Risk Assessments for Employees who are Deaf or have Hearing Loss

Tackling physical barriers with practical, inclusive solutions for safer workplaces.

• By Dan Morgan-Williams
• Oct 15, 2025

The core of U.S. employee health and safety law is the Occupational Safety and Health (OSH) Act of 1970, enforced by the Occupational Safety and Health Administration (OSHA). The fundamental rule is the "General Duty Clause," which requires employers to provide a workplace free from recognized hazards that are likely to cause death or serious physical harm.  

Key employer requirements include:  

1. Providing a safe workplace: Employers must adhere to specific OSHA safety standards and furnish necessary personal protective equipment (PPE). 
2. Training and communication: Employers must train employees in safety procedures and hazardous materials, like chemicals, in a language they understand. 
3. Reporting and record-keeping: Work-related fatalities and severe injuries must be reported to OSHA within specified timeframes. Employers must also maintain and post logs of all work-related injuries and illnesses. 
4. Non-retaliation: Employers are forbidden from retaliating against employees who file complaints or report safety issues. 
5. Inspections: Employers must allow OSHA officers to conduct workplace inspections.  
6. Additionally, some states have their own OSHA-approved programs, which must meet or exceed federal standards. Other federal laws, such as the Fair Labor Standards Act and the Americans with Disabilities Act, also contain provisions that affect employee well-being. Non-compliance can result in fines and penalties.  

Generic risk assessments often fail to identify the additional hazards that an employee who is Deaf or has hearing loss may face, particularly in environments or job roles that involve navigation, movement, or visual cues. 

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 

Office Environments: Hidden Risks for Hearing Loss 

Offices might appear low risk, but for someone who is Deaf or has hearing loss, they can present unique safety and communication challenges.  

Common barriers: 

• Audio-only announcements (e.g., fire alarms without flashing lights) can go unnoticed. 
• Verbal-only briefings or meeting discussions may be missed if there’s no interpreter, captioning, or transcript. 
• Poor lighting or awkward seating layouts can make lipreading or visual cues difficult. 
• Sudden changes in procedure (e.g., last-minute meeting relocations) may not be effectively communicated without visual notification systems. 
• Telephone-only systems without text or video relay options can block access to critical information. 
• Equipment such as printers or intercoms may use beeps or spoken prompts without visual indicators. 

Practical solutions: 

• 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. 

Outdoor and Field-Based Roles 

In outdoor or high-noise work environments, relying on spoken communication can pose serious safety risks. 

Barriers: 

• Verbal instructions or safety warnings may be inaudible in windy, noisy, or wide-open environments. 
• Radio-only communication excludes workers who rely on visual cues. 
• Emergency instructions shouted over a distance may not be heard. 

Solutions: 

• Agree on standardized 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. 

Inclusive Risk Management for Hearing Loss 

Risk assessments for employees who are Deaf or have hearing loss are not about singling people out — they’re about ensuring equal safety and opportunity. Most barriers 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. 

By taking a proactive, person-centered approach, you meet legal obligations, protect well-being, and create a workplace where everyone, regardless of hearing ability, can thrive. To find out more, visit https://visualisetrainingandconsultancy.com/workplace-assessments/hearing-loss-workplace-assessment/. 

This article originally appeared in the October 2025 issue of Occupational Health & Safety.