Health Surveillance

Conducting health surveillance to establish the effects of noise exposure can only really mean audiometric testing (hearing tests) and the reason this was not included in the 1989 regulations is that, in theory, these tests are freely available on the NHS. In practice, of course, this is not the case and certainly does not provide a satisfactory system for use in industry.

The new regulations will certainly have mandatory health surveillance as a requirement at the Upper Action Value (UAV) although at the Lower Action Value (LAV) the requirement may only be to conduct audiometry for susceptible individuals. Selecting these people without missing anyone in practice could be quite tricky.

There is still some uncertainty as to who can carry out the hearing tests. The Directive states that employees exposed to the UAV or above have the right to a hearing check conducted by or under the responsibility of a doctor. The draft regulations however say that it will be acceptable for the test to be conducted and interpreted by a suitably qualified person although referral to a doctor should be made if necessary. The reason for this is down to the availability of occupational health professionals in industry. It is yet to be seen whether the EU will accept this interpretation of the Directive.