The Aging Workforce and Noise Exposures
Employers must adapt hearing conservation programs to protect workers who wear hearing aids or have diminished hearing.
- By Gregory Boothe
- Nov 20, 2025
By most measures, the U.S. workforce is aging. A report from the Pew Research Group shows since the end of the COVID-19 pandemic, the number of workers over the age of 65 has almost quadrupled to approximately 11 million workers.
This equates to approximately 19 percent of all workers in the U.S. being 65+ years of age. In fact, the age group 75+ years is the fastest growing age group in the workforce. At the same time, the percentage of workers between 25 and 65 has decreased. Workforce changes such as these can result in difficult decisions for management in many areas of safety and health.
One area where difficulties arise involves noise and Occupational Safety and Health Administration regulations on noise control. The National Council on Aging recently estimated that 31 percent of individuals aged 65 and over suffer from some form of hearing loss. With an estimated 11 million workers in this category, that would equate to more than 3.4 million workers over the age of 65 with some form of hearing loss.
Protecting workers’ hearing
OSHA’s occupational noise standard, 29 CFR 1910.95 requires employers to provide feasible administrative or engineering controls when noise exposures exceed specific sound levels. Controls must reduce the noise exposure to the identified levels or to less than 85 dBA for workers who have been identified with a Standard Threshold Shift (STS).
When there are no feasible controls to reduce noise exposure levels, workers must be required to wear personal protective equipment. Difficulties arise when employees have hearing loss and are wearing hearing aids. Additional difficulties may arise when employees are present who have been diagnosed as being deaf. How do the regulations apply to these groups?
OSHA has responded to letters from industries stating that the occupational noise standard applies to all employees, including those with diminished hearing capacity and those who have been diagnosed as being deaf.4 But how does an employer apply the regulations to these groups?
Most employers provide hearing protection to workers in the form of ear plugs. Ear plugs are small and unobtrusive, easy to use and less costly than other forms of hearing protection; however, ear plugs can’t typically be worn by individuals who are already wearing hearing aids. One common misconception is that individuals with hearing loss who are wearing hearing aids do not have to be furnished with hearing protection.
First, some believe that since the individual already suffers from hearing loss, the sound levels at the inner ear are already reduced to less than 85 dBA. This reasoning is also sometimes applied to individuals who have been diagnosed as being deaf.
The second reasoning is that individuals who are wearing hearing aids can simply turn them off or remove them when entering an area with elevated noise levels and turn them back on or reinsert than upon leaving the area with elevated noise levels. Both approaches assume that the individual already has hearing loss so it can’t be any worse with additional noise exposures.
Some employers will also have their workers with hearing aids remove them in the work areas with higher noise levels and wear the same ear plugs as other workers in the area. This approach assumes that it is adequate to just provide hearing protection that reduces the exposure to an adequate level for individuals with hearing aids.
Hearing aids are not protection
Let’s look at each of these scenarios. OSHA has stated that employers can’t satisfy the requirements of the occupational noise hazard by simply having the employee remove or turn off their hearing aids even if they are left in the employees’ ears. OSHA’s reasoning for that decision is that hearing aids are not designed to be hearing protection devices.
To be considered as adequate hearing protection devices, the hearing protectors must be tested and assigned a noise reduction rating (NRR) using the laboratory methods published by the Environmental Protection Agency. The NRR is used to determine if the hearing devices reduce the noise levels to which the employee is exposed to less than the identified or 85 dBA for employees with an STS.
Since very few manufacturers test their hearing aids to determine NRR values, there is no way to determine if a hearing aid that has been turned off will reduce noise exposures to an applicable level. Another problem is that employees must be able to hear emergency notification systems and sometimes machine noises on their job. Removing or turning off hearing aids can diminish the employees’ ability to work safely in some work environments.
What is the best approach for controlling noise exposures for workers who are wearing hearing aids? Using the hierarchy of controls, the best approach is to move these employees to jobs where noise levels are below 85 dBA continuously, although this may not be feasible in many work situations. As we have already seen, the occupational noise standard requires the employer to provide personal protection for workers that reduces noise levels.
The most effective method to provide the required protection for workers with hearing aids is to provide the employee with earmuffs instead of ear plugs. The employer will still have to determine if the earmuffs can reduce the noise exposures to adequate levels by using the NRR for the earmuffs that are chosen.
There are some instances where noise levels are so high that double protection (ear plugs and earmuffs) are required to reduce noise exposures to an acceptable level. In those cases, workers with hearing aids would likely be excluded from those work areas because they can’t use double hearing protection.
Employers should include provisions in their hearing conservation program to address the hearing protection needs of workers who are wearing hearing aids and those that have been diagnosed as being deaf. However, the efforts to accommodate these workers can be offset by the increased experience in the job leading to increases in productivity.
References :
- https://tinyurl.com/2s4m2kaf
- https://tinyurl.com/3udh7shn
- https://tinyurl.com/yc7nb5k6
- https://tinyurl.com/2wz82d8z
This article originally appeared in the November/December 2025 issue of Occupational Health & Safety.