Driving for work and noise exposures
The Control of Noise at Work Regulations 2005 apply to all workplace noise exposure risks, which could include driving for work reasons.
Key points on noise safety and driving for work
Driving often does include some level of noise risk from engine, wind and tyre noise, as well as the stereo in the car.
Vans are often louder than cars.
Engine type doesn’t really matter, electric, petrol or diesel. It is wind, tyre and stereo noise which is the issue.
If someone is driving for work then technically that is workplace noise exposure.
Measuring every exposure is impractical, as would be most actions to reduce the noise or using hearing protection. But people who routinely drive for work could be included in health surveillance programmes as a precaution.
This is one of the greyer areas of noise safety as there is no clear answer to this, but when completing a noise risk assessment, has a company included the noise exposure risks for anyone driving cars, vans, HGVs or motorbikes?
By drivers I mean any person driving as part of their job so the obvious ones like van or HGV drivers, but also anyone else driving around in a car or van for work - managers on site visits, sales reps, any person driving between sites or to customer sites, etc.
How much noise do car drivers get at work?
To see how loud noise can be when driving around I had a little play around to measure it.
I put a dosemeter on the passenger seatbelt of my car (at the time it was a bog-standard Mondeo so decent enough in terms of internal noise and quieter than a lot of smaller cars). I had the stereo on loud enough to hear what was being said on podcasts without blasting out and I measured the noise for a couple of hours while driving down the M6 in clear traffic.
It came in at 86 dB(A), and that was being quite moderate with the stereo volume, I would normally have music louder than that.
Back when I also did occupational hearing testing I had a proper bank-robber's tranny van kitted out as a mobile clinic and driving that was noticeably louder than the car on the motorway.
I also ride a motorbike for work in the warmer months and that is really loud on motorways and major A roads. After an hour or so on fast roads you start to wince when passing trucks. You can wear ear plugs to reduce the noise but do need to be careful as someone will try and kill you on a daily basis. Audis particularly have special glass in their windows which renders a motorbike invisible. Keeping a good awareness of what is going on around you is important, including hearing, so plugs can sometimes not be a great solution.
No company I have come across includes driving in their noise assessments when measuring noise as it would be an absolute nightmare to measure the noise levels in any way which is remotely accurate. Every car and van will be different, indeed every journey would depending on road type, speeds, distances, window open or closed, stereo on or off, and on and on. But, there is a good chance the noise will be such that if it was in a factory it would be a hearing protection zone.
As they are ‘at work’, the Noise Regs apply
Technically, that opens the door to the issue of people regularly driving for work possibly exceeding the daily average noise exposure limits, whether it is cars, vans, HGVs, motorbikes and scooters.
The drivers are indeed ‘at work’ and there is no specific exemption in the Noise Regs for that as an activity.
Driving to and from their normal place of work is a commute and that is outside of work and the employer’s responsibilities.
I even wrote to the HSE once asking what they did for their Inspectors as they are all driving around for work but never had a reply.
What to do about drivers and noise exposures?
Clearly, the only option is to buy everyone who is driving for work a company Bentley or something similar which whooshes along in comparative silence as otherwise it would mean people sitting there with ear muffs on...
Personally, and entirely as a personal opinion rather than legal advice so please Mr HSE, don’t jump on me and send me to share a small cell with Big Dave the Lonely Sex Pest for stating something which is not entirely compliant with the Noise Regs, but I would consider a bit of a fudge as a solution.
Measuring the noise in every type of vehicle on every type of journey is going to be impractical and verging on impossible, as is dealing with the noise itself at source. You can’t ban stereos in cars and can’t mandate ear muffs for motorway driving. Companies could however include regular drivers in their hearing testing programme so they at least track any possible changes in hearing levels. Very few companies do this but I have come across some logistics companies including HGV drivers, but not many.
That is clearly a case of catching the issue only after damage has been caused, but it could be better than nothing and may be something worth considering when completing a noise risk assessment.
FAQ: Driving for work and noise exposure
Does that mean that driving to and from work is a noise risk the employer needs to account for?
Is it a noise risk? It could be if the drive is long enough. Does the employer need to account for it? No. If you are driving to and from your normal place of work then that is not ‘at work’ so it is beyond the scope of the employer’s obligations.
Shouldn’t the employer measure the noise risk and do something to reduce it?
Technically, yes, but practically what would or could they do? They can’t measure every type of vehicle on every type of journey, and can’t really do much about the noise other than banning stereos in company vehicles which nobody would want (and people would just wear headphones then anyway which is probably even more of a risk).
I drive an electric vehicle, am I OK for noise then?
I doubt this makes much difference. If you are belting down a motorway then the main noise is the wind and tyre noise and any stereo noise, not the engine no matter what vehicle type it is. If it is an expensive electric vehicle it is probably OK but that is because it has probably been built with better noise insulation, which would also be the case for a standard engine car.
