The impact of failing to monitor noise for employees is a major public health issue. What needs to change?
Peter Wilson is angry. The technical director of the Industrial Noise and Vibration Centre is a veteran in noise reduction and helped to write the IOSH ‘Noise at work – risk assessment and management’ course, yet he finds himself frustrated by the global approach to noise-induced hearing loss (NIHL).
‘I’ve been doing this for 40 years and have become increasingly disillusioned with the whole industry,’ he says. ‘Too many people treat risk assessment as a box-ticking exercise. People are still going deaf needlessly and it is 100% preventable.’
Dr David Greenberg, chief executive of noise management technology company Eave, is equally passionate about the subject of hearing loss. Before founding Eave, he practised as an NHS audiological clinician and gained a PhD in auditory neuroscience.
He spells out the consequences of hearing loss: ‘Accidents in the workplace rise with increased hearing loss. If you have normal hearing, you have a 2.4% chance of having a workplace accident in a three-month window. If you have a lot of trouble with your hearing, the chance doubles to 4.8%.
‘Employment rates for men are badly affected, too. Across almost the entire age range, if you have hearing loss you are less likely to be employed. Those with hearing loss are more likely to retire early, feel shame, embarrassment and have a lack of self-worth.’
David adds that, in a 2020 Lancet report on dementia, the number-one controllable risk factor in dementia was hearing loss. ‘When we’re exposed to noise, the inner ear, the cochlea, is affected. It has hair cells that have a direct link to the brain. Once these cells are damaged, they don’t recover. If we eliminated hearing loss, we’d reduce the number of people with dementia by 9%. We really need to start paying attention to aspects like this, because it is a public health issue.’
The important message relating to noise-induced hearing loss from the UK Health and Safety Executive (HSE) is that inspectors are looking for one thing – that duty holders are controlling risk.
Chris Steel, a noise and vibration specialist at the HSE, says: ‘All too often, health surveillance finds occupational noise-induced hearing loss.
‘Failings that have led to hearing loss should be identified and corrected, including appropriate use of grouped, anonymised health surveillance findings. Measurement and monitoring of noise are essential but should be minimal and only used when necessary to inform control actions.’
The HSE lists three fundamental factors duty holders should take into account to ensure that the risk posed by noise is controlled:
- The most efficient and effective way of controlling noise is by technical and organisational means reducing noise at source.
- When purchasing or hiring machinery, quieter machines should be preferred.
- Hearing protection is a last resort but necessary to prevent deafness in many workers. To be effective, hearing protection programmes must be supported by appropriate health surveillance and sufficient information, instruction and training.
For more information about HSE expectations and guidance, visit hse.gov.uk/noise
Crimes and punishment
Occupational noise is responsible for 16% of disabling hearing loss in adults. In Europe alone, says EU-OSHA, approximately one-quarter to one-third of the workforce is exposed to hazardous levels of noise at least a quarter of the time. The majority are in industries such as manufacturing, construction, oil and gas, and mining.
In the UK, the main noise legislation is the Control of Noise at Work Regulations 2005 (see Dialling it down, page 59). ‘There are two main noise levels,’ says solicitor Simon Ellis, a partner at Hugh James and head of the firm’s military claims department. ‘The first is a daily or weekly personal noise exposure of 80 decibels (A-weighted). The employer is under a duty to identify that fact, to make employees aware of it, and to make ear protection available to them and to make sure training is offered.
People are still going deaf needlessly and it is 100% preventable
‘The next trigger is 85 decibels (A-weighted). At this point, employers have to make sure hearing protection is used by the workforce in the areas identified as noisy.’
Failure to comply with legislation can be expensive. Simon leads a department of 40 people looking after military hearing loss. In 2019, he recovered more than £500,000 for a hearing-impaired former Royal Marine. He has more than 3500 cases on his books.
One difficulty for employers can be that workers might accept a noisy environment as ‘part of the job’ and disguise the signs associated with NIHL. Simon says people can assume that it doesn’t apply to a particular industry. ‘If you look at nightclubs, for example, there can be a perception that it doesn’t apply as it’s hospitality. But if you’re working as a bar manager then you are likely to be exposed to high levels of noise,’ he says.
‘Another problem is if you don’t wear the noise protection for the entire shift. It’s not simply a case of, “If it’s off for 25% of the time, then only 25% of the damage occurs” – it can cause much more than that over a short period of time.’
The Control of Noise at Work Regulations 2005 and the Control of Noise at Work Regulations (Northern Ireland) 2006 require employers to eliminate or reduce the risks to health and safety from noise in the workplace. Employers are required to:
- Carry out a risk assessment where exposure to noise is likely to be at or above the lower exposure action value
- Take action to eliminate noise or to reduce exposure so far as is reasonably practicable
- Introduce control measures, based on a hierarchy of control, to reduce exposure
- Maintain equipment and ensure its correct use
- Where required, provide hearing protection and hearing protection zones
- Provide employees with information, instruction, training and supervision
- Undertake health surveillance where a risk assessment indicates that there may be a risk.
How do we fix it?
Tina Morgan, an agency manager for NFU Mutual and chair of the IOSH Rural Industries Group, says that employers should look for signs that a worker is finding it difficult to hear conversations from a normal operating distance.
‘The employee may ask for things to be repeated or seem to find conversations difficult, especially in environments where there is additional background noise,’ she says.
‘There may be misunderstandings and near-misses or accidents recorded where they have failed to react to warning signals or alarms.’ IOSH’s noise toolkit has more details on signs and symptoms (see Resources below).
Tina says employers should ensure that they consult with staff and inform them what level of noise is considered harmful, the effects of exposure and the control measures required to ensure safety.
‘They must also ensure that they have noise levels checked regularly, as even well-controlled noise can increase as a result of defective machinery such as a worn motor, damaged bearings, lack of greasing or lubrication. While basic measurements can be taken by anyone, it is important to ensure that detailed measurements and analysis are carried out by a competent noise assessor and that any consultants have professional indemnity insurance,’ she says.
‘Employers should also incorporate health screening into their safety management system as part of an occupational health programme. Good practice would be to have all new employees undergo a hearing check and to ensure that they can report any symptoms without recrimination.’
IOSH has a range of relevant courses and workshops (see Resources below). Keith Foster, safety and risk consultant at Powys Safety Solutions, says that education is crucial, with examples of penalties for non-compliance. He would also like to see rewards for staff complying with good safety practices, including RoSPA awards. ‘We are always quick to chastise poor practices and discipline staff for transgressions, but what about congratulating them on safe working? We should celebrate the safety culture,’ he says.
The World Health Organization has noted that one occupation often criticised for noise-induced hearing loss is ship recycling. Mostly carried out in Bangladesh, China, India, Pakistan and Turkey, it is done ‘for the most part without effective occupational safety regulation’.
It quoted Joydeep Majumder, a workplace noise and audiometry expert at the National Institute of Occupational Health in Ahmedabad, India. He reported that oxy-fuel torch cutters tended to work in the same area all day and could be exposed to levels of sound exceeding 140 decibels for prolonged periods.
He said: ‘Workers do not want to use ear plugs or ear muffs because they cannot hear each other and because of the humidity. They are sweating heavily and the ear plugs are uncomfortable. They also fear getting ear infections.
‘The majority of these workers are not even aware that they have a problem. They typically come from rural areas and are surrounded by other hearing-impaired people and they are all shouting, and they do not realise what is happening until they go back to their families.’
Joydeep has been trying to boost awareness and encourage greater use of PPE by conducting on-site training.
The last line of defence
The subject of PPE can be contentious. ‘Doing the measurements is easy,’ Peter says. ‘The difficult bit is changing things to reduce the risk. The level of knowledge about noise control is abysmal. Everyone falls back on high-cost palliatives. As a simple example of low-cost engineering noise control, sound-damped steel can be hugely effective. It’s laminated steel, which looks like steel or stainless steel, but it sounds like rubber and can be used on chutes, hoppers, guards and so on. It has been around for 45 years but very few people know about it.
‘Likewise, a conventional risk assessment might recommend enclosures. All too often, the conclusion is that it would result in terrible hygiene and access, plus it would cost a fortune. So nothing changes. Using noise control “scalpels” such as sound-damped steel and efficient air nozzles instead of blunt instruments such as enclosures can actually help to save a fortune.’
David agrees that measurements are not useful by themselves, ‘particularly if they are just going to sit on a shelf in a report. You need to know where your problem is and how big a problem it is, so you can do something about it.’
Even as a PPE manufacturer, he acknowledges that it is the least effective way to reduce risk. ‘It is the absolute last resort, the last line of defence, which means that if it fails, the person is exposed. So if the company has failed to eliminate the hazard at source, then they’d better make damn sure the PPE works.’
Ultimately, David believes that if things are going to change, it can’t be left to education and awareness alone. ‘Education is great and you’ll capture the percentage who see that it makes sense, but what’s required, in my view, is legislation.
‘NIHL is eligible for industrial injuries disablement benefit but it’s not reportable under RIDDOR. In the eyes of the law, we can disable people so much that they need to go on benefits, but you don’t need to tell anyone about it. That’s got to change.’
- Free advice to help employers tackle noise at work: bit.ly/IOSH-noise-toolkit
- Practical ways to eliminate or reduce risk: bit.ly/IOSH-noise-control-measures
- Learn about best practice in measurement and management: bit.ly/IOSH-noise-workshop
- Identify potential problems before it’s too late: bit.ly/IOSH-noise-early-intervention