What are your ‘Health and safety’ responsibilities?
The Health and Safety at Work Act 1974 doesn't include any disability-specific requirement for employers. But, under equality law, you have a duty to make reasonable adjustments so an employee with hearing loss isn’t put at a ‘substantial disadvantage’ compared with everyone else.
Advice for employers
There are a number of things you may want to consider for supporting employees with hearing loss. These include:
We recommend you check that staff with hearing aids can hear the fire alarm anywhere their job may require them to go.
This should be done with and without their hearing aids, because batteries can run out, plus staff may switch off their hearing aids in noisy environments.
If they can't hear the fire alarm, then consider the following alternatives:
Visual fire alarms
Make sure all private and quiet areas, such as toilets and prayer rooms, have flashing alarms to alert staff with hearing loss.
Work with your employees to identify the best place for them to sit so that they can see the alarm’s strobe. The alarm could be positioned next to their desk, slightly above it or in their general eye-line.
You'll also need to install visual alarms in meeting rooms, canteens and kitchens.
Fire marshals should be made aware of employees who have hearing loss. We recommend that they complete deaf awareness training, to ensure they’re able to communicate effectively in an emergency.
Accessible health and safety training
Any staff training must be accessible to people with hearing loss. This could include providing communication support such as British Sign Language (BSL) interpreters, lipspeakers, or speech-to-text reporters. If you're using videos, make sure they have subtitles.
Review your policies to make sure they’re adequately supporting employees with hearing loss.
Policies should be in plain English, which will be helpful to staff with hearing loss and those whose first language isn’t English.
You may also want to make some or all policies available in BSL.
Emergency evacuation plan
It's vital that your emergency evacuation plan is accessible at all times, as a member of staff who is deaf and uses BSL may want to read it when an interpreter isn’t available.
We also recommend that you include a visual plan.
In organisations where travelling outside of regular daily commuting is part of an employee’s role, you could include a travel policy.
The policy should encourage staff with hearing loss to plan their journey in advance, and leave plenty of time for unexpected delays.
Your lone-working policy should ensure that any member of staff with hearing loss can easily make contact with appropriate colleagues, for example by textphone or SMS.
Where a person with hearing loss regularly works alone in an office, you should consider providing a flashing doorbell or vibrating pager to alert the person if someone wants to enter the office.
It's standard practice for an employee to report to their line manager if they’re unwell and unable to come into work.
Your policy should make it clear that texting or emailing is acceptable so that staff with hearing loss can easily inform their manager when they can't come into work.
Thought is rarely given to how a person with hearing loss can communicate in the event of a lift breaking down.
Typically, the only way for a trapped person to communicate is by the intercom. Consider installing alternative methods, such as SMS or a wall-mounted textphone. If this isn't possible, display instructions so the trapped person knows what to do and how long they may be waiting.
You should then amend your procedures to make sure that you respond to all alarm calls, by all methods and regardless of whether communication has been made.
To find out more about employing people with hearing loss see: