HSE inspections expose serious gaps in workplace hearing protection

Widespread failures in workplace hearing protection

The HSE’s campaign found that while many employers issue hearing protection equipment such as earplugs and earmuffs, few are managing them effectively in practice.

The problem is one of false compliance: PPE may exist on paper, but without training, maintenance, and supervision, it fails to protect workers.

Common issues identified included:

• PPE stored in dirty or damp conditions, degrading effectiveness.
• Shared earplugs being reused without hygiene controls.
• No regular replacement or inspection schedule.
• Workers removing hearing protection too early or wearing it incorrectly.

In essence, many businesses treat workplace hearing protection as a one-time purchase rather than a living safety system requiring continuous management and review.

Key findings from the HSE investigation

The HSE’s detailed findings show widespread deficiencies in compliance and understanding:

• 75% of employees lacked basic knowledge of how to store or check hearing protection.
• 63% had not been trained on the importance of consistent wear during exposure.
• 80% had never received training on correct fit or compatibility with other PPE.
• 95% of employers had never tested whether workers could still hear warning alarms while using hearing protection.

These failings suggest that thousands of employees may believe they are protected when they are not, resulting in long-term risk of noise-induced hearing loss.

HSE response and expert commentary

Chris Steel, the HSE’s Principal Specialist Inspector, warned that these gaps in implementation could have lifelong consequences:

“The gaps that we found in implementation are serious. They place an added risk to workers of excessive exposure to noise when they may believe they are being protected.”

“If your defence against workplace noise is to give your workers hearing protection then you need to check that it works.”

In its follow-up article, “Getting Personal Hearing Protection Right: What Really Matters,” HSE emphasised that hearing protection is the last line of defence — not a substitute for proper noise control. It requires training, supervision, inspection, and validation.

Real-world failures found included:

• Earmuffs with perished seals or broken bands.
• Earplugs reused beyond safe limits.
• Old custom-moulded plugs still in use despite poor fit.
• Over-protection blocking fire alarms and vehicle alerts.

The message is clear: effective workplace hearing protection depends on ongoing management, not assumption.

Assess and record noise exposure

Employers must carry out formal noise risk assessments to identify where and how workers may be exposed to harmful levels of noise.

• This involves measuring noise levels (in decibels, or dB(A)) using calibrated sound meters or specialist consultants.
• Assessments should consider the duration and intensity of exposure, the type of work performed, and how often employees are near noisy machinery or vehicles.
• Results must be documented and reviewed regularly, particularly when new equipment, processes, or layouts are introduced.

The goal is to establish whether noise levels exceed the lower (80 dB(A)) or upper (85 dB(A)) action values that trigger specific legal duties.

Eliminate or reduce noise at the source

The first step is always prevention, not protection. Employers are expected to control noise at its source wherever reasonably practicable.
This might include:

• Installing quieter machinery or replacing worn, noisy components.
• Using acoustic enclosures, sound barriers, or damping materials.
• Relocating noisy equipment away from workstations or rotating staff to limit exposure times.
• Scheduling noisy work at times when fewer people are present.

If noise can be engineered out of the process, hearing protection should only serve as a backup safeguard — not the first line of defence.

Provide suitable hearing protection

Where noise cannot be reduced to safe levels, employers must supply suitable workplace hearing protection.

This includes:

• Selecting the right type of PPE for the job (earplugs, earmuffs, or custom-moulded protectors).
• Ensuring the attenuation rating (SNR) is appropriate — neither under-protecting nor over-protecting workers.
• Providing options that are comfortable, hygienic, and compatible with other PPE such as helmets, visors, or glasses.

Employers should maintain a register of issued PPE, including who received it and when replacements are due.

Ensure PPE is used correctly and consistently

Issuing hearing protection is not enough — employers must ensure that it is used properly and at all required times.

This means:

• Supervisors must monitor compliance and take corrective action if PPE is not worn in designated areas.
• Signage should clearly identify mandatory hearing protection zones.
• Employees should be reminded that removing PPE for even a few minutes during high noise exposure can cause permanent hearing damage.

Active supervision and reinforcement are essential parts of a compliant hearing conservation programme.

Maintain and replace protection regularly

All hearing protection must be kept in good condition and replaced before it becomes ineffective.

• Earmuff seals can degrade, and earplugs can lose shape, elasticity, or cleanliness.
• Employers must schedule routine inspections to check for damage, cleanliness, and fit.
• Faulty or expired PPE should be replaced immediately.

Records of all inspections, maintenance, and replacements should be logged and stored to demonstrate due diligence in case of an HSE inspection or employee claim.

Inform and train employees

Every worker exposed to noise risks must receive clear information, instruction, and training.

This training should cover:

• The health effects of prolonged noise exposure.
• When and where hearing protection must be worn.
• How to fit, use, and maintain hearing protection properly.
• How to identify faults or wear, and how to report issues.

Training should be practical, interactive, and repeated regularly to ensure understanding and retention — particularly for new starters or young workers.

Offer health surveillance (Audiometry)

Where employees are exposed to noise above the upper exposure action value of 85 dB(A), employers must provide audiometric testing as part of ongoing health surveillance.

• This involves regular hearing tests conducted by qualified occupational health providers.
• Results help detect early signs of hearing loss, allowing intervention before permanent damage occurs.
• Consistent testing also provides valuable data to assess whether workplace hearing protection is performing effectively.

Audiometry programmes should include baseline testing for new employees and periodic follow-ups throughout employment.

Keep accurate documentation

All actions — assessments, training, inspections, and surveillance — must be accurately recorded.

This documentation not only supports legal compliance but also demonstrates an organisation’s commitment to employee wellbeing. In the event of an HSE investigation or compensation claim, well-kept records provide strong evidence of due diligence.

Steps employers should take now

Following the HSE’s findings, every employer should act immediately to strengthen their workplace hearing protection programme.

Conduct a CUFF audit:

• Inspect the condition, use, and fit of all PPE. Replace any worn or incompatible protection.

Reassess your noise exposure levels:

• Review existing noise assessments and retest if equipment or processes have changed.

Deliver refresher training:

• Run short, practical sessions for all employees on correct fitting, care, and reporting.

Verify warning audibility:

• Test whether alarms, vehicle signals, and PA systems remain audible with PPE in use.

Improve accessibility:

• Store hearing protection at point-of-use, not in distant storerooms.

Implement a replacement policy:

• Set a defined service life for reusable PPE (e.g., earmuffs every 6–12 months).

Introduce health surveillance:

• Offer audiometric testing to staff exposed to high noise levels and keep secure records of results.

Document everything:

• Keep evidence of audits, training, maintenance, and inspections to demonstrate compliance.