reviewing what they mean for the assessment and controls
• Not linking audiometry to the risk assessment — the two processes should be connected. Audiometry findings inform the assessment; the assessment determines who needs audiometry
• No record of fitness-for-work decisions — the employer's record should include the outcome and any actions, not just the test date
• Testing workers who do not need it — surveillance is for workers at or above the upper action values. Including everyone wastes resources and can create unnecessary anxiety

Connecting audiometry to the wider compliance workflow

Audiometric testing does not exist in isolation. It connects to:

• The noise risk assessment — which identifies who needs testing. See How to Complete a Noise Risk Assessment and Noise Risk Assessment Example.
• Control measures — audiometry results that show deterioration trigger a review of controls. See Noise Risk Assessment Control Measures.
• PPE records — hearing protection issue and suitability records
• Training records — workers must be informed about noise risks and health surveillance
• The assessment review cycle — audiometry findings are a trigger for reassessing exposure

For the full regulatory context behind these requirements, see UK Noise at Work Regulations: The Complete Employer Guide.

Sources

• The Control of Noise at Work Regulations 2005 — legislation.gov.uk
• Health surveillance for hearing — HSE
• L108: Controlling Noise at Work (3rd edition, 2021) — HSE
• Noise at work: regulations — HSE