Managing noise in the workplace to minimise the risk of damage to employees’ hearing can be a time-consuming task, particularly in large organisations with myriad sites and working practices. Jim Smith discusses how a strategic risk assessment approach can work best in such environments.
The Control of Noise at Work Regulations 2005 (the Regulations), which came into force on 6 April 2006, implemented the European Union’s Physical Agents Noise Directive in the UK and, compared with the previous regulations in this area, placed additional duties on an employer in respect of the management of risk from exposure to noise.
This provides for an alternative approach, where appropriate, to the wholesale measurement of noise levels and/or assessment of an individual’s exposure, with which industry was familiar under the previous regulations.
To some extent this now helps large organisations, which may have previously found it impractical to implement widespread measurement programmes, to properly target their resources. By large organisations I refer to those that have to contend with a significant number of sites, or assets of varying size and complexity.
Throw into the mix a large variation in the numbers of resident and visiting staff, and it quickly becomes apparent that it may not be practicable (and perhaps unnecessary) to assess individual staff exposure patterns, or individual sites, especially through noise measurement.
There is little point in undertaking a detailed assessment of just a small number of staff, when implementing a blanket approach based on the results could effectively place the majority of remaining staff at risk.
By drawing up a suitable programme of management instead, based on strategic risk assessment, large organisations can better protect employees’ hearing. Staff can be trained to identify potential hazards by employing simple techniques such as those outlined in the HSE’s guidance to the Regulations,1 which, for example, advises on assessing workplace noise levels through simple ‘listening checks’.
This helps move the emphasis from measurement to judgement and awareness of risk, and encourages continued dialogue between employers and employees to promote cognisance and reporting of potential hazards through training and health surveillance.
The following approach to building a risk management plan has been successfully followed by a major utility company, and a similar approach could be used by other large organisations, suitably tailored to their particular needs.
Noise risk management planning
The first step is to draw up a high-level plan that clearly identifies the elements of work required to provide a hearing conservation programme. Implementation of the plan involves undertaking the risk assessments required by Section 5 of the Regulations.
A Strategic Risk Assessment (SRA) is then used to manage the risks and to ensure that those sites (specific and/or generic) and staff at greatest risk are quickly identified and their needs addressed. An SRA carried out across all of the organisation’s assets can identify, on a risk-prioritised basis, areas where more detailed, site-based risk assessments are required.
(Sites essentially fall into two broad categories: those where there is considered to be an immediate risk to hearing, and those which are ‘typical’ examples of the wider selection of sites. Findings from the latter would be used to estimate likely exposures for similar sites.)
Analysis of historical noise data (and equipment datasheets), and assessing the results using the criteria stipulated in the SRA, can provide information to help determine priorities. Where it is identified that survey work is required, the SRA confirms which sites require assessment, as well as the assessment methodology and reporting mechanisms.
This should lead to the production of a register of specific sites to be surveyed (categorised and grouped geographically, where appropriate, to promote sustainability in terms of safety and the environment); procedures for assessing risk exposure on a site-by-site basis; and recording and reporting of those procedures.
Site-specific risk assessments should ultimately allow decisions to be made in respect of rolling out further risk assessments, or applying noise-control/risk-management strategies at all other similar sites/asset types, thus freeing up health and safety staff resources and minimising overall risk. To this end the Strategic Risk Assessment might result in:
Based on an initial risk assessment it may be appropriate to assess staff based at the larger, more complex sites, as these employees are likely to be most at risk of exposure to noise. In addition to site size, complexity and staffing levels, other examples of drivers for assessing risk include:
Methodology
Given the potential resource difficulties a large organisation may have in carrying out site-specific assessments internally, it may be appropriate to contract out this work. This potentially allows more sites to be assessed in a shorter time, thereby minimising risk and ensuring that in-house health and safety staff are able to concentrate on other duties.
Contracting out to several firms should allow a larger number of sites to be reviewed in parallel. However, in this case, it is essential to manage the project properly to ensure that commonality in terms of survey methodologies and reporting procedures is strictly observed. To this end, it may help to develop:
€ﾢ pre-requisites for contractor qualifications to demonstrate competence;
€ﾢ pre-requisites for measuring equipment specifications;
€ﾢ a programme of ‘shadowing’/auditing of contractors;
€ﾢ survey report pro-formas and a defined programme of reporting (e.g. daily, weekly, etc.);
€ﾢ policies and procedures for:
1 arranging surveys and liaison (it is essential to have a knowledgeable site operator as ‘chaperone’, to advise on working practices, equipment duties, site-specific health and safety issues, etc.);
2 reporting and re-arranging aborted/cancelled surveys and any compensation claims;
3 accelerated and prioritised reporting of noise and general health and safety hazards;
4 installation of signage (it may be beneficial for contractors to carry appropriate noise-warning and mandatory hearing protection signage for immediate installation, once noise levels are determined);
€ﾢ best-practice survey/measurement methodologies, including details of information to be recorded and notes on any existing noise warning signage and its appropriateness;
€ﾢ data-gathering and transmission tools, including:
1 Portable Digital Assistant (PDA) software, which can interface directly with certain types of sound-level meters;
2 procedures for uploading data using Internet file transfer protocols, etc;
3 automated methods for generating standard-format summary reports;
4 methods for identifying equipment noise trends;
5 accelerated reporting of noise and other health and safety hazards, and monitoring site progress;
6 GIS tools for selecting appropriate assets/sites in order to limit travel times, thereby reducing risk of road-traffic accidents and environmental impact.
€ﾢ new or continued use of noise-measurement/survey databases with inclusive GIS data. The database should be useful in quickly identifying trends.
Where evaluating personal exposure is considered impractical, it may be more appropriate to undertake site risk assessments based on measured workplace noise levels, combined with assumed (foreseeable worst-case) employee exposure times.
On this basis, equipment noise levels could be taken to be indicative of possible staff noise exposure for direct numerical comparison with the action values and exposure limits defined in the Regulations. This would represent a worst-case approach, based on workplace noise levels and worst-case assumptions about possible exposure duration (generally assumed to be daily exposure).
In many cases, this will represent a worst-case approach in terms of assessing and managing potential risk. However, it should help accelerate the process of managing the risk — for example, through signage, awareness training, or implementing noise-control measures, whether through general maintenance, or replacement equipment, etc.
Arguments for action based on sample workplace noise levels, as opposed to establishing individual worker noise exposures, are that it is quick, simple, and limits employer vulnerability to compensation claims. It also limits risk to non-permanent staff, such as contractors, visitors, students, etc. who could potentially be exposed to short-term/impulsive, and potentially damaging, noise levels — a general requirement under the Health and Safety at Work, etc. Act 1974.
Conclusion
In an ideal world it would be possible to establish with confidence the daily or weekly personal noise exposures for each and every member of staff to help target noise-control resources. This, however, is often simply not practicable and could even be of significant detriment in large organisations, where, even with the best of endeavours, resourcing individual assessment could lead to placing the majority of staff at risk for some time.
The strategies outlined above have been successfully employed by a major utilities organisation and it is hoped that the implementation of similar strategies, where appropriate, could allow other large organisations to avoid the pitfalls identified, and promote a robust and expeditious programme of hearing conservation.
Reference
1 HSE (2005): Controlling noise at work (L108), ISBN 0 7176 6164 4, HSE Books; Noise at work (INDG362 rev1) — free leaflet available by clicking here
Jim Smith works for Arup Acoustics and is an active member of the Institute of Acoustics, on whose technical committee he sits.
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