Noise at Work Risk Assessments Explained

There are several other factors that influence the choice of which type of hearing protector an employee may wish to use, as outlined in Part 5 of the NAW Regulations, which also state that “wherever possible the employer should make more than one type of protector available (making sure that each is suitable for the noise and jobs to be done) to allow the user a personal choice”.

Employees are often reluctant to use hearing protection, are forgetful, or do not apply protection correctly. A programme of monitoring, supervision, warning notices, instruction, and training is needed to ensure they are used. It is also important that a system of maintenance is employed, to ensure that the hearing protection maintains its level of noise reduction and does not become defective over time.

Hearing Protection Zones (HPZ)

Regulation 7 of the NAW Regulations indicates If any area in the workplace is likely to be exposed to noise levels at or above the upper exposure action value (UEAV) then the employer must ensure that:

• the area is designated a Hearing Protection Zone (HPZ);
• the area is demarcated and identified by means of the sign specified for the purpose of indicating that ear protection must be worn;
• access to the area is restricted where this is practicable and the risk from exposure justifies it; and
• no employee enters that area unless that employee is wearing personal hearing protectors, so far as is reasonably practicable.

The boundaries of HPZs should be considered carefully, i.e. they should avoid overlapping commonly used walkways and should not extend further than is necessary to protect people carrying out their normal work. In situations where the boundaries of a zone cannot be marked, then attaching hearing protection zone signs to specific tools is an appropriate alternative.

Information, Instruction, and Training

Regulation 10 of the NAW Regulations indicates that the employer must provide ‘information, instruction, and training’ to employees who are exposed to above the LEAV. It is important for the employer to tell employees:

• their likely level of noise exposure and the health risk this carries;
• what the employer is doing to control risks and exposure to noise;
• when and how the employee can obtain hearing protection and when they should use it;
• how the employee should be using hearing protection and noise control equipment in the correct way to minimize their risk, and how they can identify and report defects;
• what the employees’ duties are under the NAW Regulations; and
• how the employer is providing a health surveillance system; and
• what symptoms of hearing damage the employee should look out for, and to whom and how they should report this.

This information, instruction, and training can be provided in any way, providing the employee can find it easy to understand. The HSE’s ‘Noise: Don’t lose your hearing!’ pocked card can be handed out to supplement this.

It is also a requirement to discuss the risk assessment and all plans relating to controlling noise exposure with a trade union-appointed safety representative, or for groups of workers not covered by this, an elected employee representative.

Health Surveillance

Regulation 9 of the NAW Regulations state that there is significant evidence which links the regular exposure to noise levels above the exposure action values to long term health risks and hearing damage. Therefore, the employer should provide health surveillance to:

• all employees who are regularly exposed to noise levels above the upper exposure action values (UEAV); or
• employees who are occasionally exposed above the UEAV, or who are exposed between the lower (LEAV) and upper (UEAV) thresholds but who are known to be particularly sensitive to noise, i.e. from medical history, audiometric testing or a history of noise exposure at previous jobs, or a family history of early-onset deafness.

Health surveillance is a programme of health checks which usually involves regular hearing checks (audiometric testing), keeping health records, and referring employees to a doctor if/when hearing damage is identified. It is useful in waring employees if they exhibit early signs of hearing damage to give the opportunity to do something to prevent the damage from getting worse. It is also effective for the employer to identify whether noise control measures are working.

Surveillance can be introduced at any time for existing employees and should be introduced straightaway for new employees, to allow a baseline to be taken. Annual checks for the first two years (followed by three-yearly checks after this unless a problem is detected or the risk of hearing damage is high) should be conducted by someone with appropriate training, with the whole surveillance programme under the control of an occupational health professional.

Regulation 5 of the NAW Regulations indicate that the employer should implement an ongoing control programme in managing noise exposure risks. It may be necessary to review and produce an updated risk assessment when circumstances change, for example, if:

• circumstances change in the workplace, i.e. new equipment is installed, older machinery ceases to be used, shift patterns are changed, any reason that employees’ level of noise exposure may have changed;
• noise control measures have been implemented since the previous assessment and the impact on employees’ exposure needs to be re-assessed;
• the employer becomes aware of improved working methods and noise-control techniques that are new to the industry and could be applied to the workplace;
• control measures that could not be implemented at the time of the original assessment become more viable to do so, i.e. because of new technology or reduced costs; and/or
• continued health surveillance shows that employees’ hearing is being damaged, suggesting that noise control methods are not being properly implemented or are not effective enough.

The NAW Regulations indicate that even if none of the points above are true, the assessment should still be reviewed at least every two years.