Protection Without Prevention

Examining the Hidden Cost of New Zealand’s No-Fault ACC System for Noise-Induced Hearing Loss

Abstract

New Zealand’s no-fault Accident Compensation Corporation (ACC) provides universal support for workers affected by occupational noise-induced hearing loss (NIHL), yet questions remain about its effectiveness in driving prevention. This article examines how ACC’s levy structure, gradual process injury cover, and the Accredited Employer Programme (AEP) influence employer incentives and organisational approaches to preventing NIHL. Drawing on analysis of legislation, national ACC claims datasets, and peer-reviewed literature, the article shows that while regulatory frameworks are well established, prevention efforts often default to minimum compliance, with claim trends indicating limited prioritisation of engineering controls. The absence of direct economic consequence for chronic exposure failures weakens accountability and allows preventable harm to persist. By contrast, fault-based or experience-rated systems used in Australia and the United Kingdom are associated with stronger financial incentives for prevention, further highlighting how New Zealand’s approach detaches prevention from financial responsibility. Strengthening prevention metrics and accountability within levy structures and audit systems is essential if New Zealand is to move beyond symptom management and address the root causes of NIHL.