What employers need to do about noise - why noise assessments are needed
The HSE’s Noise Regs detail specific responsibilities for noise safety which employers need to make sure they are meeting. This is a simple (as I can make it anyway!) guide to an employer’s obligations for noise safety and what they need to do to be in compliance.
What’s the big deal about noise anyway?
The issue is that it is unseen, both in the danger and the effects, until it is too late. Noise damage to hearing is permanent, there is no fix, and by the time the hearing damage from noise is noticed it will already be having an impact on someone’s life, both home and at work, and under the current state of play, it can’t be fixed. That’s why noise is such an important issue.
The Control of Noise at Work Regulations
As this is intentionally a very short summary giving a simple overview of the key points, employers should also refer to L108.
The HSE detail all the employer’s responsibilities in their document L108: Controlling Noise at Work. This contains the Noise Regs themselves and also the HSE’s guidance on how to comply.
The Noise Regs only apply to people who are ‘at work’, including volunteers, but not people who are getting social noise. For example, in a nightclub the Noise Regs apply to the people at work but not customers.
I’ve used terminology here which is intended to reflect common usage rather than be nerdily technical, so for example ‘noise limits’ instead of ‘action values’ as it is worded by the HSE, or ‘volume’ instead of ‘sound pressure level’ which is what a noise meter measures, and avoided use of LA,eq, L,epd, etc. as that doesn’t mean much to normal people.
Regulation 4
This sets out the noise limits for work, these being:
A daily or weekly lower limit of 80 dB(A) and 135 dB(C).
A daily or weekly upper limit of 85 dB(A) and 137 dB(C).
An absolute limit of 87 dB(A) and 140 dB(C). For clarity, ignore this one as it is not helpful and adds confusion in 99% of cases. (See bottom right for a bit more on this).
Normally the daily limits apply, but if noise exposures vary a lot and are focused on only one or two days, the weekly limits can be used instead.
Importantly, these limits ignore the effect of any hearing protection, i.e. it is the actual noise in the workplace, not the noise minus the impact of ear plugs or ear muffs.
Regulation 5
This governs noise assessment and noise risk assessments.
If noise exposures are likely to be over the 80 dB(A) level then a noise risk assessment shall be done.
The noise assessment measures the noise levels and also expected exposure frequency and durations, to ideally generate a daily or weekly exposure figure.
As an aside, some workplaces are such that a daily exposure is simply not possible by the way, e.g. a joinery workshop where the work changes every day so an exposure on one day will have no relevance to any other. In these cases practicality dictates the actual machine noise levels may have to be used instead.
The noise assessment should identify:
The expected noise exposure levels in the workplace
Who is exposed
Who may need training, PPE or health surveillance.
From that, employers need a noise risk assessment which covers:
Main findings of the noise assessment
Training needs, who needs to be covered, and when it is done.
Health surveillance needs and records
Signage needs
PPE selection, training, monitoring, cleaning, storage, etc.
Any ototoxic substances which may be present or potential excessive vibration which may physically impact the ears.
Possible noise exposure reduction measures other than PPE
Noise assessments and noise risk assessments need to be reviewed.
Regulation 6
This requires employers to reduce noise exposures by something other than PPE (hearing protection) first, and then only use PPE where a risk remains.
The requirement to reduce noise exposures is not only dependent on exceeding the 85 dB(A) limit and the Regs (6-1) do require employers to reduce noise levels to as low a level as possible generally. Basically, the higher the risk the more the employer is expected to do to reduce noise generation.
Regulation 7
This requires employers to sign areas where hearing protection is needed, issue hearing protection assessed as suitable, train in its use, have somewhere to store it, clean it, means of reporting damaged protection, get replacements, etc. Also an employer must monitor compliance and enforce it - issuing it is not the end of the responsibilities,
Regulation 9
Health Surveillance (hearing testing) is needed for anyone with a daily or weekly figure exceeding the 85 dB(A) or 137 dB(C) limit.
Regulation 10
Noise safety training has to be given to anyone with a noise exposure over the lower 80 dB(A) or 135 dB(C) limit. The HSE are very specific in what that must cover.
Documents to download from the HSE
L108: Controlling Noise at Work
The HSE detail all the employer’s responsibilities in their document L108: Controlling Noise at Work. This contains the Noise Regs themselves and also the HSE’s guidance on how to comply.
A free copy can be downloaded from the HSE’s website:
L108 is your main reference and it has all the requirements an employer needs to meet such as when to do a noise assessment, what a noise assessment should cover, steps needed to mitigate noise risk, training requirements, health surveillance (hearing testing) needs, hearing protection issue, maintenance and compliance monitoring, etc. Having a copy of this as a reference can. be very beneficial.
If you already have this, make sure it is the Revision 3 version as this made some key changes, especially around the health surveillance programmes.
The HSE also have other supporting documents which could be useful to have:
INDG362: Noise at Work - A Brief Guide to Controlling The Risks
Effectively this is a simplified version of L108 and gives an overview of the Noise Regs and what employers need to do.
INDG363: Noise - Don’t Lose Your Hearing
This is aimed at employees and is a basic guide to protecting hearing. Can be useful to give to employees as part of a noise training programme.
Daily limits versus machine noise levels
There is an important distinction here in that the lower and upper limits in Regulation 4 refer to someone’s daily noise exposure, with things like hearing testing or mandatory PPE then applying where that person is over the daily limit.
That is not the same as someone being over the 85 dB(A) limit briefly.
Remember, noise risk is a combination of both how loud it is but also how long someone is exposed.
For example: An area of a factory could be generating employee noise exposures of 88 dB(A) over their working day, so as their daily exposure is over the 85 dB(A) limit then hearing protection and hearing testing is needed.
Another person who is normally based in a quiet area may walk into that noisy area briefly to walk through or to talk to someone. Their daily exposure will normally therefore be well below that 88 dB(A) level. If they are in there for a cumulative half an hour in a day and are otherwise at 70 dB(A) in an office, their daily average noise exposure will actually be around 77dB(A). That means they do not meet the requirements for mandatory hearing protection and hearing testing.
Practically, most employers make anyone entering a high noise area wear hearing protection as otherwise you can end up in the situation of two people, both in the same area, but one needs hearing protection and one does not. But, that person who is only there temporarily definitely doesn’t need to be included in a health surveillance programme.
When to use a weekly noise exposure limit
You may have a job where all the noise is focused on one or two days which can be quite loud, while the rest of the week it is nice and quiet.
One example which comes to mind purely as I had it as a situation that came up recently is theatre or music venue staff or personnel working on festivals. Often their only noise exposure is on one or two nights in a week with very little to no occupational noise exposure on the other days.
In these situations, using a weekly noise exposure calculation in a noise assessment is the most suitable way to get a result as it makes an allowance for those days with very little noise exposure at all.
Is there a maximum noise level at work which people can be exposed to?
This sometimes comes up in relation to noise risk assessment at work and is a bit of a red herring. There is a limit in the Noise Regs of 87 dB(A) which the absolute maximum people can be exposed to at work but there are some catches.
The main limits of 80 and 85 dB(A) are the noise in the workplace, those are the main limits and above 85 dB(A) things like hearing protection are needed. They do not take into account any impacts of hearing protection. So the Noise Regs don’t say people can’t work in those noise levels.
The 87 dB(A) limit is different in that it is the noise level under hearing protection. The strongest hearing protection on the market currently has an attenuation of around 39 dB. Adding 39 dB of that to the 87 dB(A) limit means a maximum noise level people can work in of around 126 dB(A). That is an average - as in what their daily average level is calculated as in a noise assessment, not a single exposure.
126 dB(A) is hellishly loud as an average - in 30 years of noise assessments I have never measured a workplace which had an average noise level of anything like that.