Is health surveillance required for employees who are regularly exposed to noise in excess of 85dB, even though they wear suitable hearing protection at all times?

For example - in a joinery workshop that contains various woodworking equipment (the majority of which produce 85-105dB), the joiners all wear hearing protection every time the equipment is in use. The SNR and attenuation is suitable. 

Would the employer be required to provide health surveillance for these employees?

Thanks

Originally Posted by: RVThompson

https://www.hse.gov.uk/pubns/priced/l108.pdf

The link above will give you the guidance for this query.

Yes, thanks, I have already read this - hence the question.

"You should provide health surveillance to workers frequently exposed above the upper exposure action values. Where exposure is between the lower and upper exposure action values, or where employees are only occasionally exposed above the upper exposure action values, health surveillance will only be required if information comes to light that an individual may be particularly sensitive to NIHL."

So, does this apply to employees frequently exposed to above the upper exposure action value but who wear suitable hearing protection?

Thanks

Edited by user 10 December 2019 16:23:56(UTC)  | Reason: Fat fingers

If you supply hearing protection and do not monitor the employees hearing how do you know it is effective?

In short yes you need to monitor.

The only time you would not monitor is employees well below the action limits e.g. office workers

This basic approach applies to all personal protective equipment. Consider the following from the ACoP for COSHH:

Examples where health surveillance is appropriate under the criteria in regulation 11(2)(b) are:

where there have been previous cases of work-related ill health in the workforce/place;

where there is reliance on PPE, eg gloves or respirators, as an exposure control measure; eg printers wearing gloves to protect against solvents used during press cleaning, or paint sprayers using two-pack paints wearing respirators to prevent asthma. Even with the closest supervision there is no guarantee that PPE will be effective at all times;

where there is evidence of ill health in jobs within the industry; eg frequent or prolonged contact with water (termed ‘wet-working’) causing dermatitis in hairdressers and healthcare workers, or breathing in mists from chrome plating baths causing chrome ulcers in platers.

Paragraph 238 amplifies this:

This is not a definitive or exhaustive list and there will be many other instances where health surveillance is required. Employers will need to seek information or advice on the specific health risks identified in the risk assessment, or through any topic-specific HSE guidance, trade associations or other professional sources.