Please see below the UK Hearing Conservation Association response to the HSE Consultation on a review of RIDDOR.
About the UKHCA
The UK Hearing Conservation Association (UKHCA) is a not for profit Association who actively campaign to improve hearing health awareness through education, advocacy and leaning on expertise across our multi-disciplinary membership to develop information and guidance based on real-life challenges.
The UKHCA commitment to hearing health and conservation not only addresses the personal and occupational impact of hearing loss but also emphasizes the social and economic costs of these preventable injuries.
UKHCA Response
The UK Hearing Conservation Association welcome broadening the scope of occupational diseases to be reported, particularly for Noise Induced Hearing Loss (NIHL). The historic lack of inclusion of noise related health effects, have been questioned by many as to HSE’s acknowledgment and priority of work-related noise harm. This is despite years of causal knowledge of harm, clear dose response evidence, and significant exposure across GB industries.
However, we recognise there will be challenges and highlight the need for specific criteria for reporting NIHL (and similar probabilistic conditions). The criteria should explicitly incorporate both the probability of occupational causation (e.g., possible/probable/highly likely), and severity of condition (mild/moderate/severe) with clear definitions of what constitutes each statement. We recognise this will be particularly important for health conditions such as NIHL that has both work and non work causes
The UK Hearing Conservation Association also raises concerns that a poorly developed RIDDOR reporting system for NIHL could blur the distinction between detection, diagnosis and attribution. This may lead to the same underlying disease being reported repeatedly as workers move between employers or undergo further surveillance. Without these distinctions, employers investing most in effective health surveillance could be most exposed to perceived culpability and regulatory or legal challenge.
The UKHCA are involved in a rather timely piece of work with the SOM – developing standardised diagnostic criteria and descriptors for NIHL, incorporating both probability and severity. The output of this work is likely to help address these areas of ambiguity. The UKHCA would be happy to support HSE in defining the specific diagnostic criteria and underpinning exposure profile for reporting requirements.
We would also note that the true figure of NIHL cases is likely to be much greater than the consultation paper estimates (more like 15, 000+ per annum). This will have a considerable impact on workload for OH practitioners.
We hope the HSE find these comments useful and remain committed to supporting HSE in protecting workers health and improving standards and evidence based practice.
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