Solicitor Peter Lodge, who specialises in occupational disease work and is acting for the car workers, said: "The Halewood plant has been hit by a large number of cases over the years where the employees have been exposed to the noise that came from the presses, trip hammers and a variety of air tools that were used during the assembly process.

"It is generally accepted that there was little or no hearing protection at the plant until the late 1980s and, in some areas, not until the late 1990s, although employees within the press shop did have some protection prior to that time.

"Although the plant was owned by Ford for a number of years, all of the cases are directed towards Jaguar, which now owns the plant and, as a result, inherits all of the old liabilities for that company."

Mr Lodge, from law firm BPE, has been pursuing deafness cases for the past 15 years, and added: "There is a duty on any employer to provide a safe system of work and safe place of work, and therefore, in the context of noise exposure, the onus is on the employer to provide hearing protection where the noise levels exceed 85/90 decibels and to ensure that regular noise surveys are carried out.

"Although in the majority of cases, protection is now available, this is of no real benefit to long-serving employees where they have had substantial exposure during their early years at work."

BPE has a total of 75 deafness claims against Jaguar.

The first deafness case was brought to court in 1963 when a Ford car worker sued the car manufacturer for hearing loss. It was established in that case that prolonged exposure to excessive noise was dangerous.

Mr Lodge said: "The cases are fairly difficult to defend from an insurance point of view as hearing protection was not compulsory in many of the larger plants until the 1980s or even the 1990s, some 20 years too late."

The usual symptoms are problems in group conversations and sometimes even conversing on a one-to-one basis can be difficult, particularly if there is any background noise.

Tinnitus, which is a hissing, buzzing, whistling or ringing in the ears, can also occur.

Mr Lodge said: "The valuation of these claims varies significantly as it depends on a number of factors, such as age, level of hearing loss and tinnitus."

A spokesperson for the Transport & General Workers Union said: "Hearing loss problems are sadly a long-term feature from the car industry, and it is right that the unions back members who have suffered. We are making significant progress in resolving claims with a number of car industry employers, including working with our solicitors for the Halewood factories."

A spokesperson for the Jaguar Halewood plant said: "We do not comment on individual cases."

I was advised about protection after 28 years at factory.

KEITH KEHOE recently settled a claim with Jaguar, receiving £6,000 for general hearing loss.

Mr Kehoe, of Runcorn, worked at the Halewood factory for 29 years. He took voluntary redundancy three years ago and now works part-time as a motor racing marshal.

The 54-year-old said: "About five years ago, when I was still working there, I noticed that if someone was talking who wasn't right in front of me, or was talking in a group situation, I couldn't hear.

"I was working in the paint shop, in the quality-control area and there were various noisy machines such as compressors mixing paint, tracks that the vehicles moved on and also tools that used compressed air that made a whining noise.

"I was advised to wear ear protection only in the last 12 months of my employment - but it wasn't compulsory."

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