Are organisations managing workplace noise as effectively as they believe?

In our last article, we looked at why workplace noise stays on the regulatory radar. We also covered why noise-induced hearing loss still affects Australian workers.

In many cases, the issue is not negligence. It is process drift.

Over time, workplaces evolve. Equipment changes. Production increases. Layouts shift. Systems that were once compliant can gradually fall out of alignment with current conditions.

Guidance from Safe Work Australia, including the Model Code of Practice, sets clear expectations.  

It covers identifying hazards, assessing risks, and reviewing control measures to prevent hearing loss at work. State regulators across Australia increasingly focus on whether those processes are active and current.

Based on national guidance and regulator commentary, several recurring gaps appear.

1. Audiometric testing completed, but not reviewed

Many organisations conduct audiometric testing as required under WHS regulations. Testing occurs. Reports are issued. Files are stored.

The problem arises when results are not reviewed for trends.

Safe Work Australia guidance makes clear that managing noise requires ongoing risk management, not one off compliance activity. Hearing threshold shifts are an early warning signal. When small changes occur across multiple workers, it may indicate exposure levels or control measures need review.

Testing without analysis limits its protective value.

2. Hearing shifts identified, but no follow up noise assessment

When audiometric testing identifies a significant shift, it should trigger further investigation.

Under national WHS duties, PCBUs must identify hazards and eliminate or minimise risks so far as reasonably practicable. If hearing changes are detected, this may require a formal workplace noise assessment to:

• Confirm current noise exposure levels
• Re-examine dominant noise sources
• Review engineering and administrative controls
• Assess suitability of hearing protection

Safe Work Australia’s Code of Practice emphasises that risk management is cyclical. Where new information arises, control measures must be reviewed.

Failing to close that loop is one of the most common weaknesses in workplace noise systems.

3. Noise Management Plans that no longer reflect operational reality

Many organisations have a documented Noise Management Plan. The issue is not absence of documentation. It is currency.

Common examples of drift include:

• New plant or equipment not captured in the original assessment
• Increased exposure duration due to production changes
• Layout adjustments affecting reverberation or proximity to noise sources
• Expanded workforce without updated exposure analysis

The Model Code of Practice stresses that control measures must be reviewed when there is a change in the workplace. If you do not periodically reassess plans, compliance gaps can develop gradually.

4. Hearing protection issued, but effectiveness not verified

Providing personal protective equipment is only one element of the hierarchy of control.

Regulators and national guidance emphasise that PPE must be:

• Appropriate for the measured noise level
• Correctly selected based on attenuation requirements
• Properly fitted
• Supported by training and supervision

Issuing hearing protection without confirming that it sufficiently reduces exposure can create a false sense of security. Safe Work Australia guidance reinforces prioritising elimination and engineering controls wherever practicable.

5. Informal awareness, but no formal measurement

In many workplaces, supervisors and workers know which tasks are loud. It may be common knowledge that certain processes generate high noise.

However, assumptions are not the same as measured exposure.

Without formal noise measurement and assessment against the 85 dB eight hour exposure standard, organisations may underestimate the cumulative risk of hearing damage.

National guidance is clear that exposure must be assessed where there is uncertainty about whether the standard may be exceeded.

A pattern of system fatigue, not deliberate non compliance

Importantly, these gaps are rarely the result of deliberate disregard for worker safety.

They more often reflect systems that have not kept pace with operational change.

Industry bodies and safety professionals consistently highlight that noise management requires ongoing review. The Australian Institute of Health and Safety has identified occupational hearing loss as a continuing priority area, reinforcing the need for structured and active risk management.

Many organisations believe they are compliant until data is reviewed more closely.

Regulators are increasingly looking beyond whether testing occurred and focusing instead on whether the information is being used to actively manage risk.

A simple internal check

Consider the following:

• When was your last formal workplace noise assessment?
• Are audiometric results reviewed for trends across groups, not just individuals?
• Does your Noise Management Plan reflect current equipment, layout and production levels?
• Have control measures been reviewed following operational changes?

Noise data only protects workers when it leads to action.

In our next article, we will outline what effective, defensible workplace noise management looks like in practice and how organisations can stay ahead of scrutiny while protecting their workforce.

Detect. Protect