The Protocol for Identifying the Functional Needs, Management and Reasonable Accommodation of Persons with Hearing Loss


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The Road to Independence Model - Protocol Principles

What all health professionals and disability rights experts should know about functional reporting:

During the employment process, a person with an impairment sometimes has to make a functional report available to the employer. This type of report provides information on, among other things, the person’s abilities and limitations and how he/she can/should be accommodated in a reasonable manner.

Unfortunately, often only a clinical/medical report is made available. However, employers cannot use this type of reporting meaningfully to grant reasonable accommodation (in line with legislation) to an employee.

The “Road to Independence Project” has developed a “Protocol & Guideline” regarding the functional needs and reasonable accommodation of a hearing-impaired or deaf adult. This process is based on the South African context, but we believe that the principles can also be applied worldwide.

The Model was developed by Fanie du Toit and the late Francis Slabber, an audiologist in private practice, who was passionate about the auditory and occupational rehabilitation of adults with hearing loss, until her untimely death in November 2021. However, the project continues as part of her legacy and in her memory by Fanie du Toit, an Adult Basic Education Practitioner and Disability Expert at the National Council of and for Persons with Disabilities (NCPD). Du Toit has more than 30 years of personal experience of hearing loss and disability.

The Protocol addresses:

  1. The degree of hearing loss experienced by the person involved.
  2. A clinical description of the loss.
  3. The Functional impact thereof on employment, social, economic, etc.
  4. Recommendations regarding hearing aids, assistive devices, technology, alternative forms of communication, human rights, accessibility to the environment, services and products in accordance with the UN Convention on the Rights of Persons with Disabilities.

This strategy was developed in collaboration with experts in the fields of audiology, hearing loss, labor relations, human rights, etc. and indicates the possible impact of hearing loss on the person concerned and the necessary support regarding reasonable accommodation within the workplace, as well as the wider society.

It can be used as a guideline in the consultation process between the following 5 role players:

  1. The individual with hearing loss
  2. This individual’s audiologist and/or ENT specialist, etc.
  3. A Disability Sector Representative – an expert on the impact of hearing loss, as prescribed in the Employment Equity Act, Code of Good Practice & Technical Assistance Guidelines, etc.
  4. A representative of the relevant institution, employer or prospective employer who is responsible for, for example, personnel matters, occupational health issues, human resources, etc.
  5. External Occupational Health Consultant (a specialist occupational therapist) as required in cases of dialogue, mediation and/or litigation.

This Model can only be used successfully if all the mentioned role players are involved. The premise is reasonableness; to provide guidance to all stakeholders on how to make decisions in terms of reasonable accommodation, as prescribed in the UN Convention on the Rights of Persons with Disabilities, SA Legislation and other applicable Codes and Guidelines.

The Protocol now forms part of a 2-hour training program namely: “Disability Rights Awareness & Functional Reporting for Dialogue and/or Mediation“. The session is accredited with the HPCSA for CPD purposes.

Inquiries can be directed to /

Information compiled by The Road to Independence

Click here for video: Protocol Guideline

Who and what decides whether someone has disabling hearing loss?

Using a fixed degree of hearing loss, for example 40dB, as the only criteria to define disabling hearing loss can deprive many persons of the opportunity to negotiate for reasonable accommodation within disability legislation.  

A hearing disability is not only about the degree of hearing loss, as some role-players do, but also about the functional impact it has on the person involved, as well as the situation in question (For example the workplace)

Role-players in the field of labour, for example, must use the content of Chapters 5 & 6 of the Technical Assistance Guidelines on the Employment of Persons with Disabilities together with a functional report in order to determine a hearing disability, and not just use the clinical description (a certain degree of hearing loss).

The prevalence of disabling hearing loss (a hearing disability) is therefore much higher than what is stated in some reports and similar statistics.

Legislation, Codes and Guidelines are clear that hearing loss that justifies reasonable accommodations like the use of assistive technology, assistive devices, as well as modifications or adjustments, is disabling.

For example:

A mild hearing loss (PTA >26dB) may be a moderate functional limitation. No matter how high tech the hearing instruments, assistive hearing devices and/or technology are, there are many factors that can hinder communication.

When an impairment is permanent and substantially limiting the individual may negotiate for reasonable accommodation under legislation. A person with a mild hearing loss (more than 26dB may negotiate for:

▪️ amplification during lectures/training (good sound system that is compatible with assistive hearing technologies)

▪️ telephone amplification

▪️ TV amplification

▪️ Favourable seating during lectures and meetings

Persons with a mild hearing loss will perform best in areas where ambient noise is controlled. (See World Report on Hearing 2021). Work assignments/tasks should be communicated in writing and will need monitoring.

Sensitisation is needed in the workplace, at home, tertiary education, churches, clubs, conferences, and so on.

Click here for access to a video regarding identifying the functional needs, reasonable accommodation of adults with hearing loss, as well as functional reporting.👇

Sources: EE Act, Technical Guidelines on the Employment of Persons with Disabilities, Code of Good Practice, White Paper on the Rights of Persons with Disabilities & Protocol for Identifying the Functional Needs and Reasonable Accommodation of deaf or hearing impaired adults).

Complied by Fanie du Toit