Author Bio ▼

Stephen Wheatley is a member of the WHO’s World Hearing Forum core team, sits on ITU/WHO working groups responsible for developing safety standards, is the Lead for WHO ‘Make Listening Safe’ Campaign UK, a Founder Director of UK Hearing Conservation Association and Founder and CEO of LimitEar/HearAngel Ltd which develops and produces technologies which reduce the risk of hearing damage for occupational and recreational headphone users.
February 1, 2023

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Listen up – Headphones and the Noise at Work regulations

Most health and safety risks change over time but there is one risk that is changing fast, some might say at the speed of sound, writes Stephen Wheatley, a Founder Director of the UK Hearing Conservation Association.

Since the introduction of the Noise at Work Regulations in 2005, responsible employers have taken action to identify processes and activities which could pose a noise risk for their employees.

As a result, most of the obvious sources of noise exposure in work settings have been addressed with mitigation strategies or by mandatory PPE. However, there are emerging noise risks that could be problematic for both employees and their employers. Furthermore, the emerging risks are not in the sectors traditionally seen as hazardous from a noise perspective but are increasingly widespread, where the majority sit in what are considered professional rather than industrial settings.


The emerging risks come from the use of headphones in the workplace. So why are headphones such a risk? Headphones on sale in Europe are restricted to a maximum output of 100dB when used with a mobile handset. The maximum safe listening period at 100dB according to the action levels in the regulations, dependent on what is being listened to, is likely to be between 15 and 30 minutes in any 24-hour period.

While it’s unlikely that an employee would wear headphones and listen at 100dB for their entire working day, they are in control of the volume, so how can an employer, who has no idea of their employee’s sound exposure level, expect to keep it below the upper action value of 85dBA over eight hours?

If an employee were to listen at an average of say 94dBA for their eight-hour working day, they could receive a sound dose which is equivalent to four times that permitted under the Noise at Work Regulations.

Two groups

There are two groups of headphone users at work: those who have to use headphones for work-related activities and those who are permitted to use headphones at work (in an open-plan office, for example). Under the regulations, it is the responsibility of the employer to manage the sound exposure levels of employees in both groups.

Unfortunately, the situation is made more problematic in terms of the employee’s hearing health and the employer’s liability by the significant increase in recreational sound exposure (RSE) over the last few years. Even if we ignore RSE from employees attending live music and sporting events, a 2022 report from Offcom, Media nations: UK 2022, estimates that adults in the UK are exposed to around 5 hours per day of screen time outside of work, and much of this, especially in the 16- to 34-year-old group, will be while using headphones.
The risk is that employees’ RSE, such as through headphones, could be significant in comparison to the noise exposure permitted at work, and thereby contribute to hearing loss. An employee who uses headphones for work, or at work with permission, who suffers hearing loss or other hearing health harm could make a claim against their employer and their insurer.

Risky business?

If the employer is unable to prove that they took the steps necessary to protect the employee’s hearing in line with the regulations they, and their insurers, may become liable for a hearing loss claim, some, or all of which is related to hearing damage caused by RSE. So, is it time that you identify those at risk from using headphones in your organisation and start to protect them?

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1 year ago

Your exposure time for noise (15-30mins @ 100dB(A) would appear to be based on exposure calcs for 85dB(A) which is not correct. The max safe exposure level is deemed to be 80dB(A) for 8 hrs. Using this calc then 100dB would be reached in less than 4mins! Furthermore, if the level is 97dB then the employer has a legal duty to reduce this by either avoiding the noise or rotating the workers/ less time @ noise source PPE is deemed a last resort and in some circumstances the wearing if PPE has resulted in fatalities as evidenced by Network Rail… Read more »

Nigel Evelyn-dupree
Nigel Evelyn-dupree
1 year ago

Well said Ronaldo’nt

Has everyone forgotten the retrospective 2011 Appeal Court findings in Bake v Quantum Clothing & Ors ?

Let alone HSE Better Display Screen RR 561 2007
or 2016 WHO ICD-10

Nigel Evelyn-dupree
Nigel Evelyn-dupree
1 year ago

What about occupational health and safety “Vision Conservation” for 58% of display screen operators suffering debilitating binocular vision loss simply due to failure to make custom “Reasonable Adjustments or Accommodations” to their screen settings!? We have had the 1998 PUWER Act, 2018 ISO 45001 “Work Exposure Limits”, 2018 WCAG 2.1 Colour Contrast Validation of websites and companion 2019 ISO 30071-1 DSE Colour Contrast Calibration to prevent and/or mitigate eye-strain, screen fatigue, Computer Vision Syndrome, myopic and asthenopic disease? Yet only up to 50% of employers engaging in developing Accessibility Strategies in compliance with regulatory guidance to meet requirements of… Read more »