FEATURE WORKPLACE SAFETY
Is your noise risk assessment up to scratch?
I
t is probably fair to say that noise risks are not well understood by many industries and most
lack the in-house expertise to carry out a good risk assessment without the aid of outside help, but how do you know that you’re getting good value? How can you improve the in-house expertise so that you can at least keep the risk assessment up to date? Do you have the ability to manage the issue on a day to day basis? Because noise risks are often regarded as
difficult to deal with and the measurement equipment is relatively complex to use, most companies tend to turn to an outside agency to construct a risk assessment for them. Nothing wrong with that, but the quality of the final product varies enormously to the extent that some do not even satisfy the minimum standard required by the Control of Noise at Work Regulations 2005. So, where is the evidence for this? In 2005 I was involved in a research project funded by the HSE, entitled “Epidemiological evidence for the effectiveness of the noise at work regulations” (HSE research report RR669). My task was to visit a number of large manufacturing companies covering a wide range of sectors, to see how they complied with the Regulations. My background is in both consulting and enforcement, so I have a good idea of what to look for. Bearing in mind that these companies were
probably performing better than average in terms of noise risks, as they had volunteered to join the study, I was very surprised at the quality of the noise risk assessments they had in their possession. I visited 12 companies, and most failed to meet all of the requirements of the Regulations; two had no noise risk assessment at all and of the rest only two had risk assessments that I would regard as being satisfactory in all respects. Although the range of deficiencies was wide the most common included the lack of an action plan, actual noise exposures not being calculated, noise exposures not being related to workers, no health surveillance, and no advice on noise risk training of workers.
20 SUMMER 2020 | INDUSTRIAL COMPLIANCE
Many companies fail to meet requirements of the Control of Noise at Work Regulations 2005. In this article, Gordon Brown discusses the importance of adequate noise risk assessment and how certification from the Institute of Acoustics can help you make sure that you are compliant
Frankly, I found this somewhat shocking, as did
the participant companies because they had, in good faith, assumed that by employing outside expertise they were at the very least protected from further enforcement action or claims for noise induced hearing loss. So, how can you avoid falling into the same trap? The following is largely reproduced from the HSE Engineering Industry Noise Task Group guidance on the subject and I make no apologies for this, it contains good advice that is difficult to improve upon. High noise exposure will eventually cause
deafness, tinnitus and possibly other types of damage. Your basic duty under the Control of Noise at Work Regulations 2005 is to prevent or reduce risks to health and safety from exposure to noise at work. To do this you need to know who is at risk, and what the level of that risk is. In order to make a plan to tackle noise problems, you must know what is causing the risk (what processes, machines, etc) and the priorities for action. The key to obtaining this information is the
Noise Risk Assessment, which must be at least adequate, but how do you, as an employer, know what an adequate assessment consists of? It is up to the employer to take reasonable steps to satisfy himself or herself that the assessment meets the requirements of the regulations, even if the assessment is carried out by someone outside the company such as a consultant. The checklist in this article will help; it shows you what you should or could expect to see in three different standards of noise assessment, starting with the minimum legal requirement.
In brief, a noise assessment should: State whether you have a noise problem, Tell you which employees are at risk, and why,
Give you enough information to let you prioritise and plan the work needed to control the risks,
Let you know what to do about the immediate risk (hearing protection, warning signs),
Help you to instruct, inform and train your employees about these issues.
There are some tell-tale signs that a noise assessment is not adequate, such as:
Noise measurements do not relate to the jobs or tasks people carry out – they are simply spot readings taken around the workplace. This is a depressingly common problem!
Noise exposures (LEP,d) are not quoted.
These must relate to individual workers or groups of workers.
No reference to legal duties (Control of Noise at Work Regulations 2005) or Action Values.
No Action Plan.
No advice on suitable hearing protection for individuals or groups.
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