Alongside measuring and controlling noise, the Regulations include a separate duty — health surveillance — aimed at catching hearing damage early, in people who are regularly exposed to noise at levels that put them at risk.
Who it applies to
Health surveillance is expected for employees who are regularly exposed above the upper exposure action value (85 dB(A) daily/weekly average), or who are otherwise identified as being at risk — for example from a history of hearing problems, or work involving impact/impulsive noise even where the averaged figure is lower.
What it involves
In practice this means periodic audiometric testing — a hearing test carried out under controlled conditions, ideally away from workplace noise, that measures hearing threshold across a range of frequencies. Results are compared against a baseline and tracked over time, so a gradual decline can be picked up before it becomes a permanent, noticeable loss.
Why it matters even where noise is well controlled
Health surveillance is not a substitute for controlling the noise itself — it is a check that the controls in place are actually working for real people. Noise-induced hearing loss is gradual and painless until it isn’t; by the time someone notices it themselves, it is usually permanent. Regular testing is the only way to catch it while anything can still be done.
Records
Health surveillance records should be kept for individual employees and made available to them on request, consistent with your wider duties to keep noise assessment and control records up to date and accessible.
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