Managing Workplace Noise Exposure: A Compliance Guide for Employers

Summary

Noise compliance should give managers a clear line of sight from exposure assessment through noise reduction, hearing protection and health surveillance. Under the Control of Noise at Work Regulations 2005, employers in Great Britain must identify employees at risk and manage their exposure according to both the level of noise and the effectiveness of existing controls.

Determine Which Employees Are Actually Exposed

A noise assessment should reflect the work employees perform over their working day or week. Managers need to consider duration as well as sound level because personal exposure depends on how much noise a person receives over time.

The Regulations set a lower exposure action value of 80 dB(A) and an upper exposure action value of 85 dB(A) for daily or weekly exposure. Separate action values of 135 dB(C) and 137 dB(C) apply to peak sound pressure.

These figures should be used to determine the controls and other duties that apply. Where exposure is uncertain, competent assessment or measurement may be necessary.

Workers who move between tasks or areas deserve particular attention. A short period of high exposure combined with other noisy work may produce a different overall exposure from a single workplace reading.

Build Noise Reduction Into Equipment and Work Decisions

Once a noise risk has been identified, control should focus on removing or reducing the exposure itself.

Managers should consider whether quieter machinery, tools or processes are available when equipment is selected or replaced. Existing equipment may require maintenance or modification where its condition or operation contributes to unnecessary noise.

Work organisation can also affect exposure. Limiting the number of people in noisy areas, reducing exposure time and arranging suitable work schedules are among the organisational measures available.

Where the upper exposure action values are reached or exceeded, employers must establish and implement a programme of technical and organisational measures. This should provide a defined basis for reducing exposure instead of leaving hearing protection as the principal response.

Treat Hearing Protection as a Managed Control

At or above the lower exposure action values, suitable personal hearing protectors must be made available to employees who request them.

The position changes at the upper exposure action values. Suitable hearing protection must be provided and employees must use it where exposure cannot be adequately controlled by other means. Hearing protection zones should be identified where reasonably practicable.

Selection requires judgement. Protection should reduce exposure sufficiently without creating unnecessary isolation from the working environment. Fit, compatibility with other PPE and the working conditions should be considered.

Supervision matters after issue. Managers should check whether protectors are being worn correctly and whether damaged, worn or unsuitable equipment is replaced.

Keep Exposure Below the Limit Values

The exposure limit values are 87 dB(A) for daily or weekly exposure and 140 dB(C) for peak sound pressure. Unlike the action values, the effect of hearing protection is taken into account when determining exposure against these limits.

Employees must not be exposed above the limit values. If a limit is exceeded, the employer must take immediate action to reduce exposure below it, determine why the overexposure occurred and amend the protection and prevention measures to prevent recurrence.

Management reporting should therefore distinguish clearly between action values, which trigger specified controls, and limit values, which must not be exceeded.

Use Health Surveillance as Part of Noise Management

Health surveillance is required for employees who are likely to be regularly exposed above the upper action values or who are otherwise at risk from noise.

Suitable surveillance includes hearing checks carried out under appropriate arrangements. Employees should receive information about the purpose of the programme, and relevant results need to feed back into management of the noise risk.

Evidence of hearing damage may require the risk assessment and control measures to be reviewed. It can also indicate that exposure arrangements or hearing protection need closer examination.

Review Noise Controls When Work Changes

Noise assessments can become outdated when machinery, processes, production rates or working patterns change. Managers should therefore connect noise review arrangements with operational change.

Maintenance is another part of control. Engineering measures, workplace controls and hearing protection need to remain effective throughout their use. A control that has deteriorated may leave actual exposure above the level assumed by the assessment.

Common Compliance Gaps

Weak arrangements often include noise surveys that record sound levels without establishing personal exposure, hearing protection issued without a planned programme of noise reduction, and assessments left unchanged after machinery or working patterns alter.

Further gaps include uncertainty over who requires health surveillance, inconsistent use of hearing protection zones and failure to investigate exposure above a limit value.

Manager Checklist

1. Identify employees whose daily, weekly or peak exposure may trigger duties under the Regulations.
2. Check that assessments consider both noise level and exposure duration.
3. Examine procurement and maintenance decisions for opportunities to reduce noise at source.
4. Sample the delivery of technical and organisational controls in higher-exposure work.
5. Confirm hearing protectors provide suitable protection and are used where required.
6. Verify that exposure limit values are not exceeded after hearing protection is taken into account.
7. Review which employees require health surveillance and whether they are included.
8. Use equipment, process and working-pattern changes as triggers for reassessment.

Frequently Asked Questions

What is the difference between an action value and an exposure limit value?

An action value triggers particular employer duties. An exposure limit value sets a maximum exposure that must not be exceeded, with hearing protection taken into account when assessing compliance with the limit.

Can weekly exposure be used instead of daily exposure?

The Regulations provide for daily or weekly personal noise exposure. Weekly exposure can be relevant where daily exposure varies markedly, subject to the conditions applying to its use.

Is health surveillance required for everyone working in a noisy area?

No. It is required where employees are likely to be regularly exposed above the upper exposure action values or where they are otherwise at risk from noise.

What happens if the exposure limit value is exceeded?

The employer must act immediately to reduce exposure below the limit, investigate the reason for the overexposure and amend the protective or preventive measures to prevent it happening again.

Should noise controls be maintained?

Yes. Equipment and measures provided to control workplace noise, together with personal hearing protection, need to be maintained so that they continue to perform effectively.