Risk assessments for employees who are deaf or have hearing loss may not always be straightforward. But, writes Dan Morgan-Williams, they are definitely not about singling people out. Rather, they are about ensuring equal safety and opportunity.
As HR professionals will well know, under UK law employers have a duty to ensure all employees are safe at work. This includes compliance with reasonable adjustments in the Equality Act 2010, the Health and Safety at Work Act 1974, and the Management of Health and Safety at Work Regulations 1999, among other regulations.
A key element within this is, of course, risk assessment. Generic risk assessments, however, can fail to identify the additional hazards that an employee who is deaf or has hearing loss may face.
This is particularly the case in environments or job roles that involve navigation, movement, or visual cues. What, therefore, should a risk assessment in this context encompass?
Broadly, risk assessments tailored to hearing loss should consider:
- Lighting levels and visibility of visual alerts
- Layout and navigation to support clear visual communication
- Access to equipment and controls that don’t rely solely on audio cues
- Communication methods and accessible signage
- Task-specific hazards where hearing is usually relied upon
- Access to assistive listening technology or visual alert systems.
It is also important, however, to consider the hidden risks for hearing loss contained within your average office environment.
Offices might appear low risk when it comes to health and safety but, for someone who is deaf or has hearing loss, they can present unique safety and communication challenges. Common barriers can include:
- Audio-only announcements (for example, fire alarms without flashing lights) that can go unnoticed
- Verbal-only briefings or meeting discussions, which may be missed if there s no interpreter, captioning, or transcript
- Poor lighting or awkward seating layouts, which can make lipreading or visual cues difficult
- Sudden changes in procedure (for example, last-minute meeting relocations), which may not be effectively communicated without visual notification systems
- Telephone-only systems without text or video relay options, which can block access to critical information
- Equipment such as printers or intercoms, which may use beeps or spoken prompts without visual indicators.
What, then, are the sort of practical solutions you can put in place to mitigate these risks? I’d suggest the following:
- Install visual alarms (flashing beacons) for fire and emergency alerts
- Provide real-time captioning, transcripts, or sign language interpreting for meetings
- Arrange seating and lighting to support lipreading and clear visual communication
- Use email, instant messaging, or visual display boards for last-minute updates
- Offer text relay, video relay, or instant messaging options instead of phone-only communication
- Select equipment with visual indicators, text displays, or vibration alerts.
As well as the indoor office environment, in outdoor or high-noise work environments, relying on spoken communication can pose serious safety risks. These can include:
- Verbal instructions or safety warnings that may be inaudible in windy, noisy, or wide-open environments
- Radio-only communication that excludes workers who rely on visual cues
- Emergency instructions that are shouted over a distance and which, therefore, may not be heard.
Solutions in this context can be relatively straightforward and include:
- Agree on standardised hand signals or gesture-based safety commands
- Use written or pictorial instructions before tasks begin
- Implement high-visibility visual alarms, flashing lights, or coloured flags for urgent alerts
- Establish a buddy system for high-risk or fast-changing environments
- Provide waterproof or rugged wearable devices with vibration or flashing alerts for emergencies.
How to make risk management inclusive for hearing loss
In summary, most barriers, as we have seen, can be solved with simple, low-cost adjustments that benefit the whole workforce. In rare cases, specific environments or roles may carry unresolvable risks. When this happens, employers should work with the employee and occupational health professionals to explore alternative tasks or work patterns.
Ultimately, by taking a proactive, person-centred approach, you meet legal obligations, protect wellbeing, and create a workplace where everyone, regardless of hearing ability, can thrive.
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