Which NSW workers need audiometric testing, and when?

An NSW PCBU must arrange and pay for audiometric testing when it frequently requires a worker to use hearing protection to control noise that exceeds the exposure standard. Under SafeWork NSW's current hearing-test requirements, a new affected worker needs a baseline test within three months of starting employment and a follow-up at least every two years. The final stage of the rollout applied from 1 January 2026, when existing affected workers had to be covered. The test is a health-surveillance measure; it is not permission to leave excessive noise uncontrolled.

This is a New South Wales employer guide. It does not assume the same start dates or exemptions in every Australian jurisdiction. The current NSW WHS Regulation 2025 and SafeWork guidance should be checked for a real workplace. The verified Complys AU training-tracking page describes training and certificate records, not audiometric testing or clinical interpretation. This article explains the legal task, and the product link is only a potential record-management connection after implementation checks.

What triggers the testing duty?

The trigger is a combination of noise exposure above the standard and frequent use of hearing-protection PPE required as a control. It is not enough to ask whether workers happen to own earmuffs or whether a workplace is generally loud. Assess the actual tasks and noise exposure, who is required to wear protection, and whether use is frequent. SafeWork NSW's employer information is the primary starting point.

SafeWork NSW's 2025 information sheet identifies the current NSW noise exposure standard as 85 dB(A) averaged over eight hours or a 140 dB(C) peak. A single spot reading, especially one made far from the ear or during an atypically quiet period, may not establish the worker's exposure. Use competent noise assessment and the current regulation where classification is uncertain. Some activities may need controls even when a particular audiometric-testing trigger is not met.

The duty reaches manufacturing, construction, logistics and other sectors when their actual conditions meet the test. A role title is not decisive. A mechanic who only occasionally walks through a noisy area may differ from a machine operator required to wear hearing protection throughout each shift. Conversely, a site with intermittent but very high peak exposures may need urgent noise controls even before the employer settles the audiometry schedule.

Example: two crews in one workshop

A fabrication workshop has a cutting crew that uses hearing protection throughout daily cutting and a packaging crew that only enters the cutting bay briefly on rare occasions. The PCBU should assess each crew's actual exposure and PPE requirements rather than booking identical tests solely because both work at the same address. If the cutting crew meets the NSW trigger, schedule employer-funded baseline and repeat tests. The packaging crew still needs protection from hazardous noise as appropriate; the employer should not infer that no audiometry duty means the area is safe.

Baseline and repeat timing

For a newly affected employee, SafeWork NSW says the baseline test must be completed within three months of starting employment, and ideally before exposure to hazardous noise so it provides a useful reference. At least every two years, arrange a monitoring test during employment. A high-exposure situation may call for more frequent testing under professional or regulator guidance. Do not turn the two-year minimum into a reason to ignore a sudden hearing concern.

SafeWork NSW describes staged commencement: clause 58 was approved for commencement from 2024, and the final phase applied from 1 January 2026, including workers employed before January 2024 who had to be tested by then. For publication in October 2026, present those dates as historical rollout context, not a future grace period. A PCBU that has not met the applicable requirement should arrange current compliance promptly and seek specialist advice about any gap rather than writing an inaccurate backdated test record.

Maintain a schedule keyed to the worker's actual baseline date and next due date. Changes of role, noise exposure, employment or medical advice may require reassessment. Labour-hire arrangements need clear coordination: SafeWork's labour-hire FAQ says the labour-hire PCBU has the section 58 duty to organise and pay for audiometry, while both labour-hire and host PCBUs have safety duties. The host should not assume the agency has acted without confirmation, and the agency needs real exposure information from the host.

Who performs the test, and who pays?

The PCBU must organise and pay for testing. SafeWork NSW says a competent person, such as an appropriately trained audiologist, should conduct and interpret it using the prescribed procedures. A doctor referral is not normally required just to book the hearing test. The PCBU should use a competent provider and give them the exposure and previous-test context needed for an accurate comparison.

Do not substitute a casual online hearing quiz or a quick informal tone check. A baseline and follow-up need to be comparable and properly interpreted. The SafeWork NSW page explains pure-tone audiometry, temporary and permanent threshold shifts, and the appropriate re-test where a temporary shift is suspected. Clinical diagnosis and medical referral belong to the competent practitioner, not a compliance administrator.

A relevant coal-mining exemption took effect 1 January 2026 and is scheduled through December 2031 under stated conditions tied to Coal Services Order No. 45. It does not mean coal workers need no hearing assessment. Verify the precise employer and condition before applying it. Do not generalise the exemption to mining, quarrying or construction businesses that are outside its scope.

What should happen after a result changes?

The worker should receive an explanation of the test result from the competent provider. If a significant or temporary threshold shift is identified, follow the provider's and SafeWork NSW's guidance on re-testing, medical referral and a review of the workplace controls. The regulator notes that a temporary shift may call for a test after a quiet period; a permanent shift calls for medical assessment. An employer should not diagnose the cause from a spreadsheet trend alone.

Review the workplace: noise source, equipment condition, enclosure, maintenance, isolation, task duration and hearing-protection selection, fit and consistent use. SafeWork NSW's noise-management page sets out the identify-assess-control-review process. If several workers show deterioration, examine whether a shared hazard or failed control is present. Even one result may warrant prompt investigation of that person's tasks and exposure.

Use higher-order controls where reasonably practicable. Quieter plant, engineering enclosure, damping or better work design may reduce exposure more reliably than relying solely on PPE. Audiometry tells the business whether harm may be occurring; it does not reduce the noise itself. Provide training on correct hearing-protector use, but do not treat that as the only response to an excessive exposure.

Records, privacy and scheduling

Keep the risk assessment or noise-exposure basis for identifying affected workers, appointments, completed-test dates, provider details, next due dates, worker communication and the actions taken after concerning findings. Protect medical information with appropriate access controls and applicable privacy rules. An operational dashboard may only need to show that a test is due, completed or requires follow-up; it should not expose an audiogram to every site supervisor.

Confirm the specific NSW retention and disclosure requirements for audiometric results against current law and provider guidance. Do not invent a universal retention period from another medical-surveillance scheme. Employers also need a way to know when a new worker enters a frequently protected noisy task, changes role or returns from a period away. A static induction list alone will miss these changes.

The live Complys AU induction and training-tracking page confirms that it tracks WHS training records, certificates and due-date reminders. It does not establish a dedicated audiometry module, clinical result storage, automatic legal trigger calculation or booking integration. If the current implementation can hold a restricted completion document and reminder, that may help the administrative schedule, but verify permissions and product reality first. The PCBU remains responsible for provider selection, test cost, exposure control and any medical response.

A workable NSW implementation sequence

1. Assess noise: identify jobs where exposure may exceed the standard, using competent measurement where needed.
2. Identify workers: determine who is frequently required to use hearing protection as a control for that noise.
3. Coordinate duty holders: clarify host and labour-hire responsibilities and any narrowly applicable exemption.
4. Book baseline tests: for newly affected workers, complete within the current three-month rule and ideally before exposure.
5. Schedule follow-ups: set at least a two-year cycle and any shorter interval recommended for the actual exposure.
6. Use competent testers: obtain results and interpretation through the proper provider.
7. Respond to findings: arrange re-test or medical referral where indicated and investigate workplace controls.
8. Keep controlled records: store dates and actions with appropriate privacy safeguards and review the worker list as jobs change.

Common mistakes

• Assuming audiometry is required for everyone who sometimes wears earmuffs. Apply the actual frequent-use and noise-exposure test.
• Assuming PPE removes the obligation to reduce noise. Source and engineering controls remain important.
• Treating January 2026 as a future grace period. The final rollout date has passed.
• Counting from the wrong date. Track the affected new worker's baseline and follow-up schedule.
• Using an informal hearing check as statutory audiometry. Competence and procedure matter.
• Ignoring labour-hire coordination. Both duty holders need the exposure and test arrangement to be clear.
• Publishing clinical data in a general training register. Limit access to personal results.
• Assuming an app performs a hearing test or diagnoses loss. It can only support verified administrative records.

Next step

Review the actual noisy tasks and hearing-protection requirements, create a list of affected NSW workers, and book overdue or upcoming audiometry with a competent provider. Use SafeWork NSW's current hearing-test page for timing and the live regulation for legal interpretation. If administrative dates are hard to track, assess whether verified Complys training tracking can hold the required non-clinical evidence and reminders under suitable access controls.

For the related Complys product, see Induction Training Tracking Software. This guide is general information, not legal advice; verify current requirements against the official sources linked above.