Comment on “ISO estimates of noise-induced hearing impairment” [J. Acoust. Soc. Am. <b>45</b>(6), 3640–3646 (2019)]

ISO/DIS 1999 document, titled "Estimation of noise-induced hearing loss" (NIHL) [ISO (2024). (International Organization for Standardization, Geneva, Switzerland)] was published in June 2024. Surprisingly, this document presents significantly higher estimates of NIHL compared to the current ISO standard [ISO (2013). (International Organization for Standardization, Geneva, Switzerland)].We found that these higher estimates are based on the publication "ISO estimates of noise-induced hearing impairment" [Lempert (2019). J. Acoust. Soc. Am. 145(6), 3640-3646]. A recalculation of the data basis used by Lempert, however, revealed methodical errors that lead to the conclusion that Lempert's assumption of an underestimation of NIHL cannot be substantiated. The significant underestimations presented by Lempert are caused by using non-compatible non-noise exposed population data.