Introduction
From November 10, 2025, to January 30, 2026, the Workplace Safety and Insurance Board (WSIB) asked for feedback on the proposed update to the policy on Noise-Induced Hearing Loss, On/After January 2, 1990 (16-01-04).
Thank you to everyone who submitted feedback on the draft policy. We carefully reviewed and considered all feedback to help revise the policy. This report includes background on the policy, an overview of the consultation process, a summary of the key themes that we heard from stakeholders and our responses.
Background
In the 2025 policy agenda, we shared our plan to consult on the noise-induced hearing loss (NIHL) policy. The proposed updates reflect changes in the evidence and modernize our approach to decision-making in NIHL and NIHL-related tinnitus claims. The WSIB has a long history of adjudicating these claims. We accepted the first claim for “industrial noise deafness” and recognized NIHL as an occupational disease in 1947.
The initial entitlement guidelines in our policy on Noise-Induced Hearing Loss, On/After January 2, 1990 (16-01-04) have not changed since 1992. After more than 30 years, the policy needs updating to improve transparency and consistency in decision-making, better align with legislative and regulatory requirements, and modernize administrative practices.
As part of this update, and with support from the WSIB’s Scientific Advisory Table on Occupational Disease, we updated the policy to reflect the latest scientific evidence on how occupational NIHL progresses, especially in relation to age-related hearing loss. These updates will improve the policy’s design and content and support consistent and timely initial entitlement decisions in NIHL and NIHL-related tinnitus claims. They will also help people with claims, businesses and others better understand how we make decisions.
About the consultation
Recognizing the important role that stakeholders play in the development of effective and responsive policies, we asked for feedback on the draft policy on our website.
During the consultation, we received . This included input from health care providers and professionals, employer representatives, representatives of people with claims, and health and safety system partners. We reviewed each submission and identified approximately 300 distinct comments. We shared feedback that was outside the scope of the policy with the appropriate areas of the WSIB.
The extensive feedback we received and the changes we made in response, show both the importance of the policy and our commitment to addressing concerns and recommendations.
The submissions are posted in the format we received them. If you need them in another format, please contact the [email protected].
Summary of findings
Given the large volume and range of comments, this report focuses on key recurring themes. People generally welcomed the revisions and updates to the policy. However, finding common ground between employer representatives, groups representing people with claims, health care providers while meeting the WSIB’s legislative and broader policy requirements presented challenges, especially regarding entitlement thresholds. The revisions made to the policy reflect feedback from all groups.
Key themes we heard during the consultation:
- The 26.25 decibels (dB) occupational NIHL threshold should be reduced
- The 500 hertz (Hz), 1000 Hz, 2000 Hz, and 3000 Hz frequencies used to determine average hearing loss for occupational NIHL are inappropriate
- The noise exposure threshold (NET) of 90 A-weighted decibel (dBA) for five years (or equivalent) is too high
- Additional guidance on how we consider non-occupational factors and exceptional cases
Other relevant themes:
- Clarify the roles of regulated health care professionals, such as audiologists, and non-regulated health care providers, such as hearing instrument specialists
- For tinnitus, the two-year requirement for non-economic loss benefits should be shortened
- For tinnitus, specify that the two-year requirement must be dated and documented and clarify that health care benefits are available once entitlement is established
Detailed findings and responses
The 26.25 dB occupational NIHL threshold should be reduced
What we heard:
Health care providers and representatives of people with claims recommended maintaining the current threshold of 22.5 dB or lowering it to 20 dB to align with the World Health Organization’s (WHO) definition of “mild hearing loss.” Alternatively, some stakeholders recommended a lower threshold for hearing aids and a higher threshold for entitlement to a non-economic loss benefit.
Our response:
Most people with average hearing loss of 25 dB or below experience minimal difficulty hearing conversational speech. The World Report on Hearing (2021) reports that despite the functional limitations associated with hearing loss, adults typically wait as much as nine or 10 years before seeking any hearing care1. WSIB claims data shows that people wait to submit claims for occupational NIHL until they have profound hearing loss, often long after they have left the workplace.
We reviewed the WHO’s rationale for changing the definition of mild hearing loss, which was to standardize how hearing loss severity is reported and make it easier to compare with other disabilities or degrees of disability. The WHO also sought to recognize hearing impairment in children at lower levels (i.e., 20 dB) to assist in their broader goals of making ear and hearing care a global public health priority across the life course.
The WHO reviewed studies that reported severity of hearing loss was one of the strongest predictors of hearing aid uptake and that >35 dB (moderate or worse hearing impairment) was the level at which intervention is beneficial. A 2017 Cochrane Review also concluded that hearing aids improve participation, overall health-related quality of life and listening ability in adults with hearing loss of 26 dB or greater2.
An average hearing loss of 26.25 dB is the lowest level at which hearing loss can be rated as a permanent impairment in the American Medical Association Guides to the Evaluation of Permanent Impairment, Third Edition (Revised) (AMA Guides). The change to 26.25 dB hearing loss is needed given the removal of the presbycusis factor.
The WSIB’s view is that the 26.25 dB threshold remains appropriate and should not be reduced.
The 500 Hz, 1000 Hz, 2000 Hz, and 3000 Hz frequencies used to determine average hearing loss for occupational NIHL are inappropriate
What we heard:
Health care providers and representatives of people with claims expressed concerns about maintaining the audiogram frequencies used to determine a person’s average hearing loss. These respondents recommended removing the lower frequency (500 Hz) and including a higher frequency (4000 Hz) to more accurately identify NIHL.
Our response:
The frequencies the WSIB uses to determine average hearing loss for NIHL align with the AMA Guides, which we must use when determining a permanent impairment.
While determining hearing loss for entitlement to benefits is distinct from assessing permanent impairment, adopting two separate sets of frequencies (one set for entitlement to health care and a different set to rate the permanent impairment) would result in two different noise calculations, making claims administration more complex and impractical.
Although we are required to use the third edition of the AMA Guides, the same frequencies continue to be used in the most recent sixth edition. Most Canadian workers’ compensation boards also use these frequencies.
Our view is that the 500 Hz, 1000 Hz, 2000 Hz, and 3000 Hz frequencies remain appropriate and should not be changed.
The noise exposure threshold of 90 dBA for five years (or equivalent) is too high
What we heard:
Groups representing people with claims argued that the noise exposure threshold in the draft policy, which is maintained from the current policy, does not align with the noise exposure limits set out in the Occupational Health and Safety Act (OHSA). They recommended lowering the noise exposure threshold to align with both the OHSA and other workers’ compensation boards in Canada.
Our response:
The draft policy’s noise exposure threshold (90 dBA for five years) and the OHSA noise exposure limit (85 dBA for eight hours a day) serve different purposes. The OHSA limit is a prevention measure designed to protect people from harmful workplace noise exposures. In contrast, the noise exposure threshold in the policy is an entitlement threshold that helps determine whether a person’s employment, on a balance of probabilities, significantly contributed to their NIHL. This threshold is the standard of proof used in adjudicating almost all injuries.
The “balance of probabilities” is the relative weight of the evidence used to establish one side or another and is the standard of proof used to adjudicate workplace injury claims. In practice, this means that, when determining whether a person’s NIHL was caused by their employment, adjudicators consider noise exposure evidence that makes it probable, rather than merely possible, that their employment significantly contributed to their NIHL. Exposure to 90 dBA for eight hours a day for five years is sufficient evidence to establish that it is probable that a person’s employment significantly contributed to their NIHL.
While some Canadian workers’ compensation boards use a noise exposure threshold of 85 dBA for two years, that standard merely suggests that occupational NIHL is possible, not that it is probable.
We recognize, however, that there may be circumstances where a person’s exposure to noise at work significantly contributed to their NIHL even though the noise exposure threshold has not been met. To account for these unique situations, the policy includes guidance indicating that these claims will still be considered on a case-by-case basis, taking into account relevant factors such as individual susceptibility to NIHL or exposure to chemicals known to cause hearing loss.
Adopting the lower threshold would also likely increase denied claims and reconsiderations because many claims would still not meet the 26.25 dB hearing loss requirement.
Our view is that the noise exposure threshold (90 dBA for five years) remains appropriate and should not be changed.
Additional guidance on how we consider non-occupational factors and exceptional cases
What we heard:
Both representatives of people with claims and employer stakeholders commented that the policy should address non-occupational factors for NIHL. Representatives of people with claims argued that non-occupational factors should not prevent entitlement where the noise exposure threshold has been met, whereas employer stakeholders requested additional information on how we will account for non-occupational factors.
Our response:
Entitlement to benefits may be allowed when a decision-maker determines that a person's employment, more likely than not, significantly contributed to their NIHL. The policy is clear that employment can significantly contribute to their NIHL even when workplace noise is not the largest or main source of their noise exposure. In most cases, entitlement will be allowed when the evidentiary requirements in the policy are met.
However, there are exceptional cases where a decision-maker may determine that, despite meeting the evidentiary requirements in the policy, a person’s exposure to noise at work did not significantly contribute to their NIHL. These rare instances are limited to scenarios where the person’s exposure to noise at work just met the noise exposure threshold, their hearing assessment was conducted a considerable number of years after they left the noisy work environment, and there is evidence of other non-occupational contributors to the hearing loss. In these cases, decision-makers will review claims on a case-by-case basis and assess entitlement to benefits based on the individual facts and circumstances of each claim.
Based on the feedback, we added clarity to the policy to address these issues.
Clarify the scopes of practice between regulated health professionals and non-regulated healthcare providers
What we heard:
Health care stakeholders recommended revising the language throughout the policy to ensure consistent references to regulated health care professionals (e.g., Audiologists) and non-regulated health care providers (e.g., hearing instrument practitioners) based on the scope of practice of each profession.
Our response:
As part of the policy review, we examined the legislative and regulatory framework for regulated health professionals to ensure alignment with provincial legal requirements. We also identified an opportunity to remove ambiguity between the roles of regulated health professionals and non-regulated health care providers.
Based on feedback, the policy has been updated to ensure that the roles of audiologists, physicians (including otolaryngologists), and hearing instrument practitioners (as they relate to providing hearing services under the policy) are clear and align with the provincial regulatory landscape. For example, the policy now clearly identifies that hearing instrument practitioners and audiologists can both complete hearing assessments.
Based on the feedback, we revised the policy to more clearly distinguish between the roles of regulated health care professionals and non-regulated health care providers.
For tinnitus, the two-year requirement for non-economic loss benefits should be shortened
What we heard:
Representatives of people with claims raised concerns about the two-year period and suggested that entitlement to a permanent impairment for NIHL tinnitus be available after six months.
Our response:
People with permanent impairments resulting from work-related injuries or illnesses are entitled to a non-economic loss benefit. To determine that a permanent impairment exists, decision-makers must confirm that the person has reached maximum medical recovery. This means that the person’s recovery has plateaued and it is unlikely that there will be any further significant improvement in the work-related injury or illness. This approach is consistent with our policy on determining permanent impairment. For more information, see our policy on Determining Permanent Impairment (11-01-05).
Evidence indicates that, for many people, tinnitus naturally improves over time and becomes less problematic and intrusive. Research shows a moderate degree of spontaneous improvement, and a sizeable percentage of patients appear to get used to their symptoms over a prolonged period. For example, the first evidence-based clinical guideline by the American Academy of Otolaryngology-Head and Neck Surgery (AAO-HNS) reviewed a study where patients with significant tinnitus improved after five years, with a subset of patients reporting complete resolution and the remainder reporting only mild symptoms. In another study, 20 per cent of patients who reported tinnitus at the outset of the study had spontaneous improvement after five years.
Given this evidence, our view is that the two-year period is a reasonable, fair, and appropriate compromise to monitor the persistence of tinnitus before a decision-maker can determine that maximum medical recovery has been reached and assign a permanent impairment rating.
For tinnitus, specify that the two-year requirement for non-economic loss benefits must be dated and documented and clarify that health care benefits are available once entitlement is established
What we heard:
Employer stakeholders suggested adding details about documenting tinnitus symptoms during the two-year period and clarifying that health care is available immediately after entitlement to help manage symptoms and potentially reduce the severity of any permanent impairment.
Our response:
Based on the feedback, we modified the policy to specify that an audiologist or another qualified regulated health professional must provide dated and documented health care information to support this two-year period. The information must describe the extent of the ongoing tinnitus and demonstrate continuity for a minimum of two years.
Although there is a two-year period before permanent impairment can be determined, we revised the policy to state that health care benefits are immediately available upon entitlement.
Updated: