Clause 58 of the NSW Work Health and Safety Regulation 2017 introduces mandatory audiometric (hearing) testing for certain workers to prevent noise-induced hearing loss. This guide breaks down what NSW organisations need to do – from scheduling tests and managing reports to maintaining records and using the correct testing standards – in clear, practical terms. All information is aligned with official requirements (SafeWork NSW, WHS Regulation, Standards Australia) and is presented in Australian English.
1. What Clause 58 Requires: Who Must Be Tested and When
Who is covered? Clause 58 applies to any worker “frequently required” to wear personal hearing protectors because noise levels in their job exceed the exposure standard (LAeq,8h 85 dB(A) or peak 140 dB(C)). In simple terms, if a worker regularly uses earmuffs or earplugs as part of routine work in loud areas (not just a rare one-off task), they fall under Clause 58’s requirements. (Note: “Frequently” isn’t strictly defined in the law, but regulators interpret it as often or as a normal part of the job – e.g. daily or weekly use, not a once-in-a-blue-moon situation.)
Testing timelines: For any worker in this category, the PCBU (employer) must provide audiometric testing within 3 months of the worker commencing the noisy work (a baseline test), and at least once every 2 years thereafter. This means a new employee entering a high-noise role should ideally have a hearing test at the start of their role (or within the first three months on the job), and existing employees in such roles should be tested at least biannually. In practice, many organisations schedule repeat tests every 2 years to meet the minimum law, though more frequent testing (e.g. annual checks) can be done as a best practice – especially if noise levels are extremely high (above 100 dB(A) regularly) or shifts are long. The key is that no more than two years should ever pass between hearing tests for an at-risk worker.
Start date for compliance: After years of NSW delaying this requirement, Clause 58 is now in force. The long-standing exemption ended on 31 December 2023, so from 1 January 2024 onwards, all NSW PCBUs must comply with Clause 58. (Originally the law was set in 2017, but enforcement was postponed multiple times; it is now mandatory). There is a further grace period until 1 January 2026 for full enforcement in some guidance, but businesses should already be implementing audiometric testing programs to avoid penalties and protect workers’ hearing. The maximum penalties for not complying are significant (up to $6,000 for an individual PCBU or $30,000 for a company).
Summary of Clause 58 duties: The table below recaps the core obligations.
| Clause 58 Requirement | Details |
|---|---|
| Who must be tested | Any worker frequently required to wear hearing PPE due to hazardous noise >85 dB(A). This typically includes roles in workshops, factories, construction, heavy machinery operation, loud plant rooms, etc.. |
| Baseline test (new workers) | Provide an audiometric test within 3 months of the worker starting the noisy role. (Best done before or very soon after first exposure, to get a true baseline.) |
| Periodic re-testing | Provide follow-up hearing tests at least every 2 years for as long as the worker remains in that role. (More frequent testing can be done by choice; 2-yearly is the minimum.) |
| Employer’s cost | The PCBU must arrange and pay for the tests. It’s not to be charged to the worker. |
| Use of results | Use test results to verify if noise controls are effective and whether any hearing degradation is occurring, so you can intervene early. If testing reveals issues, you must act – more on that below. |
Integrate testing into safety management: In practice, NSW employers should incorporate audiometric testing into their onboarding and WHS programs. For example, ensure every new at-risk worker gets scheduled for a baseline hearing test (perhaps as part of their induction or within the first weeks on the job), and maintain a register or calendar for periodic tests (so that every 24 months, a reminder is set for re-test). Many organisations treat audiometric testing as part of their ongoing noise monitoring. The goal is not just “do a test and forget”; it’s to continuously monitor and protect workers’ hearing. As The Audiology Place notes, employers need a simple, reliable workflow – identify who needs testing, test on time, keep records updated, and respond to any changes in hearing (don’t just file the report away).
2. Audiometric Test Reports: Content, Format, and Providing Results to Workers
After each audiometric test, a report must be produced documenting the worker’s hearing levels. Clause 58 itself doesn’t spell out the report format, but best practice (and standards) dictate what information should be in these reports and how they are shared:
Audiometric test report content: At a minimum, the report will include the worker’s audiogram (the hearing threshold levels measured in each ear at various frequencies) and relevant details like the date of test, the worker’s details, and the testing conditions. Typically, frequencies from 500 Hz up to 8,000 Hz are tested. The baseline audiogram establishes the worker’s reference hearing levels, and subsequent monitoring audiograms show any changes compared to the baseline. The report should clearly indicate whether any significant shifts or hearing loss are present (see Section 5 for what counts as significant). It may also note if the test was done pre- or post-work shift, and any relevant observations (e.g. if the worker had earwax removed or if they had recent noise exposure). In essence, the report should present the results in a way that the PCBU and the worker can “make appropriate decisions” about hearing health – for example, flagging if follow-up is needed or if the worker’s hearing protection might be inadequate.
Providing results to the worker: Workers must be informed of their hearing test results and given an explanation of what those results mean. SafeWork NSW guidance makes it clear that results are given to workers immediately after the hearing test, with an explanation in plain language. In practice, the person conducting the test (often an audiologist) will review the audiogram with the worker right after testing – letting them know if their hearing is normal, if any hearing loss is detected, and whether any changes since their last test are apparent. This immediate feedback is important so the worker understands their hearing status on the spot.
Worker’s copy of report: The worker is also entitled to a written copy of their audiometric test results. Best practice is to give the worker a copy of each test report soon after the test (or make it accessible to them), and at the very latest, the PCBU must provide the worker with their cumulative hearing test reports when their employment ends. In NSW, the guidance specifically says employees “should get a copy of their hearing test reports when their employment ends.” This ensures the worker leaves with a record of their hearing status (which can be important for their future reference or if they need to make a workers’ compensation claim). However, it’s wise to provide a copy after each test as well – many providers will issue a personal report to the employee as a matter of course. For example, The Audiology Place delivers secure digital reports that can be shared with both the employer and employee, making sure the worker has easy access to their results.
Explanation of results: It’s not enough to hand over a graph of hearing thresholds. The results should be presented clearly. A competent tester (audiologist or audiometrist) will typically explain whether the hearing test is normal or indicates hearing loss. If it’s a monitoring test, they will compare it to the baseline and point out any changes. According to SafeWork NSW, even subtle shifts in hearing should be noted, though these may have no clinical significance; only larger shifts count as “significant” (discussed later). The worker should be told if their hearing is within normal range or if a hearing loss (permanent or temporary) is indicated. If a concerning change is found, the worker should be advised on next steps (e.g. needing a follow-up test after a quiet period, or seeing a doctor).
Confidentiality of reports: Audiometric reports contain personal health information, so they must be treated confidentially. The PCBU has a duty to ensure these reports are kept confidential (see Section 3 below), including how results are communicated. Typically, the results are given privately to the worker (e.g. one-on-one with the tester or a manager) rather than in a group setting. If the employer needs to discuss results with the worker, it should be done sensitively and privately.
In summary, after each hearing test, the process should be: the worker receives immediate verbal feedback on their hearing status, the employer gets the report for record-keeping, and the worker is provided a copy of the report (either at the time or at least upon exit). The report should clearly document the hearing levels and note any threshold shifts or recommendations, serving as both a medical record and an actionable document for workplace noise management.
3. Record-Keeping and Confidentiality Obligations
Proper record-keeping of audiometric test results is crucial for compliance. Clause 58 testing creates ongoing health records that the PCBU must manage responsibly, with respect for worker privacy. Key obligations include:
Keep all hearing test reports confidential: The PCBU must ensure that all audiometric test reports are kept confidential. This means storing them securely (whether in digital form or hard copy) and restricting access to authorised personnel only. Typically, these records would be treated like medical records or health surveillance files, separate from general HR files, with access limited to health and safety managers, occupational health staff, or others who need to know (and the worker themselves). Privacy laws (and good ethics) require that personal health information like hearing test results not be disclosed without the worker’s consent except for legitimate WHS purposes. SafeWork NSW explicitly states that hearing test reports must be kept confidential and not shared freely.
Retention period for records: NSW’s WHS Regulation doesn’t set a specific number of years to keep noise test records, but guidance suggests keeping them for a significant period. WorkSafe WA, for instance (which has essentially the same requirement in their regulations), advises employers to keep a copy of audiometric test results for at least 2 years. However, in practice you should keep them much longer – effectively for the duration of the worker’s employment (and even some years beyond, as noise-induced hearing loss can be cumulative and claims can arise later). A common recommendation in occupational health is to retain health surveillance records like audiograms for 30 years (similar to how records for asbestos or other exposures are kept). While 30 years isn’t a legal requirement for noise in Australia, it is best practice to err on the side of longer retention. At a minimum, ensure you always have the baseline and the most recent tests on file, and do not dispose of records while the person is employed. Given that SafeWork NSW requires you to give the worker their reports at the end of employment, it implies you will keep them at least until then. In short: retain audiometric records for each worker throughout their employment (and preferably long after) to maintain a continuous history of their hearing status.
Providing access to records: The worker has a right to access their own audiometric test results. As noted, they should receive copies upon leaving employment, but they can also request their results at any time. Employers should facilitate this and treat it as the worker’s personal health information. On the flip side, others (managers, etc.) should only access an individual’s results on a need-to-know basis. Typically, aggregate data might be used for workplace noise control evaluation (like seeing if groups of workers are showing shifts), but individual results should not be broadcast. If a regulator (SafeWork NSW inspector) asks to see evidence of compliance, you might show that tests have been done and perhaps anonymised summaries – do not hand out personal details without proper cause. Generally, though, regulators will expect you to produce records if needed to prove you’ve done the tests (so maintain an organised filing system).
Privacy considerations: Audiometric results are considered sensitive personal information under privacy principles. Employers in NSW should comply with the Privacy Act (if applicable) and any health records legislation. This includes obtaining consent for tests (usually part of employment conditions in noise roles), and handling data in accordance with privacy policies. Also, ensure that if you use an external provider, they too have confidentiality practices (most audiology providers will have workers sign a consent and will only release results to the employer and the worker). Keep in mind that an employee’s hearing ability might be a sensitive topic; maintain discretion.
Record updates and “updated baseline”: If a worker has a significant change in hearing, the audiologist may issue a new “updated baseline” audiogram. This means the hearing loss is considered permanent and future tests will be compared against this new reference (so you’re not counting the same loss twice). Employers should keep all versions – original baseline and any updated baseline reports – in the file (safework.nsw.gov.au). This history is important to see progression. Each report should be dated and labeled so you know which is the baseline (or updated baseline) and which are monitoring results.
Retention of noise exposure data: Related to audiometric records, you should also keep any noise survey results or exposure assessments that led you to identify who needs testing. While not explicitly part of Clause 58, the Code of Practice recommends doing noise level checks. Those records (noise measurements) help justify why certain workers are included in the testing program.
In summary, maintain a confidential hearing test register: store every test result securely, update it with each new test, and ensure workers can obtain their records. A good practice is to have a spreadsheet or database listing each worker’s test dates and next due date, with the detailed reports filed separately (electronically or in a medical file). Keep everything confidential and long-term. By doing so, you not only comply with legal duties but also have valuable data to defend against or manage any future hearing loss claims.
4. Role of AS/NZS 1269.4:2014 – Testing Standards and Methods
AS/NZS 1269.4:2014 (Occupational Noise Management – Part 4: Auditory Assessment) is the Australian/New Zealand Standard that specifies how occupational hearing tests must be conducted and how results should be managed. Clause 58 explicitly requires that audiometric testing be done according to procedures outlined in AS/NZS 1269.4:2014. In practical terms, this standard ensures consistency and accuracy in testing. Here’s what it mandates or recommends:
Testing procedure: The standard prescribes the use of pure-tone audiometry for measuring hearing thresholds. Clause 58 itself defines audiometric testing as “the testing and measurement of the hearing threshold levels of each ear of a person by means of pure tone air conduction threshold tests.” This means the classic hearing test where tones at various frequencies are played through headphones and the subject indicates when they hear them. AS/NZS 1269.4 gives detailed procedures for this: which frequencies to test, calibration of the audiometer, how to present the tones (e.g. duration, interval), etc., to ensure reliable results. Testing must cover a range of frequencies (typically 500 Hz up to 8,000 Hz) because noise-induced hearing loss often shows up first at high frequencies (3,000–6,000 Hz range). The standard likely aligns with testing at standard audiometric frequencies: 0.5, 1, 1.5, 2, 3, 4, 6 and 8 kHz3.
Test environment: AS/NZS 1269.4 specifies the maximum allowable background noise in the test environment to ensure accurate threshold detection. In practice, this means tests should be conducted in a quiet room or audiometric booth. Often a sound-proof booth or specially designed quiet room is used on-site, or a testing van with a booth. The standard likely includes an appendix with ambient noise level criteria for the room (for example, OSHA has specific dB limits per frequency band for audiometric test rooms; AS/NZS would have similar). The bottom line: the worker should be tested in a setting where external noise won’t mask the test tones. Typically, the person sits in a booth wearing calibrated headphones. The tester (outside the booth) plays tones and the worker presses a button each time they hear a sound. If a quiet booth is not available on-site, tests may be done at an off-site clinic with proper facilities. The Audiology Place, for example, conducts tests in a controlled “quiet suite” or via a mobile setup to meet these standards. Ensuring the environment meets AS/NZS 1269.4 is critical for accuracy – background noise can elevate threshold results (making hearing appear worse than it is).
Tester qualifications: The standard emphasizes that testing be done by a competent person. AS/NZS 1269.4 includes competency requirements (previous editions had an Appendix E listing required skills for audiometric officers). SafeWork NSW echoes that a hearing test must be performed by “a competent person (e.g., audiologist) having acquired the necessary level of training and experience to perform the test, interpret the results and present them in a manner that enables persons at the workplace to make appropriate decisions.” In practice, this means the tester should be either a qualified audiologist, audiometrist, or an occupational health professional with specific training in audiometric testing. There are certified courses for Occupational Audiometrists (often 2–4 day training courses based on AS/NZS 1269.4). Many providers use audiologists (who have university degrees in audiology) to ensure high competence. The key is that the person can not only operate the equipment correctly but also interpret audiograms and recognize whether a pattern of hearing loss is work-related noise damage or possibly due to other causes. AS/NZS 1269.4 effectively requires that if an audiometric technician (not fully qualified audiologist) conducts the test, there should be audiologist or physician oversight for reviewing any abnormal results3. For most businesses, the simplest path is to engage a reputable occupational audiometry service so you know the personnel meet these criteria. (Section 6 below addresses tester qualifications in more detail.)
When and how tests are done (baseline vs monitoring): The standard provides guidance on timing of tests relative to noise exposure. A baseline (reference) audiogram should be obtained after a sufficient period of quiet, so it reflects the worker’s true hearing not temporarily dulled by recent noise. Ideally, new workers should do a baseline test before they commence noisy duties or at least have had 14+ hours away from loud noise before the test. However, given Clause 58 allows up to 3 months after starting work, the worker might have been exposed already – in those cases, some companies do two tests: one at the end of a work shift (to catch any immediate temporary shift) and another the next day after quiet, to establish the true baseline. AS/NZS 1269.4 describes procedures for monitoring audiometry: it suggests periodic tests (2-yearly or more frequent) and indicates that doing a test during the work shift (or end of shift) can help detect Temporary Threshold Shifts (TTS), whereas doing a test after a quiet period determines if there’s a Permanent Threshold Shift. In practice, a common approach consistent with the standard is: do the monitoring test a few hours into the shift (when the ears might be fatigued by noise) to see if there’s any temporary shift present, then follow up with a second test after 16 hours of quiet if the first test shows a significant change. This two-step method is implied in guidance: SafeWork NSW says monitoring tests “should be performed a few hours into the worker’s shift to identify the presence of temporary threshold shifts”, and if a temporary shift is found, a re-test after 16 hours quiet is needed to see if it’s permanent. Not every routine test will require two tests, only if a shift is suspected. The standard basically ensures that any apparent hearing loss is verified as permanent by retesting in quiet conditions.
Calibration and equipment standards: AS/NZS 1269.4 also covers the technical aspects: the audiometer must be properly calibrated (usually to AS/NZS 1269.4 or IEC standards) and checked (often daily using a bioacoustic simulator). Headphones used for testing need to be the specific ones calibrated with the machine. The standard likely references that audiometric test rooms and equipment meet certain criteria (e.g., background noise levels, audiometer calibration to AS/NZS 1269.4 Appendix, etc.). This is typically handled by the test provider – they ensure their kit and setup comply. If an organisation does in-house testing, they need to strictly follow these requirements.
Interpretation of results: The standard doesn’t just stop at doing the test – it provides guidance on assessing the audiogram. It defines what constitutes abnormal hearing and significant shifts (see next section for the exact criteria of “significant threshold shift” defined in AS/NZS 1269.4). It likely requires that any significant change be reviewed by a qualified professional (audiologist or ENT doctor), and that results are communicated to the worker with appropriate advice. AS/NZS 1269.4 is essentially embedded into the process to ensure that the audiometric testing program is effective as a hearing conservation tool – meaning it should detect early signs of noise damage so the employer can act, not just fulfill a checkbox.
In summary, AS/NZS 1269.4:2014 is the rulebook for how to do hearing tests properly. NSW organisations must use testing services or methods that comply with this standard. By doing so, you ensure tests are accurate (done in the right conditions), consistent, and that any hearing changes are correctly identified. Always ask your testing provider if they follow AS/NZS 1269.4 – reputable ones will do so automatically. The Audiology Place, for example, explicitly conducts “industrial audiometry to AS/NZS 1269.4” and uses a sound-treated environment to meet the standard. Following the standard also protects you legally: if ever questioned, you can show that tests were done according to the recognized technical standard for workplace audiometry.
5. ‘Significant Threshold Shift’ – Definition and Importance
A critical concept in interpreting audiometric results is the “significant threshold shift”. This term refers to a change in a worker’s hearing thresholds that is large enough to indicate a potential noise-induced hearing loss (as opposed to minor day-to-day variations or testing error). Under AS/NZS 1269.4 (and related guidelines), not every change in an audiogram is significant – the standard sets specific criteria for determining whether a hearing shift is significant. If a shift meets those criteria, it often triggers specific actions (e.g. follow-up tests, review of controls, possible reporting to insurer).
Definition under AS/NZS 1269.4:2014: The standard defines a significant threshold shift in quantitative terms. A shift is typically considered “significant” if the difference between the latest test and the baseline (or updated baseline) meets any of the following conditions (in either ear)
High-frequency average shift: An average hearing threshold increase of ≥ 5 dB at 3,000, 4,000 and 6,000 Hz (high-frequency range relevant to noise) (In other words, when you take the thresholds at 3, 4, and 6 kHz, the new test is at least 5 dB worse on average than the baseline.)
Mid-frequency shift: An average increase of ≥ 10 dB at 3,000 and 4,000 Hz (This captures cases where maybe 6 kHz hasn’t shifted as much, but 3 and 4 kHz have a notable change.)
6 kHz isolated shift: A ≥ 15 dB increase in threshold at 6,000 Hz(if not already caught by the 5 dB average criterion). Noise-induced loss often shows up at 4–6 kHz, so a big drop at 6 kHz alone is significant.
Low-to-mid frequency shift: A threshold increase of ≥ 15 dB at any of the low/mid frequencies 500, 1000, 1500, or 2000 Hz. (These frequencies are less commonly affected purely by noise, so if they shift that much, it’s significant and possibly due to other issues or a very broad hearing loss.)
8 kHz shift: A threshold increase of ≥ 20 dB at 8,000 Hz. (8 kHz is quite high frequency; a big change here is also notable, though 8 kHz can sometimes be variable.)
(These criteria are derived from AS/NZS 1269.4, which lists thresholds (a) through (e) as above for a standard threshold shift)
To put it more simply: a significant shift is generally a change of 10–15 dB or more in hearing ability at key frequencies, especially the high frequencies, compared to the baseline. Even a 5 dB average worsening in the high-frequency range is flagged, as it could signal the onset of noise-induced loss if it persists. The standard is deliberately a bit sensitive; it errs on the side of catching potential shifts early.
Temporary vs permanent shifts: Not every significant shift is permanent. Workers may show a significant shift on a test conducted during or at end of a noisy shift – this could be a Temporary Threshold Shift (TTS), essentially a short-term reduction in hearing due to recent noise exposure (like your ears “tiring out”). A TTS will recover after a period of quiet (usually within 16 hours). That’s why the standard and guidance require a confirmatory retest after the worker has been away from noise for at least 16 hours (often the next morning before the shift, or after a weekend) if a significant shift is observed. If the follow-up test still shows the shift, it is then considered a Permanent Threshold Shift (PTS) – meaning the hearing loss is real and lasting. SafeWork NSW outlines this process: a temporary shift triggers a retest after 16 hours of quiet to see if it was just temporary or permanent. A permanent shift suggests noise-induced hearing loss (or another pathology) has occurred.
What happens if a significant permanent threshold shift is found? Under Clause 58 and general duties, the PCBU must take action. A significant permanent shift in a worker’s hearing means that despite using hearing protection, the worker has sustained hearing damage. This is a red flag that the noise controls in place may not be sufficient or not properly used. SafeWork NSW and the Code of Practice direct PCBUs to review and improve noise control measures whenever a significant permanent shift is detected. Actions should include:
Investigating the work tasks and environment to identify why the hearing loss occurred: Was there an increase in noise exposure recently (new equipment, longer hours, lapse in using protection)?
Checking that all feasible higher-order noise controls are in place: e.g. isolating noisy machinery, engineering controls like silencers or enclosures, rather than relying solely on earplugs.
Ensuring the worker’s hearing protectors are adequate and properly fitted. The protector’s rating (SLC80 or class) should reduce noise to below 85 dB at the ear; if not, provide better protectors. Also, re-train the worker on fitting them – even the best earplug won’t work if worn loosely.
Considering ototoxic chemicals or other factors if applicable: some chemicals can worsen hearing loss. The guidance suggests substituting or controlling such substances if they’re present.
Re-training and supervision: Ensure the worker and their supervisors enforce consistent use of hearing protectors throughout the duration of noise exposure. Sometimes hearing loss happens because people remove their earplugs intermittently – training and supervision can address this.
Follow-up medical action: If a permanent shift is confirmed, the worker should be referred to a medical practitioner or audiologist for a thorough evaluation. This can rule out other causes (e.g. ear infections, age-related loss) and confirm the diagnosis of noise-induced hearing loss. Also, an ENT specialist might check if the loss is treatable or needs hearing aids.
Additionally, because a confirmed permanent shift constitutes an injury/illness (occupational hearing loss), the PCBU in NSW is generally expected to notify their workers’ compensation insurer once an audiometric assessment identifies a worker with a permanent hearing loss. The SafeWork NSW fact sheet explicitly states: “A business must notify its workers’ compensation insurer when an audiometric assessment identifies a worker as having a permanent threshold shift.”. The insurer will then handle it as a reported incident of potential industrial deafness – possibly arranging further assessments and determining liability or compensation. (Note: The requirement to notify may also tie into the definition of a notifiable incident if the hearing loss is deemed serious – but usually, gradual hearing loss is handled via workers’ comp rather than immediate incident notification.)
Accommodating workers with hearing loss: If a worker develops permanent hearing impairment, the employer should also consider whether any workplace adjustments are needed so they can continue working safely. For example, if the worker has trouble hearing warning signals or communications, you might need to install visual alarms (flashing lights), provide two-way radios or amplified headsets, ensure machines have volume controls or lower noise output, or even rotate the worker to a less noisy job if necessary. The SafeWork NSW guidance suggests making “suitable arrangements at the workplace to accommodate a worker’s hearing loss” such as volume control on phones, acoustic treatments in meeting areas, visual warning signals, etc., or alternative duties if needed. This goes beyond Clause 58’s testing requirement, but it’s part of the employer’s general duty to ensure the worker isn’t put at risk due to their hearing limitation.
In summary, a significant threshold shift is a measurable drop in hearing that exceeds the standard’s criteria – essentially an alert that the worker’s hearing has likely been damaged. It’s the trigger for action: confirm if it’s permanent, report it appropriately, and intervene to prevent further loss. Clause 58’s whole purpose is to catch these shifts early, so that employers can step in with better controls or medical intervention before the hearing loss worsens. Always pay close attention to the audiometric reports: if a report shows a significant shift (which the tester will usually flag), treat it with the urgency it deserves.
6. Qualifications and Training for Audiometric Testers (AS/NZS 1269.4 Requirements)
The quality of audiometric testing depends heavily on the people who conduct and interpret the tests. Under AS/NZS 1269.4 and WHS regulations, audiometric tests must be performed by competent, appropriately trained individuals.
“Competent person” requirement: SafeWork NSW and the model WHS laws stipulate that a “competent person (e.g., audiologist)” should carry out the hearing tests. In this context, competent means someone who has acquired through training, qualification, or experience the knowledge and skills to carry out the task. Specifically for audiometry, competency involves being able to:
Administer the test properly: set up the equipment, position the worker, give instructions, and conduct the hearing test in accordance with the correct protocol (as per AS/NZS 1269.4).
Ensure test validity: check for things like excessive background noise, suspect unreliable responses, or ear issues (a tester should, for instance, inspect the ear canal for wax using an otoscope before testing, as occluded ears can affect results).
Interpret the audiogram: understand what the results mean – distinguishing between normal hearing, standard patterns of noise-induced loss, and other abnormal configurations. They should know the criteria for a significant shift (as discussed) and what actions are recommended if a shift is found.
Communicate results effectively: translate audiogram data into plain-language advice for the worker and into clear reports for the employer. The tester should be able to advise whether the results are within expectations or indicate a potential problem.
AS/NZS 1269.4 likely details competencies in an Appendix (the 2014 standard has an Appendix D or E listing the competency requirements for audiometrists). These typically include knowledge of acoustics, anatomy and physiology of hearing, audiometric techniques, equipment calibration, and understanding of noise regulations and hearing conservation principles.
Typical qualifications for testers:
Audiologist: A university-trained audiologist (often holding a Master’s degree in Audiology) is fully qualified to conduct and interpret audiometric tests. Audiologists are credentialed professionals skilled in diagnostic hearing assessments and are certainly competent to do workplace hearing tests. Many organisations choose to have audiologists perform Clause 58 testing for the highest standard of care.
Audiometrist / Occupational Audiometrist: In Australia, an audiometrist is often someone with TAFE or industry training in hearing testing (not a full audiologist, but trained to conduct hearing tests). There are specific courses for Occupational Audiometry – for example, 2-day or 4-day courses focused on industrial hearing testing in accordance with AS/NZS 1269.4. People who complete these courses (often safety professionals, nurses, or others in OH&S) can be deemed competent to perform screening audiometry in workplaces. They learn to do the tests and usually when to refer issues to an audiologist or doctor. If an audiometrist (rather than an audiologist) does the tests, it’s good practice to have an audiologist review any abnormal audiograms (e.g., significant shifts) – something AS/NZS 1269.4 allows for and 3M’s guide notes as required in some regulations.
Other healthcare professionals: Sometimes occupational health nurses or doctors with training in audiometry can do the tests. However, they too must have completed appropriate training per the standard.
Certification: There is no state-issued “license” specific to audiometric testers in NSW, but certification from recognised training (like courses endorsed by Audiology Australia or SafeWork) is evidence of competence. For instance, courses by Occupational Hearing Conservation organisations or the Hearing Company provide a certificate of competency in occupational audiometry aligned with AS/NZS 1269.4. Employers should ensure that whoever is conducting the tests has the necessary credentials or ample experience.
Regulatory oversight: While the WHS Regulation doesn’t require you to submit qualifications, it implicitly expects competence. If an inspector audited your program, they might ask, “Who’s doing the tests and are they qualified?” Using a reputable provider (like an occupational audiology clinic) generally satisfies this, since those providers stake their business on meeting the standard. If you do testing in-house, ensure your staff are trained to the standard and keep records of their training.
Summary: Ensure that audiometric testing is conducted or overseen by qualified professionals. In simple terms, engage an audiologist or an accredited occupational audiometric tester to do the job. They will not only administer the tests correctly, but also properly interpret results and advise on next steps. AS/NZS 1269.4 provides guidance on what training/knowledge is required; by following it, you ensure the person testing your workers isn’t a random technician but someone who can catch early signs of hearing loss and help you act on them. The Audiology Place, for example, uses an independent audiologist (Dr. Signe Steens) with over 20 years’ experience in noise-induced hearing loss, ensuring precise assessments and credible results. That level of expertise is invaluable for compliance and for your workers’ health.
7. Delivering Clause 58 Compliance: How a Provider like The Audiology Place Can Help
Achieving compliance with Clause 58 can be straightforward with the right support. Specialised occupational audiometry providers (such as The Audiology Place) offer services tailored to meet all the requirements we’ve outlined. Here’s how a provider can assist NSW organisations in a practical way:
Complete testing service (baseline & periodic): A provider will conduct the required baseline hearing test within 3 months of a worker commencing a high-noise role and establish a schedule for repeat tests at least every 2 years. This ensures no worker “falls through the cracks.” The Audiology Place, for instance, helps employers by setting automated reminders for each employee’s next test due date, so the testing cycle stays on track. They can test new hires promptly and then re-test all relevant staff every 24 months (or more often if requested).
On-site or off-site testing with appropriate facilities: Providers can often bring mobile testing booths or equipment on-site, minimising disruption (workers don’t have to travel off-site). The Audiology Place notes that they can run industrial audiometry onsite or in their quiet suite in Forestville, using properly calibrated equipment and a sound-controlled environment that meets the requirements of AS/NZS 1269.4. On-site testing is popular for larger teams: a van or a quiet room is set up at your workplace and workers cycle through quick tests. Alternatively, for smaller companies or pre-employment checks, workers can attend the provider’s clinic. In both cases, the provider ensures the testing environment and procedure comply with the standard – you as the PCBU don’t have to worry about technical details.
Qualified personnel: A compliance-focused provider will use independent, qualified audiologists or audiometrists to perform the tests. The Audiology Place emphasises that they are independent (not affiliated with hearing aid sales, etc.) and have expert audiologists to ensure “the best assessment of hearing for your workplace.” This means the results are trustworthy and unbiased. They also mention being a “certified provider for SIRA, iCare, and WHS NSW,” indicating they are recognised by relevant bodies to provide these services. Using such a provider gives confidence that the testers know the WHS law and the technical standards.
Testing to the AS/NZS 1269.4 standard: Providers like The Audiology Place explicitly perform tests in accordance with it. They adhere to the correct methods (pure-tone audiometry, appropriate frequencies, calibration) and recommended practices (for example, they might do tests both mid-shift and post-shift if needed to identify temporary vs permanent shifts, per the standard). They’ll also have protocols for follow-up testing after 16 hours of quiet when a shift is detected, and for referral to medical professionals if hearing loss is found – all aligned with the standard and SafeWork guidelines.
Comprehensive reporting: After testing, a good provider will supply clear, detailed reports for each worker. The Audiology Place delivers secure digital reports that slot into your WHS files. These reports typically include the audiogram chart, an explanation of results (e.g. “Hearing within normal limits” or “Mild high-frequency loss detected”), and highlight any significant threshold shifts compared to the baseline. They may also include recommendations (e.g. “fit check hearing protection” or “re-test after 16 hours quiet to confirm shift”). Because the reports are digital, it’s easy for the organisation to store them (ensuring confidentiality) and also easy to forward the individual report to the worker. A provider’s report format is usually designed to meet Clause 58 obligations – containing all the needed info and ready to be shared. Additionally, The Audiology Place states that it provides clear next steps whenever a result requires follow-up. For example, if a worker shows a permanent shift, the report might advise “investigate workplace noise controls and refer worker for medical assessment.” This helps the PCBU know what actions to take.
Employee communication and education: The provider can handle communicating results to workers, including providing an immediate explanation. Their audiologist will typically counsel each worker on their results in a private setting, answering questions (e.g. about tinnitus or any changes noticed). Providers can also offer education sessions or materials on hearing protector use and care, which complements the testing program. The Audiology Place notes they can “brief supervisors on correct PPE use (so your testing actually prevents loss)”, meaning they don’t just do the test and leave – they help reinforce the workplace’s hearing conservation practices. This holistic approach ensures the testing program contributes to real hearing loss prevention, not just paperwork.
Determining who needs testing: A provider can assist in reviewing your workplace noise exposures to map which roles are “in scope” for Clause 58. Sometimes an employer isn’t sure which workers cross the threshold of “frequently exposed above 85 dB.” The provider (often experienced across various industries) can help identify those roles, possibly by reviewing your noise survey or conducting a noise-level screening. This ensures you test all the required workers and don’t waste resources testing those who don’t need it.
Maintaining records and reminders: As mentioned, providers often keep a database of tests conducted and will send you reminders when the next test is due (since they want your repeat business and you want compliance). This is extremely helpful administratively – it acts like a hearing test calendar for your workforce. All you need to do as the PCBU is act on those reminders (schedule the provider’s visit or send the worker for their appointment). The Audiology Place specifically highlights that they “set automated reminders so no one falls out of cycle”, which is a valuable service feature.
Support with compliance and follow-up: If an inspector ever queries your audiometric testing compliance, having a professional provider’s involvement can make it easy to demonstrate compliance – you’ll have organised reports and proof of testing. Moreover, if a significant hearing loss is identified, providers can guide you on next steps (for example, The Audiology Place can “guide businesses through compensation claims processes if needed”, since they are familiar with workers’ comp requirements). They can also help determine whether a loss is likely work-related or due to non-occupational factors, which can be important information for the insurer or a workplace investigation.
In essence, a provider like The Audiology Place acts as a partner in your hearing conservation program. They bring expertise, equipment, and systems to ensure you meet Clause 58 efficiently. For businesses, this is often much easier than trying to set up an internal audiometric testing capability. By outsourcing to qualified professionals, you benefit from their knowledge (20+ years of experience in the case of Dr Steers at The Audiology Place) and demonstrate due diligence in protecting your workers.
When selecting a provider, look for those who:
explicitly state compliance with WHS regulations and AS/NZS standards,
use qualified audiologists or audiometrists,
offer on-site testing for convenience,
provide detailed reports and data management, and
have a track record in occupational health.
The Audiology Place is one such example, and engaging a similar service will make fulfilling Clause 58 not only achievable but relatively hassle-free. Remember, the goal isn’t just to “tick the box” – it’s to genuinely prevent hearing loss. A good provider helps you do both: stay compliant and keep your team’s hearing safe.
References
NSW Legislation – Work Health and Safety Regulation 2017, Clause 58 “Audiometric testing” (in force as of 2024).
SafeWork NSW – Hearing test requirements for NSW workers (2023).
SafeWork NSW – Fact Sheet: New hearing test requirements for NSW employers and workers (2023).
NSW Resources Regulator – Fact Sheet: Audiometric testing requirements (Sep 2023).
WorkSafe WA – Audiometric testing requirements FAQs (2025).
AS/NZS 1269.4:2014 – Occupational Noise Management Part 4: Auditory Assessment (via 3M NZ summary)3mnz.co.nz.
The Audiology Place – Workplace Hearing Tests – Clause 58 (website information).
