How to Arrange Hearing Tests for Employees
- Mark Ashmore
- May 20
- 12 min read
Updated: May 21
A UK Employer's Step-by-Step Guide
By Mark Ashmore, HCPC-registered audiologist (RHAD, MIOA)
Founder, Hear 4 The Long Term • Approx. 2,600 words • 11-minute read
Most employers do not arrange hearing tests because someone tells them to. They arranged them because something happened. A new starter mentioned the noise on the line.
A near-miss with a reversing forklift. An HSE inspector with a clipboard is asking whether anyone has been tested in the last twelve months. A solicitor's letter referencing a former employee who claims their hearing was damaged on your watch.
Whichever it was, the question that lands on your desk is the same. How do I arrange this, and how do I make sure what we end up with stands up if anyone asks to see the paperwork?
This is the guide I wish more employers had when they reach that moment.
Seven steps, what the law actually requires, what it costs in 2026, and what the documentation needs to look like at the end. No jargon where plain English will do.
Why does this matter more in 2026 than it did in 2024?
The Health and Safety Executive has put workplace noise back on its enforcement agenda. A multi-year inspection campaign launched in 2024 continued through 2025, with HSE reporting a 300% increase in noise-related enforcement actions in the first three months of targeted inspections (British Safety Council, 2025).
A separate HSE press release in September 2025 found that three-quarters of noisy workplaces lacked essential knowledge on maintaining hearing protection equipment, one in four workplaces had noise levels requiring mandatory hearing protection under the regulations, and 95% of employers had not verified whether their workers could still hear warning signals such as fire alarms while wearing protection (HSE Press Release, 10 September 2025).
The figures are uncomfortable reading for any employer who has been quietly hoping the regulations apply to someone else.
The pattern across both reports is the same. Employers are not deliberately ignoring the law. They have simply not been shown a clear, ordered way to do it properly.
So that is what the next seven steps lay out.
Step 1: Establish whether you have a legal duty to test
The legal trigger for arranging hearing tests is set out in Regulation 9 of the Control of Noise at Work Regulations 2005 (covered in library entry 1.7).
The wording itself is short and worth reading once:
"If the risk assessment indicates that there is a risk to the health of his employees who are, or are liable to be, exposed to noise, the employer shall ensure that such employees are placed under suitable health surveillance, which shall include testing of their hearing."
The trigger is "risk to the health" of employees exposed to noise, demonstrated through a proper risk assessment under Regulation 5. The exposure action values themselves are set out in Regulation 4 (Exposure limit values and action values).
Three exposure thresholds matter under the regulations (see library entry 1.2 for the full breakdown):
Threshold | Daily/Weekly | Peak | Trigger |
Lower Exposure Action Value (LEAV) | 80 dB(A) | 135 dB(C) | Protection on request, training, and risk assessment |
Upper Exposure Action Value (UEAV) | 85 dB(A) | 137 dB(C) | Mandatory protection AND health surveillance |
Exposure Limit Value (ELV) | 87 dB(A) | 140 dB(C) | Must never be exceeded after protection |
If you do not yet have a noise risk assessment, that is Step Zero. You cannot judge whether testing is required without one. The practical guidance on running an assessment is in library entry 1.4 (Risk Assessment and L108 Paragraph 34), and the statutory wording is in library entry 1.3 (Regulation 5).
Step 2: Decide what type of test you actually need
There are three distinct types of workplace hearing tests, and the difference matters because they apply at different points and produce different records.
Test type | When | Purpose |
Baseline (induction) test | Within the first weeks of a new starter joining a noisy role | Establishes their hearing before workplace exposure starts. Legal defence if a claim is brought years later. |
Periodic surveillance | Second test at 12 months after baseline, then normally at three-year intervals (annual for higher-risk workers) | Detects early signs of noise-induced hearing loss. Triggers HSE categorisation and any required action. |
Triggered test | After an incident, complaint, or notable exposure change | Investigates a specific concern or follows an HSE notice. |
The frequency point is worth dwelling on, because most employers assume it means "annual testing forever." It does not. L108 (3rd edition) actually sets out a more nuanced schedule.
A baseline as soon as practicable after starting noise-exposed work, a second test approximately twelve months after the baseline, and then normally not more than three years apart for routine workers.
Annual testing is reserved for higher-risk employees: those with very high exposure, young workers, or anyone showing deterioration on previous audiograms. This is set out in the L108 guidance on Audiometry and Setting up an audiometry programme (library entry 2.1.2).
In practice, most employers in noisy sectors run baseline tests during induction and as part of a rolling annual programme for the workforce. The reason is simple.
It is administratively easier to keep one schedule than two, and the worker confidence benefits of annual reassurance often outweigh the cost savings of stretching to three-year intervals. The point is, if your risk profile allows it, you have options.
Details on each test type and its legal basis are in library entry 1.7 (Health Surveillance, Regulation 9) and library entry 2.1.2 (L108 Audiometry Requirements).
Step 3: Choose a provider, and understand what you are paying for
This is where most employers feel out of their depth because the pricing models in this market are inconsistent. There are two main delivery models in the UK, and the cost difference between them can be significant.
The mobile audiology van model
Traditional providers send a fully equipped van with an audiometric booth, an operator, and a day's worth of capacity. Day rates are typically £1,000 to £1,500 for an on-site visit, plus add-on costs for set-up, calibration, and travel. Equipment hire if you buy in-house runs to £3,000 to £15,000 or more, with ongoing calibration and operator training (industry commentary from H4TLT (Hearing 4 The Long Term) pricing comparison, 2026).
This model works well for sites that can dedicate a full day, group their workforce, and accept the logistical complexity. It works less well for shift patterns, multi-site businesses, or smaller teams.
The self-service, per-test model
A more recent model uses pre-calibrated headsets sent to the employer, with the test run by a nominated person on-site during induction or annual surveillance.
Pricing is per test rather than per day. UK occupational audiology pricing in 2025-2026 typically falls between £10 and £120 per worker, with HSE-compliant screening in volume commonly landing in the £20 to £60 per person band (Hearing Healthcare Centre lists £50
screening to £120 full assessment; Regain Hearing quotes £69 for a private clinic assessment).
Whichever model you choose, the questions to ask any provider are the same:
● Can the provider prove the test complies with BS EN 60645-1:2017 and BS EN ISO 8253-1:2010?
● Do test results come with HSE categorisation 1 to 4, ready for the health record?
● How are results stored, and how does the employer access them for HSE inspection or claim defence?
● What happens when a worker shows a Category 3 or 4 result?
Step 4: Prepare your workforce
A surprising proportion of workplace hearing test failures are not technical; they are communication failures. Workers turn up without warning or context and assume something is wrong with them when results show a shift.
Three things to handle before the test day:
● Tell workers what the test is, why it is happening, and that it is not a disciplinary process. The legal driver is your duty to them under Regulation 9, not a question mark over their performance.
● Give them at least 14 hours of quiet time before the test, where possible. This figure is specified in the SOM Supplementary Guidance on Interpreting an Audiogram (September 2024, page 9) and in BS EN ISO 8253-1:2010 clause 5.1.3 for baseline audiometry. Older guidance cited 16 hours, which is the OSHA US figure, not the current UK practice.
● Confirm the worker is ready to take the test. Under Regulation 9(5), workers have a statutory duty to present themselves for surveillance during working hours, covered in library entry 1.7.3.
Your duty to provide information, instruction, and training is set out in Regulation 10 (library entry 1.8), which covers the practical scope of what workers should know about the noise risks they are exposed to and the controls in place.
Step 5: Run the test properly
A compliant workplace audiometric test is not the same as a hearing check at the local high street optician. It must meet specific international standards for the results to count as HSE-compliant health surveillance.
At a minimum, a compliant test covers:
● Pure-tone air-conduction audiometry at 0.5, 1, 2, 3, 4, 6, and 8 kHz, in both ears.
● A quiet test environment meeting the ambient sound requirements of ISO 8253-1.
● Equipment calibrated and certified to BS EN 60645-1:2017 (audiometer standard, library reference) within the previous twelve months.
● The test process must follow BS EN ISO 8253-1:2010 methodology (audiometric test methods, library reference).
● Worker preparation, including the 14-hour quiet period from Step 4.
The underlying clinical and equipment standards, and the detailed L108 surveillance and audiometry programme requirements, are in library entry 2.1.2 (L108 Health Surveillance and Audiometry Requirements).
Step 6: Receive and interpret the results
Results from a compliance test are categorised under HSE's four-category scheme, which compares each worker's hearing thresholds at 1, 2, 3, 4, and 6 kHz against age- and sex-standardised reference data.
Category | Meaning | Employer action |
Category 1 | Acceptable hearing | Continue routine periodic surveillance |
Category 2 | Mild hearing impairment | Warn worker, review noise controls, continue surveillance |
Category 3 | Poor hearing | Refer to qualified medical advice, review controls |
Category 4 | Rapid hearing loss | Immediate referral to occupational health or audiologist, urgent review of exposure and controls |
The full categorisation logic and what each category triggers, operationally, are in library entry 5.4 (HSE Hearing Surveillance Categorisation). A Category 4 result requires immediate action and is one of the situations that can become reportable under RIDDOR if linked to occupational exposure.
A note on audiometric variation
One point worth making to any employer commissioning surveillance because it affects how results should be read.
Audiometry is a psychophysical test. Test-retest variation of ±5 dB at a single frequency under controlled conditions and up to ±10 dB in routine occupational practice has been documented in the primary literature (Hogan and Turner 2017; Dobie and Rabinowitz 2002; Carhart and Jerger 1959).
The SOM Supplementary Guidance on Interpreting an Audiogram (September 2024) codifies this in surveillance interpretation: small shifts may fall within normal test-retest variation, whereas consistent patterns across baseline and subsequent audiograms reveal genuine change.
Interpretation is the audiology provider's job, but the principle is worth knowing as an employer: a single result is a snapshot, not an absolute. The detailed technical background sits in library entry 5.1 (Why Audiometry Has Inherent Variation).
Step 7: Act on the results, and document everything
Regulation 9(4) sets out what must happen if surveillance identifies hearing damage likely to have been caused by noise.
The worker must be examined by a doctor, controls reviewed, alternative work considered if appropriate, and ongoing surveillance maintained. The details on these duties and how to discharge them are covered in library entry 1.7.2 (Action on Identified Hearing Damage). None of this is optional, and none of it is documented in your head. It needs to be on paper.
Health records under Regulation 9(2) must include the items detailed in library entry 1.7.1 (Health Records):
● Name, date of birth, and permanent identifier for each employee.
● A summary of their exposure history.
● Dates of all hearing tests conducted.
● Results, categorised against the HSE four-category scheme.
● Any actions taken in response to those results.
In the event of a civil claim for noise-induced hearing loss, your record-keeping is what stands between you and a settlement. Library entry 7.6 (Documentation Requirements for Defensibility) goes deeper into what HSE and the courts actually look for.
Library entry 8.1 (Legal Precedent: Hearing Loss Claims and HSE Enforcement) covers recent HSE enforcement patterns and the kinds of cases that have already cost employers six-figure sums.
The cost of not doing it
The September 2025 HSE inspection findings showed how widespread the gap really is. 95% of employers in noisy workplaces had not verified whether workers wearing hearing protection could still detect warning signals. 80% of workers had received no instruction on correct fitting.
63% had received no guidance on continuous wearing.
The full enforcement landscape and recent precedent are set out in library entry 8.1 (Legal Precedent and HSE Enforcement), with the source HSE press release available at press.hse.gov.uk.
The cost of an improvement notice is administrative. The cost of a prosecution runs into five and six figures.
The cost of a successful civil claim for noise-induced hearing loss runs into tens of thousands per claimant, often more if multiple workers are affected. The cost of arranging the testing properly, by contrast, runs to £10 to £25 per worker per year for screening at scale.
What to do this week
If you have not yet arranged workplace hearing surveillance and you employ anyone exposed to noise above 80 dB(A) for any part of their working day, three things this week:
● Check whether you have a current noise risk assessment under Regulation 5. If not, that is the first call.
● Identify how many workers fall into the surveillance group (likely frequent exposure at or above 85 dB(A) daily or weekly average).
● Run the H4TLT (Hearing 4 The Long Term) compliance checker to see your obligations clearly and get a quote for testing under the self-service model.
The H4TLT (Hearing 4 The Long Term) compliance checker walks you through the same questions an HSE inspector would ask, and produces a quote you can hold against any other provider.
How H4TLT delivers this
Hear 4 The Long Term provides workplace hearing surveillance through a self-service model that removes the audiology van from the equation. Pre-calibrated headsets are sent to the employer; the test is run by a nominated on-site person; results are automatically categorised against the HSE scheme; and records are produced, ready for inspection or claim defence.
Equipment is loaned at no additional cost. There are no day rates, no travel charges, no calibration fees. You pay for the tests, not the logistics.
What Now?
Now that you have the information, the next logical step is to assess your current compliance status.
There are methods that can be costly, which is why we have introduced a free version that will tell you where the cracks are in real time.
Click the button below to run a fast, confidential compliance check.
About the author
Mark Ashmore is the founder of Hear 4 The Long Term and an HCPC-registered audiologist (RHAD, MIOA) with over thirty years in audiology.
He sits on British Standards committees PH/7 (Hearing Protection) and EH/1 (Acoustics), and co-authored Variation in Tone Presentation by Pure Tone Audiometers (Barlow, Davison, Ashmore; Euronoise 2015).
Hear 4 The Long Term provides software-driven workplace hearing surveillance to UK employers, replacing traditional audiology van models with a self-service per-test approach that meets British Standards.
Frequently Asked Questions
Do I have to arrange hearing tests if my workers wear ear defenders?
Yes. Hearing protection reduces exposure but does not eliminate the legal duty. Regulation 9 surveillance is required where workers are likely to be frequently exposed to levels above the upper exposure action value, regardless of the protection in use.
How often do I need to test workers?
The L108 schedule is: baseline as soon as practicable, a second audiogram about 12 months after the baseline, then, normally, not more than 3 years apart for routine workers. Annual testing is appropriate for higher-risk groups: those with very high exposure, young workers, or those showing deterioration on previous audiograms.
Most employers in noisy sectors choose to run annual surveillance for the whole exposed workforce because it is administratively simpler than a mixed schedule, but the technically correct minimum is the L108 schedule above.
Can workers refuse a hearing test?
Regulation 9(5) (library entry 1.7.3) requires employees to present themselves for health surveillance during working hours. Refusal triggers a documented conversation, a review of why, and in some cases, a disciplinary process. Workers have a statutory duty to attend under Regulation 9(5).
What happens if a worker fails the test?
There is no single "fail." Results are categorised into HSE Categories 1 to 4. Categories 3 and 4 require employer action, including medical referral, review of controls, and in some cases, workplace adjustments. Library entry 5.4 covers each category in detail.
It is also worth understanding that audiometry has inherent variation, covered in library entry 5.1 — a single Category 2 result is not yet a pattern, but a trend across baseline and subsequent tests is.
How much does workplace hearing testing cost in 2026?
UK pricing in 2025-2026 typically runs from £10 to £120 per worker, depending on model and volume. Self-service screening models routinely come in at the lower end. Mobile audiology van day rates remain £1,000 to £1,500 plus add-ons.
How long before the test should workers avoid loud noise?
Current L108 (3rd edition) and SOM/HSE Supplementary Guidance on Interpreting an Audiogram (2024) recommend 14 hours of quiet before audiometric testing. Older guidance and many third-party occupational audiology sources cite 16 hours, which was the figure from the first edition of L108 and is now superseded.
Sources and further reading
Primary external authorities cited in this article:
● HSE Press Release: Serious gaps found in protecting workers from excessive noise (10 September 2025)
● British Safety Council: HSE Inspections Target Hearing Protection and Noise Control Failures (2025)
Internal H4TLT library references:
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