NOISE ASSESSMENT
Industrial noise surveys
Measurement and reporting for employee noise exposure in all workplaces
All UK covered ● Experienced assessors ● Daily average exposures
Assessment of hearing protection ● Wearable and hand-held noise monitoring
Not just carbon neutral, we are are carbon negative
“Thank you for the report. Very comprehensive with good, easy to understand information for us to make improvements
and changes where necessary”. QHSE Manager, Hull, 2022
Our noise assessments are conducted by individuals with over 30 years of experience in industrial noise assessment, monitoring noise for clients ranging from 2 to 2,000 employees, anywhere in the UK from Cornwall to Scotland. In the last year we have worked in heavy industry, colleges and schools, the NHS, the food industry, engineering and fabrication, joinery, agriculture, and shipping.
Our reports are not just a templated list of machines and measurements, but give a range of noise safety data and advice as appropriate to the site such as daily exposure values, recommendations on reducing noise levels, assessment of suitability of current hearing protection and advice on possible alternatives, and much more.
With personal accountability for every noise assessment we do, we can provide high-quality noise assessments to help companies comply with the HSE’s Noise Regs, and all at an extremely reasonable price.
Why choose us?
As the company name implies, we are noise nerds through and through. We don’t dabble in other safety subjects; within the safety realm we just do noise at work assessments.
As we also do audiometry on the health side, this means we have a thorough overview of not just the practical side of measuring noise risks, but also the health implications of it.
Simple to arrange
Point us at the area you want measuring and we will cover the average dB(A) figures and peak dB(C) levels you need, using whichever noise meters best suit the jobs taking place.
Measurements are made for as long as is needed to get a good result. For jobs which are not running, a short sample measurement can be made to cover as much as possible.
Noise assessment report
While the report has a standard layout, we change parts as-needed for each client - we make the report fit your site rather than making your measurements fit our standard template.
We give a summary of the key findings for those who want a quick over-view, followed by specific details and recommendations for those who want to dive into it more deeply.
“I would just like to thank you for your time on site, and the professional manner in which the noise assessment was conducted. Your report also reflects this, I've found it very easy to read and from which to produce an action plan.”
MD and co-owner of an engineering site, Newcastle, May 2022
Noise assessment quotes
More information on our noise assessments
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Noise levels
We measure the noise levels and give comparison to the Noise Regs limits.For noise nerds - we measure dB(A), dB(C) peaks, and give eight-hour daily averages. We will use hand-held and wearable noise meters - whichever is most appropriate for the job.
Hearing protection assessment
We will assess current hearing protection against the noise levels present confirm all is OK. We will also give alternatives and tell you what SNR to aim for so you can choose as needed.Other advice
Such as some suggested noise reduction measures, who needs hearing protection, who needs hearing testing (audiometry), etc. -
Either email hello@thenoisechap.com, or complete the form here.
All we need to know is where in the country you are and as a guide to size, how many people work in the noisy area. (That’s a much better guide to size than physical size of the site). We will then send a quote back to you which is a complete price with no extras.
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Our noise assessor is certified by the Institute of Acoustics in workplace noise risk assessment, but this is only the start of their knowledge and competence is a combination of qualification and experience.
Qualification in noise assessment
Our assessor holds the Certificate of Competence in Workplace Noise Assessment from the Institute of Acoustics for specialism in noise risk assessment, along with the NEBOSH Diploma, the combination of which gives a good overall understanding of health and safety principles and how noise slots into that.
Experience of noise assessments
With 30 years of experience of industrial noise surveys in everything from joinery workshops to food factories, emergency services to ships, automotive industries to ship building, and companies from 5 to 2000 employees, we have experience of delivering high quality noise assessments in all workplaces.
Direct accountability
As a small company we have a direct relationships with clients meaning we are accountable for what we do and want to get it right every time. We don’t take the lazy way of templated lists of numbers or a map of the site with some dB levels on it, but provide you with a proper noise risk assessment, with clear results and noise management advice.
Why no CMIOSH or OSHCR?
We are not on the OSHCR for the simple reason that we are not Health and Safety Consultants. Health and Safety Consultants do asbestos, lone working, electrics, working at heights, accident investigation, workplace safety, and on and on, whereas we just do noise. But better.
The Noise Chap himself used to be CMIOSH but when the decision was taken to focus purely on noise and audiometry, the rest of the CMIOSH stuff became irrelevant, so it was cancelled.
There is no overall membership body purely for noise assessment in the UK, unfortunately.
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When we get there all we need is someone to show us around so we know what you want measuring and get an idea of the place.
After that we are pretty much self-contained and will crack on with the noise assessment, pootling along until we have all the measurements we need. We may use multiple noise meters at once, depending on the specific jobs we’re measuring.
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These take a little time to do as we gather a lot of data on the day, but also change our report slightly to match each client. We make the report fit your site, not make your site’s data fit our report…
You get a PDF report which contains:
Summary section
This is a short-n-sweet one or two pages which can be useful for circulating in the company to people who don’t need the full opus.How we did the noise assessment
Guidance on how the data was gathered and what it means..Individual noise results
The measurement results per noise measurement made, along with specific comments on each.Hearing protection section
How well your current hearing protection performs, any issues seen, and some suitable alternatives calculated based on your noise levels should you wish to change in the future.Recommendations for managing noise
A section outlining what actions we recommend are taken next to manage noise in the workplace.Noise risk assessment example
Bear in mind that measuring noise is only part of an overall noise risk assessment. We give you a simple example outline of a noise risk assessment for your site based on your individual results and recommendations.
We have undertaken noise assessments in a huge variety of workplaces.
joinery workshops ● metal fabrication ● NHS wards ● printing ● many parts of the food industry ● agriculture ● ship’s crews, both in port and at-sea ● vehicle manufacture ● brewing ● helicopter pilots ● at-sea enforcement agencies ● fire brigades ● clothing industry ● furniture manufacture ● packaging industries ● music schools ● colleges teaching welding, joinery, etc. ● window and door manufacturing ● recycling sites ● nightclubs ● armed forces ● logistics ● vehicle repair ● national park grounds maintenance teams ● foundries ● steel industries
Managing Noise FAQ
Some of the key issues which come up for both noise assessments and managing noise.
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It’s an interesting dilemma - how do you know you need to do a noise assessment without actually doing a noise assessment?
A noise assessment must be done by any employer who has noise levels which are exceeding 80dB(A).
Note that this is the lower 80 dB(A) level, not the 85 dB(A) point where things like hearing protection are needed.
It is also recommended to have a full noise assessment if noise levels are thought to be around 78-79 dB(A) due to the natural variations each day.
L108 has some guidance (not law) that ‘if you are in any doubt, it would be best to assume that [a noise assessment is needed]’.
Ways to identify if you should do a noise assessment
If noise is intrusive while having a conversation with people then that is an indication the levels are around 80 dB(A).
Noise data provided by the manufacturer of the equipment being used.
If someone on your site has an Apple Watch then the built-in noise meter function on that is surprisingly accurate. We have tested it ourselves and found it to reliably be within 1.5 to 2dB of the actual level.
A cheap Type 3 noise meter can be a big help in this part as a rough and ready indication of whether it's getting a bit loud.
Phone apps are not great to be honest.
Advice if you decide you do not need a noise assessment
Document that you went through the decision-making process, covering who was involved, how it was done and when it was done. That way when the HSE come knocking you can say 'yes my Benevolent Lord of Safety, we have checked to see if we needed a noise assessment and here is how and when we did it'.
If you say you checked but have nothing documenting it then they will get a steely glint behind the monocle over their one good eye and pour forth their anger upon you.
Remember if there is no proof or record of something being done then it didn't happen. And it's always better to have done the right thing and got a result they disagree with than to be thought not to have tried at all.
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Noise assessments aren't a one-shot process and do need to be reviewed or renewed every so often, but how often? Sometimes consultants put an ‘expiry’ date on their noise assessment report but often this is more about marketing than law, and a lot of the time you can do the review in-house.
What the Noise Regs actually say
The Regulations, the actual law bit, simply say: ‘The risk assessment shall be reviewed regularly, and forthwith, if there is reason to suspect that the risk assessment is no longer valid; or there has been a significant change in the work to which the assessment relates’. That’s it for the actual law - review it when you think you need to.
Review vs repeat a noise assessment
I think it is helpful to distinguish between a ‘review’, which can mean checking an existing noise assessment is still valid, and ‘repeat’, meaning doing a new noise assessment from scratch.
What we recommend
Reviewing a noise assessment
The basic principle is that you should review the noise assessment when you have reason to believe things may have changed and possibly altered peoples' exposures to noise. For example, changes to a factory layout, introduction of new machinery, changes in how long machines are used, changes in shifts, etc.
A review can be a systematic check of the existing assessment looking to make sure nothing has changed; the machines are the same, the people the same, the shifts the same, etc. and if all is good, document that this review has been done and that's it, all sorted.
Even if you had the noise assessment itself done by an external consultant you can still do this review in-house - it is your business and you know if something has changed.
If nothing has changed, document that the review was done so you can prove when it took place, who was involved and what was looked at, and then you are done. This needn’t be too onerous and notes or minutes will suffice.
Do an in-house review at least annually and keep the record alongside the noise assessment.
Repeating a noise assessment
This is a less frequent repeat or new noise assessment (most likely done externally)
To be clear, as the Regs say almost nothing on this, this is entirely a recommendation from us and we don’t want to pretend noise assessments have any kind of expiry date set in law.
As a recommendation for re-doing / repeating a noise assessment, for sites with a general noise risk I would recommend you re-do the assessment from scratch every three years or so. This is purely because although it may look like nothing has changed, some things inevitably will. Cutting heads may be increasingly worn and worn heads make more noise than sharp ones. Bearings may be wearing in a motor. A loose panel bolt can make a dramatic change in the noise levels. None of these will be apparent on a quick check so a policy of doing it again from scratch will act as a good fail-safe for you.
If your noise risks are particularly high or there are often changes to working practices or equipment, consider re-doing it from scratch every two years, but make that decision based on your assessment of your risks and whether you consider the noise risks to be high or not.
This is only a recommendation from us and if you choose to go longer, with more interim reviews, then that is perfectly valid.
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Despite the similar-sounding terminology, there is a difference between a ‘noise assessment’ and a ‘noise risk assessment’ and a noise assessment forms part of a wider noise risk assessment.
A noise consultant can do the noise assessment for you but only the employer can do the noise risk assessment. But don’t worry, it’s not very onerous and doing a noise risk assessment is more a case of pulling together disparate activities which are likely already in place.
We have a page going into this in more detail, but in brief:
Noise survey / noise maps
Generally, a plan of the site with noise levels marked on. Not really relevant to what is required by the Noise Reg
Noise assessment
Measuring the noise levels and providing advice on who needs to wear hearing protection, suitability of hearing protection, who needs training and some possible engineering or organisational controls.
Noise risk assessment
To meet their obligations, companies need to take what we have given you as the noise assessment and then do a noise risk assessment.
This can be a simple document referencing things like training records, hearing testing programme records, noise reduction records, etc.
We have more information on the difference between a noise assessment and noise risk assessment, and a free noise risk assessment template to download, here.
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There are two types of noise meter, those you hold in your hand and those you place on a person. The wearable ones are called dosimeters (or sometimes dosemeters) and effectively do the same as the hand-held, just over a longer period of time.
The requirement for all noise assessments to use wearable dosimeters is one of the most commonly misunderstood elements of a noise assessment. To be unambiguous:
Hand-held noise meters are far superior to a wearable noise meter. Dosimeters must be viewed with a bucket-load of caution as they are so open to incorrect results.
With a wearable noise meter, as soon as someone walks away you have lost control of that measurement, there WILL absolutely be interference of one form or another with the meter, and it will generate some incorrect readings - most commonly recording the sound of the wearer’s own voice.
Wearable dosimeters have their use but they are very inferior to hand-held and should only be used where the specific measurement needs a wearable.
There is more information on this here:
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A noise risk assessment can be very simple and is often a short document linking together various other documents and information sources within the organisation.
An example noise assessment template can be downloaded here.
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This is quite a new area but is one employers should start getting in front of. From talking to clients we’ve had feedback that some HSE Inspectors are starting to ask companies if they have looked into this, so as always with the HSE it is better to be able to answer ‘yes, Almighty God Of Safety, we have indeed’ than look blank and feed their wrath.
Ototoxic means ‘poisonous to ears’ and chemicals which act in this way have various impacts:
At their simplest they can directly damage hearing or cause tinnitus.
Slightly more weirdly, some chemicals don’t damage hearing directly but can make the ear more susceptible to damage from excess noise.
They can mean that someone who would otherwise be absolutely fine at say 85 dB(A) instead has their hearing damaged,
At the moment there are no exposure limits for them but companies should identify what they do have via their CoSHH assessments. There is more information here on ototoxicity, what employers should do and a list of chemical products to watch out for.
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Not actually 'at work'?
The Noise Regs only apply to people who are experiencing noise at work. If you are not at work then there are no noise exposure limits. 'Work' doesn't necessarily mean being paid to be there and would cover anyone who is ‘working’, so includes volunteers, interns, contractors, etc.
Averaging is important for dB(A) limits, not for dB(C) though
Remember, the dB(A) limits of 80 and 85 are averages for a day, not peaks. So if it is 88 dB(A) for 10 minutes and quiet otherwise, then you are fine. dB(C) is however instantaneous - duration doesn’t matter.
80 dB(A) or 135 dB(C)
This is a raised eyebrow and a 'we may have a bit of a problem here'. (The HSE didn't use that precise wording which is their loss as it describes it perfectly).
Meeting either of these, (it doesn't have to be both), is a sign that noise levels are getting too high and certain requirements kick in.
Do a noise assessment.
Give employees training about noise including what the noise levels are.
Provide hearing protection but the employees can choose whether to use it.
Sign the areas as optional hearing protection.
85 dB(A) or 137 dB(C)
This is the biggie and again applies if the noise hits either one of them, not necessarily both.
Eliminate or reduce the noise levels by means such as engineering the noise out, or limiting exposure times.
Hearing protection is now mandatory - everyone exposed must wear it.
Use of hearing protection must be monitored and enforced. Issuing it and telling employees to wear it is not sufficient to meet the employer’s legal duties.
You need to do audiometric testing (health surveillance). This must be done in work-time and it cannot be optional, employees must attend. (Yep, the law is clear on this, employees cannot choose to opt-out).
87dB(A)
I will mention this fifth number as it is a specific limit but don't get too excited and distracted by it as it almost never applies.
87dB(A) is the absolute maximum noise level a worker may experience under the hearing protection. But, and this is not just a big 'but' but is a bloody huuuuuuge 'but', exceeding the standard 85dB(A) limit under the protection is only allowed where there is absolutely no other way of reducing the noise experienced by the worker - so where there are no options for limiting exposure time, there are no engineering options available, no more powerful hearing protection is available, etc. Only where all these are met can a worker be exposed up to 87dB(A) under the protection.
In reality there are very very few instances where this fifth limit is applied. Put it this way, in my 30-odd years working on noise issues including hundreds of different workplaces I've never come across a situation which met the criteria where the noise was so high there was no way to get the noise exposure under the protection back down to a safe level.
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This comes down the a book called L108 published by the HSE, and the Noise Regs.
If an employer think levels may be close to 80 dB(A)
Then they have to get a noise assessment - they have to measure the noise levels.
If levels are confirmed to be 80 to 84 dB(A)
Employee noise safety training has to be given.
Hearing protection has to be made available.
The use the hearing protection is optional for employees - they can choose whether to use it or not.
If levels are confirmed to be 84 dB(A) specifically
The HSE say that noise levels which are close to the 85 dB(A) limit should be treated as meeting it, so if you measure levels as being 84 dB(A), then the requirements for 85dB(A) and above below should be followed.
If levels are confirmed to be 85 dB(A) or over
Reduce the noise levels by engineering controls where reasonably possible.
Use organisational controls, eg limiting exposure time.
Hearing protection use is mandatory.
Hearing testing (audiometry) is mandatory.
Hearing Protection FAQ
Some guidance and advice on managing hearing protection at work. Trust this man for he is clearly wise.
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SNR figures
Hearing protection has a rating of how powerful it is and in the UK and EU this is the SNR figure. SNR is the number of decibels hearing protection reduces noise by. (SNR by the way is Single Number rating).
There are two other methods as well, HML and Octave Band, but only noise nerds need worry about those.
As a note, our American brethren use NRR, (Noise Reduction Rating). NRR is not the same as SNR and you can’t assume that an NRR figure will be the same value as an SNR, they are calculated differently.
Strongest is not best
Higher SNR is not a synonym for better so do not buy the most powerful protection just because it has a higher SNR. Higher SNRs can often be linked with decreased compliance, more incorrect use, and slightly incongruously, increased risk. You need the right hearing protection, not the strongest.
Use SNR to choose the right hearing protection
SNR tells you how strong some hearing protection is. In your noise assessment take the average dB(C) level, subtract the protector’s SNR, add 4dB back on to allow for incorrect use, and that is the figure people should experience under the protector.
Note: that is average dB(C), not peak dB(C), and not average dB(A).
We have a page describing this in more detail and walking you through the process.
Link: Using SNR to choose the right hearing protection
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This is a common question, but the unhelful answer is ‘there is no ‘best’ as such. We have a page going into this in more detail but the headlines are:
Ear muffs are not ‘stronger’ than ear plugs. The most powerful hearing protection on the market are actually squishy foam plugs. There are quite a few of them which are stronger than the most powerful muffs.
Stronger, as in reducing noise, is not always best. You need the right amount of noise reduction, at work too much is bad.
What is best depends on usage and other risks, for example:
For music listening you want a protector which reduces all frequencies by the same amount so it doesn’t distort the music.
For work you want hearing protection which removes the danger but means people can still hear alarms or speech or vehicles.
For sleeping you often want maximum noise reduction but also soft for comfort when sleeping on your side.
For DIY or home use you can use whatever you want really.
On a motorbike you want to eliminate the excess wind and tyre noise but keep situational awareness so someone in an Audi doesn’t kill you, but you also don’t want pain from the helmet pressing on the ear plug.
You may want to listen to the radio or music at the same time and some hearing protection is good at this, while most others are absolute crap. ISOTunes or 3M Worktunes are good, most of the off-brand stuff on Amazon is absolute shite and best avoided.
We have a page going into this in a lot more details and which recommends products for each of these categories.
Link: Best hearing protection
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Short answer: no, these can’t be worn in high noise areas or used as hearing protection, and this applies equally to over-head styles, in-ear styles and bone conduction.
(By the way, if you have no noise risk, then there is nothing stopping them being used).
1) The law says an employer can’t permit it.
Employers have a legal duty to provide hearing protection which is certified as hearing protection and carries a CE mark confirming it has been assessed as hearing protection. It will have performance figures such as an SNR value.
If music playing headphones do not have this, then it is simply illegal for them to be used in a high noise workplace.
2) Noise reduction claims lead more towards marketing
Noise reduction levels claimed by music headphones are not certified and not consistent enough to be relied on. (If Apple could get their AirPods certified as hearing protection as the noise cancelling feature was so good and reliable they’d do it in a heartbeat, the sales would be huge).
3) Noise cancelling removes noise, then the music adds it back.
For most wearers, if the noise-cancelling reduces external noise levels then the music playback will add that noise back in again. Their hearing will be damaged and unfortunately for the employer, they’ll end up still liable for the hearing loss.
More information
There is a lot more information on the use of noise cancelling headphones at work on this page.
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Over-protection means hearing protection is too strong for the noise risk, and yes, that is an actual thing…
Over-protection often comes from well-meaning employers buying the strongest hearing protection they can find. They mean well but it often actually increases risk and for the employer, means more of the money they spend on hearing protection is wasted.
The issues with over-protection
When hearing protection is too strong people feel isolated, so they simply don’t wear ir, or only put it in loosely. They are then at risk of noise damage whereas with less powerful protection it can be worn properly and the risk controlled.
Don’t believe the manufacturer hype on high SNRs
A lot of the less established hearing protection manufacturers market their hearing protection is being strong, or the strongest on the market. These are usually the off-brand Del Boys selling on Amazon frankly, they don’t really know what they are selling and just go on strongest is best. Not only them though, Screwfix sell their own brand hearing protection and don’t seem to have a clue about what they are selling either if they Customer Services are anything to go by.
Stronger is not better. Indeed stronger is often worse.
There is a separate page giving more information on this.
Link: Over-protection issues
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This one is an easy simple answer - no, no and thrice no. Ear plugs do not cause tinnitus or make tinnitus worse.
There are a few reasons which play a part in the perception of ear plugs causing tinnitus:
Someone starts wearing ear plugs and then notices tinnitus in their ears, but this is more often than not because they are now blocking out a lot of the external noise which they would otherwise be hearing, even at night, meaning what they are left with is the noise inside their ears. This can mean the first time people notice tinnitus is when they wear ear plugs as up to then it was always being drowned out. The tinnitus is then linked with the ear plugs.
Often, when people start wearing ear plugs it can be the first time they really think about their hearing, and when people do that, quite often they realise there there is actually a gentle hiss there all the time which they hadn’t noticed before. Again, as this has been noticed at the same time the ear plugs started being worn, the tinnitus can then be linked to the plug.
Temporary tinnitus can come and go a lot. If someone has had ear plugs forced on them at work then they may be a little resentful of it, and then when a bout of tinnitus naturally occurs, they link it to the ear plugs.
Tinnitus has many many causes. Lack of sleep, anxiety, depression, stress, caffeine, infections, a cold, a side-effect of a lot of medication, and on and on. One of the very common causes of tinnitus is simply getting older. Generally people look for a specific cause for something and look for an action or product which can be pointed at to say ‘that caused it’. As ear plugs are almost never the most welcome of devices, the finger naturally gets pointed at them, when in reality the fact ear plugs are used is nothing more than coincidence.
Ear plugs go in maybe half way down the ear canal, and are a long way from any of the more sensitive areas of the ear where damage can potentially cause tinnitus.
Conversely ear plugs may prevent some kinds of tinnitus.
Ear plugs can help stop tinnitus getting any worse if it is being caused by repeated exposures to high noise levels, by which I mean noises over 85dB(A), the kind of noise levels where you start to have to raise your voice or shout gently to have a conversation with someone.
If you don't have that kind of regular exposure though then ear plugs will be of no help at all in stopping you getting tinnitus, but won’t cause it either.
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Most foam ear plugs are use-once, so no.
Firstly, if there is nowhere to put the ear plug when it it is taken out, it can’t be reused. You can’t put it in a pocket or on a table or something and then back in the ear as that’s a route to an infection.
Secondly, foam plugs are designed to be used once and with repeated use get less and less effective. They don’t expand as well so don’t seal as well and their noise attenuation drops.
If an employer wants people to reuse ear plugs then buy the washable silicone styles which come with a small carrying case so the plugs can be kept clean when not used, and washed before reuse.
We have a further page on this giving a comparison audiogram for new vs reused ear plugs.
Link: Reusing foam ear plugs
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No, ear plugs do not cause ear infections. That is simple and unambiguous.
Putting dirty ear plugs in will cause infections so no taking them out, putting them in a pocket, and then putting them back in the ears unless they are a silicone type and can be washed first.
Dirty hands putting the ear plugs in will cause infections. Having a good scratch of the Gentleman Jewels then getting hold of the ear plug and rolling it about in the fingers and shoving it into an ear will cause infections.
Ear plugs do not cause infections - how someone uses them causes infections.
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A short answer to this one, no.
There are a couple of reasons.
Firstly, the employer has a duty to protect employees where they possibly can and they cannot set this obligation aside. A disclaimer doesn’t free the employer from this obligation to protect the employee if it is within their power to do so.
Also, it is not an agreement between equal parties. For example, assume it was legal for an employee to sign a disclaimer that they accept any risks and to then not wear any PPE. (Not only hearing protection but as if it was good for ears then it would also be good for boots, eye protection, etc.). How long would it be before more unscrupulous employers were leaning on their employees quietly saying ‘sign this and you can keep your job’?
It is simply not possible to do.
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Due to deafness
A GP can confirm someone’s hearing is so bad that further damage to noise exposure will not and cannot damage their hearing, but this is the limit of it.
Due to infections or irritation
A GP cannot exempt someone from wearing hearing protection because they say it is painful or causes infections.
Firstly, ear plugs do not cause infections - dirty hands inserting them can cause infections. Plugs taken out and put in pockets then back into the ears can cause infections. But clean, soft plugs cannot.
Despite their self-perceived omnipotence, a G.P. cannot over-rule basic law and they do not have the authority to cause someone to be at risk of developing noise induced hearing loss. This is somewhat akin to a G.P. saying a person has bad mobility problems so rather than cross a bridge over a motorway they are giving that person the authority to cross the motorway among the speeding traffic.
In addition, the choice is not a binary ‘ear plugs or no ear plugs’ choice. Improved hygiene is an option, softer ear plugs may be a choice, as are earmuffs / defenders which don’t go into the ear at all.
If someone will still not wear either plugs or defenders then relocating them to a quieter job free from noise risks is the next step to look at. If that is not possible, meaning they cannot / will not wear hearing protection and there is no quieter position available, dismissal is the only option.
A person still cannot be permitted to work in a high noise area where their hearing will be damaged, whatever a GP says. It will not be the G.P. the employee sues down the line when they have developed hearing loss from noise.
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If they are in a high noise area then not wearing it is not an option, no matter what the issue.
If they don’t like it, that doesn’t remove the need to wear it.
If it causes pain, that doesn’t remove the need to wear it.
If someone says they cannot wear hearing protection there are some steps to be followed:
Try different styles. If a silicone ear plug causes pain, try a foam one or ear muffs.
If there is no hearing protection which they say they can wear, they must be removed from the risk which means moving them to a job where there is no noise risk.
If there is no such low-noise job available, the unfortunate position is that they still cannot work in the high noise area without hearing protection, and as there are no other jobs, terminating employment is the only option.
Can GPs / Doctors exempt people from the need to wear hearing protection?
This is something we’ve seen a few times in the past and no, despite giving themselves omnipotent god-like powers, a GP doesn't have the power to over-rule the law and say someone can work in a high noise area without hearing protection.
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Sure, there is nothing to stop this.
An employee may have bought hearing protection with music playback features, e.g. ISOTunes so want to use them.
An employee may have personally moulded ear plugs from somewhere else and want to use them.
They may just have a style of ear muff they like
The employer should ask for confirmation of the SNR for the protector and then do the normal calculations to ensure it is suitable.
Personally-moulded styles
One extra step here - ask for proof of how old they are. As the ear canal keeps growing and changing shape, once they are about five to six hears old they no longer fit as well and their noise attenuation drops off. We would recommend no personally moulded plugs older than about six years are permitted.
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When it comes down to a simple ‘can they do this’, then yes, they can, there is nothing in law to stop it. However, the HSE don’t like it.
HSE statement on ‘don’t make hearing protection compulsory where the noise levels do not need it’.
Our comments on blanket hearing protection policies
Blanket hearing protection policies are not great as they tend to mean people end up wearing the protection in areas where it is not needed. In the short term it is generally not an issue, but in the longer term it can become a hindrance and possibly even increase risk.
Over time, the knowledge that they are wearing hearing protection on jobs which are actually quiet often erodes the importance of it, and that then impacts places where there is a genuine risk. Move and more people start to not wear it as they know it is not really needed and it interferes with things like them talking to others or hearing equipment such as forklifts, and you end up in a situation where it is seen as a hindrance rather than a necessary safety measure. Compliance drops.
Then there are occasions where there is a genuinely high noise risk but people aren’t wearing it, meaning that over time they are at increased risk.
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Short there: is no exemption from the need to wear hearing protection for forklift drivers.
High noise will have the same impact on them as on any other person.
Their hearing will still be damaged by noise
If a FLT (Forklift truck) driver routinely goes into a high noise area to the extent that their daily exposure is exceeding 85dB(A) then they are at risk of noise induced hearing loss. This means that over time their hearing may start to deteriorate through the effects of the exposures and they will eventually no longer be able to hear the screams of their victims as they run them over anyway, even without hearing protection.
They may need different, less powerful, protection
FLT drivers should be looked at closely though as it is particularly important that they are not provided with too much protection and isolating them. What they need is a protector which is getting them down to about say 77 or 78dB under the protector so they are safe from possible hearing loss but also still able to hear what is going on around them at a decent level.
Or provide a FLT with an enclosed cab that reduces the noise to a safe level without hearing protection.
Good choices for Forklift driver hearing protection
Some standard ear plugs which have reasonably low attenuation (noise reduction) are:
E-A-R Ultrafit 14, SNR of 14 (a reusable product and around £2.50 or so)
Alpha Sota L1 muffs, SNR of 18 (about £17)
3M ClearEar, Tracer 20, Ultrafit20 (all are cheap and have low SNRs of 20dB)
Howard Leight Neutron, SNR 20 (reusable corded plug, about £1.20)
Perhaps one of the best choices though is a banded plug style which are easy to put on as they don’t require the same insertion as an ear plug, but as they are small don’t get in the way like an ear-muff. With those the Forklift driver can have them around their neck when in lower noise areas, and easily put them on when needed but they don’t dig into the chin when round the neck and limit movement. Some styles are:
E-A-R Caps banded plugs
E-A-R Flex 20
NoiseBETA Foam Earpods Band
Ultimate Industrial UC-EP07B Earbands
Arco Banded Earplugs
Beeswift B-Brand Banded Ear Plug
Moldex Pura-Band
One exception which may apply
The Noise Regs say that hearing protection is needed by those who have a noise exposure which is routinely exceeding 85dB(A). The Regs also then say that areas where this happens should be marked with the blue and white signs as mandatory hearing protection zones. That is actually rather contradictory as one is saying it is time-based while the other is saying it is location-based and this could come into play with our FLT driver.
Assume you have an area where employees are routinely exposed to 88dB(A) so it is signed as a mandatory hearing protection area. Your FLT driver meanwhile largely works in the very quiet stores area and only occasionally goes into the higher noise level work area, maybe for up to an hour a day in total. In this case, the FLT driver's noise exposure will not come close to the 85dB(A) limit so technically, according to the Regs hearing protection is not needed, even though another part of the Regs say the zone must be signed as a mandatory hearing protection area for anyone in there. If you could guarantee that the FLT driver never spends long enough in the high noise area to breach the 85dB(A) limit then there is an argument that hearing protection is not needed, but this is based on noise exposure duration rather than a blanket exemption due to the fact they are a FLT driver and would apply equally to a pedestrian as it would a FLT driver. This could be covered in the noise risk assessment for you but if in doubt as to the duration of any possible FLT driver noise exposures, stick to the principle of hearing protection being needed in all areas zoned as having high noise levels.
L108 and talk of exemptions from hearing protection
L108, the HSE’s bible on noise safety, does contain a provision that exemptions may be granted by the HSE for specific individuals because the use of hearing protection introduces a larger risk. There are some important stipulations here though.
This exemption can only be granted by the HSE themselves, companies do not have the authority to do it. To do so is very naughty.
Any exemption has to be in writing, for specific jobs, and is time-limited. i.e. it expires.
It will only be granted where the risk caused by hearing protection is large, such as working on busy public roads. It is not something which can be used for FLT drivers as the risk can easily be controlled via proper suitable hearing protection which ‘takes the top off’ the noise but doesn’t isolate the driver. As there is a suitable control route, exemptions aren’t granted to all FLT drivers.
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Hearing aids are a particular problem when it comes to wearing hearing protection. The issue is that a lot of people with some form of hearing loss can still have their hearing made worse by excess noise so the fact they have hearing aids doesn’t mean noise won’t damage their hearing even more.
For example, there are many forms of ‘deafness’ and their cochlea may still perfectly fine, which means it can be damaged by excess noise in exactly the same way as anyone else with normal hearing.
This is critical in that not only can their hearing be made worse by excess noise, there is a good chance that the impact of that loss is disproportionately greater in them than it would be for someone with ‘normal’ hearing. A 10dB reduction in hearing ability for someone who has a limit of hearing already around speech volumes could have a life-changing impact, while a 10dB reduction for someone with perfect hearing will be negligible.
In many cases the duty to ensure hearing is protected is even stronger in someone with existing hearing loss than it is for people with normal hearing.
We have a page going into this in more detail.
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These are getting increasingly common and have correspondingly lower prices, and nothing wrong with them at all with some very good ones on the market now. But an awful lot of crap on the market as well.
From a work perspective, there is nothing to stop hearing protection with music-playing features being worn in high noise areas, as long as it is certified as hearing protection (so will have an SNR figure assigned) then it is OK to use.
There are benefits to the company as well. Usually, this type of protector has far better compliance with being used as the employee is getting a discernible benefit too.
There are no issues with someone becoming isolated and unable to hear other sounds around themas the music playback has an upper volume limit, at least at 85 dB(A) but often even lower than that. That’s quieter than shouted warnings, alarms, etc.
Recommended types:
ISOTunes have a range of in-ear and over-ear styles. Not overly expensive, comfy, all-day battery and good quality music playback. These are what use on noise assessments - the ISOTunes Air Defender.
3M Worktunes, again, good quality music playback, comfy and good battery.
And to avoid
Don’t get lured in by some of the absolute garbage on places like Amazon. Prohear, Protear, etc have abysmal sound playback reminiscent of a 1980s walkman in a biscuit tin. Uncomfy and just terrible. Same with some of the rebranded stuff like Clas Ohlson’s.
Also, if a company is selling on Amazon in the UK while listing the NRR rating, avoid them. NRR is irrelevant here and a good sign they have not got a clue about what they are selling.