Labour hire and hearing testing: who is responsible?

When a worker is placed into a noisy environment through a labour hire arrangement, both the agency and the host employer carry obligations — but the agency is almost always the one who needs to organise and fund the testing. Here's how the split works.

The labour hire agency's obligations

As the worker's employer of record, the labour hire agency is responsible for:

• Ensuring workers receive a baseline hearing test within 3 months of being placed in a noisy role
• Maintaining records of each worker's hearing tests across all placements
• Arranging monitoring tests every 2 years for workers in ongoing noisy placements
• Following up if a worker shows a change in hearing

The host employer's obligations

As the business running the worksite, the host employer is responsible for:

• Informing the labour hire agency about the noise exposure levels in the relevant roles
• Ensuring the workplace has appropriate noise controls in place
• Providing hearing protection as required PPE

What happens in practice

In most arrangements, the agency takes responsibility for organising and funding the hearing testing program, since they hold the employment relationship with the worker. The host employer provides information about noise levels and cooperates with scheduling.

The practical approach: treat hearing testing as a standard part of onboarding into any noisy placement — the same way you'd handle induction paperwork. Before a worker starts at a noisy client site, confirm their baseline test is booked for the same week as their induction. A monitoring register then tracks when each worker's next test is due.

What happens to records when a worker moves between placements?

Records stay with the agency. A baseline test conducted for one placement remains valid and relevant for future placements — you don't need a new baseline every time a worker moves to a different client site. What matters is that the baseline exists and that monitoring tests are conducted every 2 years from that point, regardless of which site the worker is at.

This is one of the key advantages of a structured agency-level program: one set of records follows the worker, rather than each host employer starting from scratch.

Where confusion most often occurs

Problems arise when agencies assume the host employer is handling testing, and host employers assume the agency has it covered. The result is workers in noisy roles with no record at all. Under Clause 58, the obligation is clear: the agency must confirm testing has occurred, not assume it.