In NSW, a PCBU must provide audiometric testing for workers who are frequently required to use hearing protection because workplace noise exceeds the exposure standard. The exposure standard is LAeq,8h 85 dB(A) or LC, peak 140 dB(C). [1] The PCBU providing the hearing protection must arrange testing within 3 months of the worker commencing the work, and at least every 2 years thereafter. [2]
SafeWork NSW is explicit that hearing tests must be performed by a competent Audiologist and conducted in accordance with the procedures in AS/NZS 1269.4:2014. [3] AS/NZS 1269.4 sets the requirements for conducting pure-tone air-conduction threshold audiometry for occupational monitoring, including the acoustical environment, equipment requirements, audit-ready documentation, and what to do when a change in hearing is detected. [4]
A compliant, audit-ready program has a few pillars:
It starts with pre-test controls: identify who is in-scope, book correctly, screen medically, and ensure the test environment meets Maximum Permissible Ambient Noise Levels (MPANLs).
It then uses a standardised on-site protocol with calibrated equipment and repeatability checks.
It concludes with evidence-based interpretation (including significant threshold-shift follow-up) and strong privacy controls, so that workers receive their full results, while employers receive compliance-focused outcomes and de-identified trends unless the worker consents to broader disclosure. [5]
The compliance framework in NSW
What NSW law actually requires
Clause 58 applies when a worker is frequently required to wear hearing protection to protect against hearing loss from noise that exceeds the exposure standard. [2] In practice, SafeWork NSW explains “frequently” in this context as “often or many times” throughout the shift, when higher-order controls cannot keep noise below the standard. [6]
The testing frequency rules are simple and enforceable:
A baseline test must be provided within 3 months of commencing the work, and testing must occur at least every 2 years. [7] SafeWork NSW adds that more frequent testing may be required where the average noise across the shift is high (for example, ≥100 dB(A)). [8]
SafeWork NSW also flagged a transition requirement: workers employed before 1 January 2024 needed to be tested before 1 January 2026. [3]
What “compliant audiometry” means in practice
SafeWork NSW states that the hearing test must be performed by a competent person (for example, an audiologist) with the training and experience to conduct the test and interpret the results, and that hearing tests must be conducted in accordance with AS/NZS 1269.4:2014. [3]
AS/NZS 1269.4:2014 confirms its scope for workplace hearing monitoring using pure-tone air-conduction threshold audiometry, specifies the conditions under which audiometry should be carried out, the form of tests, who should perform them, and how to compare a reference audiogram with follow-ups. [4] It also warns that these procedures are not designed to diagnose the cause or determine the percentage loss for compensation. [9]
What employers should do with the results?
Two principles must be kept together:
Employers have a duty to review controls if a threshold shift or tinnitus is identified. SafeWork NSW states that when a significant permanent threshold shift is detected, or tinnitus is diagnosed, the PCBU must review noise control measures and actions such as ensuring hearing protectors are adequate, and workers are retrained. [10]
At the same time, privacy is not optional. The NSW Code of Practice states that workers should be given results with a written explanation, and that an employer can provide an individual worker’s results to other parties only with the worker’s consent; only de-identified individual results and group data should be shared more broadly. [11]
The practical solution is a two-tier reporting model:
Workers get their full audiogram and counselling.
Employers get a WHS-focused compliance summary (testing completed, follow-up required, de-identified trends, and program recommendations), and only receive identifiable medical details if the worker provides informed consent. [12]
Pre-test requirements and site preparedness
Booking and employer inputs
Before anyone is tested on-site, you need evidence that the program is targeting the correct population:
Confirm the workplace has done a noise risk assessment (SafeWork NSW says PCBUs must make a reasonable attempt to assess noise risk, and complex workplaces should use a competent person such as an occupational hygienist). [6]
Confirm the test cohort: only workers frequently required to use hearing protection because noise exceeds the exposure standard are automatically in scope. [13]
Worker instructions and the 16‑hour quiet requirement
SafeWork NSW notes that, where a temporary threshold shift is identified, a re-test must be conducted on another day after 16 hours in quiet conditions to determine whether the shift is permanent. [10]
Even when not legally mandatory for every monitoring test, the 16-hour quiet principle is central to interpreting changes. A robust clinic workflow does two things:
It asks workers to avoid loud noise (or use effective hearing protection) during the 16 hours before any test used as a baseline, or as a confirmatory “quiet” retest after a suspected shift. [3]
It uses timing strategically: the NSW Code of Practice recommends that follow-up tests be undertaken “well into the work shift” to detect temporary hearing loss, while SafeWork NSW suggests monitoring tests a few hours into the shift to identify temporary hearing loss. [5] Your program can accommodate both by clearly marking each test as either a “quiet baseline/confirmatory retest” or a “work-shift monitoring test”.
Medical screening before testing
SafeWork NSW states that an ear examination should be performed before the hearing test to check for physical damage or obstructions such as earwax that may affect results. [10]
Your screening should identify situations where testing should not proceed (or should be documented as incomplete), including:
Occluding wax, active ear infection, acute ear pain, recent ear surgery, or any condition making earphone placement unsafe or unreliable.
Recent high-noise exposure makes the test likely to reflect temporary changes rather than stable hearing thresholds.
Your internal on-site workflow should specify that incomplete testing due to medical factors triggers referral and retesting once medically cleared.
Site suitability and MPANLs
AS/NZS 1269.4 includes a dedicated section on the acoustical environment and appendices covering measurement of ambient noise and maximum permissible ambient noise levels for workplace programs. [9] The standard moved from a fixed “approved headset list” toward a performance-based MPANL approach (Appendix C), recognising that compliance depends on the earphone/enclosure combination and measured ambient noise. [9]
In practical terms, site suitability has three checks:
The room must be quiet enough in the relevant frequency bands during the test.
The room must stay stable (HVAC cycling, forklifts, grinders, conversations, and coffee roaster operations can all break compliance).
The physical setup must support good test technique (seated comfort, minimal distractions, safe infection control, and privacy).
MPANL tables for supra-aural vs insert earphones
Insert earphones generally allow testing in higher ambient noise than supra-aural earphones, but only when they are inserted correctly. The E-A-RTONE insert earphone documentation notes that full insertion depth is required for maximum ambient noise attenuation, and that insert earphones reduce background noise that might otherwise mask test signals. [14]
Below is a widely used octave-band MPANL reference set for “ears covered” testing derived from ANSI S3.1 values and reproduced in published insert earphone technical documentation. These figures are useful as conservative, field-friendly benchmarks when conducting air-conduction testing at 500–8000 Hz, which is typical for occupational monitoring. [14]
Maximum permissible ambient noise levels, dB SPL (octave bands), test frequency range 500–8000 Hz
| Octave band centre frequency (Hz) | Supra-aural earphones MPANL (dB SPL) | Insert earphones MPANL (dB SPL) |
| 125 | 49.0 | 78.0 |
| 250 | 35.0 | 64.0 |
| 500 | 21.0 | 50.0 |
| 1000 | 26.0 | 47.0 |
| 2000 | 34.0 | 49.0 |
| 4000 | 37.0 | 50.0 |
| 8000 | 37.0 | 56.0 |
These are not a substitute for applying AS/NZS 1269.4’s MPANL method to your specific equipment, but they are highly practical for deciding whether a room is viable for boothless screening and whether you should switch from supra-aural to inserts to improve environmental tolerance. [15]
On-site testing procedures aligned to AS/NZS 1269.4
Equipment and calibration essentials
SafeWork NSW and the NSW Code of Practice both require audiometric testing to be performed by a competent person and conducted in accordance with AS/NZS 1269.4 procedures. [8] A practical on-site kit typically includes:
A calibrated audiometer suitable for pure-tone audiometry, an otoscope, hygienic consumables, and a system for secure record capture.
A method for performance checking before the day’s testing begins, because invalid tests cannot be used to meet regulatory requirements. [16]
Insert earphones as an option when ambient noise is borderline, noting that insertion quality matters. [14]
Your internal clinical workflow should specify daily listening checks and clear “stop rules” when equipment performance is suspect.
Supra-aural vs insert earphones
Choosing transducers is a compliance decision as much as a clinical one:
Supra-aural earphones are common and fast, but are more vulnerable to low-frequency ambient noise. [14]
Insert earphones improve background noise tolerance and reduce the risk that room noise will mask tones, but only if inserted correctly and consistently. [14]
For challenging environments, research from the Australian Acoustical Society journal describes how combining insert earphones with an earmuff enclosure increases attenuation and allows testing in noisier locations than would otherwise be possible, aligning with performance-based MPANL concepts. [17]
Standardised test protocol with repeatability checks
The NSW legal definition of audiometric testing is pure-tone air-conduction threshold tests. [2] AS/NZS 1269.4 governs how to run that protocol in an occupational monitoring context. [18]
A robust workplace protocol includes:
Clear worker instructions and a quick demonstration to ensure the response method is understood.
Otoscopy before placing transducers. [19]
A consistent frequency order (commonly starting mid-frequency, working to higher frequencies, then returning to low frequencies) and a built-in retest point to verify reliability.
Repeatability checks that trigger immediate re-instruction, transducer repositioning, or a full retest when results are inconsistent or suggest non-organic responding.
Your internal operational checklist can encode these steps, including the re-seat and retest process at key frequencies before finalising results.
Handling incomplete or invalid tests
SafeWork NSW recognises that some tests are invalid or incomplete and may need to be repeated; in other cases, workers require referral for more comprehensive testing. [16]
There are two distinct “incomplete” categories you should handle differently:
If the worker does not attend or cannot be tested due to site disruption, document as incomplete due to operational factors and rebook according to your service agreement rules.
If the test cannot be completed due to a medical issue, such as occluding wax or a suspected infection, document it as incomplete due to medical factors, advise medical review, and plan retesting once cleared. This aligns with SafeWork NSW’s emphasis on ear examination and ensuring blockages do not invalidate the test. [19]
Clinician checklist for on-site audit readiness
A clinician-ready checklist that pairs well with AS/NZS 1269.4 and NSW expectations is:
Confirm the worker is in-scope (frequent hearing protection due to noise > standard). [13]
Record test type (baseline/reference, monitoring, or confirmatory quiet retest) and timing relative to work shift. [5]
Document otoscopy findings and whether any medical factor affected validity. [20]
Document the test environment: location, ambient noise verification outcome, transducer type used, and any mitigations.
Document equipment status: calibration currency and day-of-test performance check outcome.
Provide the worker with their result and explanation at the time, consistent with NSW guidance. [8]
Post-test interpretation, significant threshold shift, and follow-up
Comparing baseline to monitoring tests
AS/NZS 1269.4 is specifically designed to support comparison of a reference audiogram to follow-up audiograms and to guide action when deterioration is detected. [9] SafeWork NSW emphasises that monitoring results are compared to baseline to assess changes. [3]
Where a change suggests a temporary shift, SafeWork NSW states a re-test must be performed on another day after 16 hours in quiet conditions to determine if the shift is permanent. [10]
Significant threshold shift criteria
A widely cited AS/NZS 1269.4-aligned significant threshold shift definition is:
Average shift at 3000, 4000, 6000 Hz ≥ 5 dB; or mean shift at 3000 and 4000 Hz ≥ 10 dB; or change at 6000 Hz ≥ 15 dB; or shift ≥ 15 dB at 500, 1000, 1500 or 2000 Hz; or shift ≥ 20 dB at 8000 Hz. [16]
Your clinic’s interpretation framework should treat these as “triggers for action”, not as a diagnosis, consistent with AS/NZS 1269.4’s limitation that workplace audiometry is not sufficient to diagnose cause. [9]
What to do when a shift or tinnitus is identified
The NSW Code of Practice requires that reasons for changes over time be thoroughly investigated, and that when temporary or permanent threshold shifts are revealed, or tinnitus is reported, the PCBU must review control measures and potentially implement more effective controls. [21]
SafeWork NSW similarly states that when a significant permanent threshold shift is detected or tinnitus is diagnosed, the PCBU must review noise controls, ensure hearing protectors are adequate, retrain workers on correct fit and consistent use, and consider higher order controls. [10]
A practical post-test pathway looks like this:
If the shift is suspected to be temporary, schedule a confirmatory retest after quiet conditions. [3]
If the shift is confirmed and consistent with a permanent change, provide counselling, recommend medical referral, and trigger employer WHS actions. SafeWork NSW notes workers should be referred to a doctor when permanent threshold shifts occur. [10]
If the audiogram is abnormal or inconsistent, repeat or refer, because invalid tests cannot meet their purpose. [16]
Hearing protection inspection and fit support
The NSW Code of Practice is very specific about what the PCBU should do if workers continue using hearing protectors after a shift:
Verify protector adequacy for the exposure level, examine for damage, check fit and leakage, ask the worker about difficulty, and check correct and consistent use. [11]
SafeWork NSW also provides selection guidance, including targeting an in-ear level around 80 dB(A) and using Class/SLC80 methods (linked to AS/NZS 1270 and AS/NZS 1269.3). [22]
As “noise protection testing”, hearing protector fit testing can be added as best practice. 3M describes fit testing as measuring the real-world attenuation a hearing protection device provides to a specific individual, producing a Personal Attenuation Rating, and frames it as a way to verify adequacy and improve hearing conservation outcomes. [23]
Privacy, consent, and what the employer should receive
The rule in workplace audiometry
The NSW Code of Practice provides a clear privacy standard: a worker should receive their results with written explanation, and individual results should only be provided to other parties with the worker’s consent, while de-identified results and group data can be used for WHS learning and consultation. [11]
SafeWork NSW also states that PCBUs must keep hearing test reports confidential, and employees should receive a copy of reports when employment ends. [3]
How privacy law supports this model
Under Australian privacy guidance, consent is generally needed for collecting sensitive information and for uses or disclosures beyond the original purpose; express consent must be obtained before handling sensitive information. [24] Health service providers must follow strict rules when collecting, using and disclosing health information. [25]
For audiology practices, Audiology Australia’s Professional Practice Guide embeds this in professional standards: clients have a right to privacy, practices need confidentiality and privacy policies, and they must obtain and document informed consent. [26]
A practical disclosure model for clinics
For publication on a clinic blog, The Audiology Place can state its approach plainly:
Workers receive their full audiogram and clinical explanation.
Employers receive a compliance-oriented summary showing who attended, whether testing was completed, and whether follow-up is required, with individual audiograms remaining confidential unless the worker provides informed consent for release.
This aligns with the NSW Code of Practice consent requirement. [12]
Documentation, audit readiness, and employer compliance templates
What to record to be audit-ready
SafeWork NSW expects confidential record keeping of hearing test reports, including updated baseline tests. [3] The Code of Practice frames audiometric testing as part of a broader noise management system and notes that it can be evidence of whether controls are effective. [11]
A defensible documentation pack includes:
Noise program context: evidence of noise assessment and identification of workers frequently requiring hearing protection. [27]
Testing schedule compliance: baseline within 3 months; follow-ups at least every 2 years; and any risk-based increases in frequency. [28]
For each test: test type, date/time, tester, equipment identifiers, transducer type, and whether ambient noise was verified as compliant for that setup.
Clinical validity: otoscopy findings, factors affecting reliability, and whether a retest/referral pathway was triggered. [29]
Communication: evidence that the worker received results and an explanation; and consent documentation for any release to the employer beyond compliance outcomes.[12]
Audiology Australia emphasises practice-level systems for confidentiality, privacy, documentation, and informed consent. [26]
Employer checklist for “Are we compliant in NSW?”
An employer-facing “ready reckoner” checklist can be:
We have assessed noise risk and identified roles/areas where workers must rely on hearing protection because noise exceeds the exposure standard. [30]
We provide audiometric testing to those workers within 3 months of commencing the work and at least every 2 years. [7]
We consult workers about hearing tests and reinforce that testing is to evaluate the effectiveness of controls. [31]
We keep hearing test reports confidential and provide workers copies when employment ends. [3]
If a threshold shift or tinnitus is identified, we review controls, check hearing protectors (adequacy, condition, fit, training, consistent use), and consider higher-order controls. [5]
References
[1] [2] [7] [13] [28] Work Health and Safety Regulation 2017
https://legislation.nsw.gov.au/view/html/inforce/current/sl-2017-0404
[3] [6] [8] [10] [18] [27] [30] https://www.safework.nsw.gov.au/hazards-a-z/noise-at-work/hearing-test-requirements-for-nsw-workers
https://www.safework.nsw.gov.au/hazards-a-z/noise-at-work/hearing-test-requirements-for-nsw-workers
[4] [9] [15] https://i2.saiglobal.com/mpc2v/preview/825762669310.pdf?nsai_sku=as-nzs-1269-4-2014-111832_saig_as_as_233907&sku=111832_SAIG_AS_AS_233907
[5] [11] [12] [21] [31] https://www.safework.nsw.gov.au/__data/assets/pdf_file/0017/50075/Managing-noise-and-preventing-hearing-loss-at-work-COP.pdf
[14] 140763_Infostrip.ai
https://www.biopac.com/wp-content/uploads/out101-user-guide.pdf
[16] Audiometric Testing | Worker Health & Safety | 3M Australia
[17] https://www.acoustics.asn.au/journal/2013/2013_41_3_Fisher.pdf
https://www.acoustics.asn.au/journal/2013/2013_41_3_Fisher.pdf
[19] [20] [29] https://www.safework.nsw.gov.au/__data/assets/pdf_file/0006/1196574/Hearing_test_requirements_for_NSW.pdf
[22] https://www.safework.nsw.gov.au/resource-library/hazardous-manual-tasks/hearing-personal-protective-equipment-ppe-the-facts
[23] What you need to know before purchasing a hearing protection fit test system.
[24] https://www.oaic.gov.au/privacy/your-privacy-rights/your-personal-information/consent-to-the-handling-of-personal-information
[25] https://www.oaic.gov.au/privacy/your-privacy-rights/health-information
https://www.oaic.gov.au/privacy/your-privacy-rights/health-information
[26] https://audiology.asn.au/wp-content/uploads/2023/07/AudA_Professional_Practice_Guide_2022.pdf
https://audiology.asn.au/wp-content/uploads/2023/07/AudA_Professional_Practice_Guide_2022.pdf
