Noise Toolbox Talk

The injury nobody notices happening

There is no pain, no bruise and no bad day to point at. Noise-induced hearing loss arrives as ringing in your ears on the drive home, then as asking people to repeat themselves, then as losing a conversation in a pub while everyone else follows it fine.

By the time it is obvious, it is permanent. HSE describes the damage as permanent and disabling, and there is no treatment that gives it back. Tinnitus, the ringing or whistling that comes with it, is often what people notice first and what keeps them awake afterwards.

Most site trades are already over the line

This is not a talk about unusually loud jobs. HSE’s own figures for construction put angle grinding and cutting at 90 to 110 dB, carpentry and formwork at 92 dB, piling from 85 to over 100 dB, and dumpers and rollers at 85 dB or more. The upper action value, where the law requires hearing protection to be provided and worn, is 85 dB.

What the law requires

The Control of Noise at Work Regulations 2005 work off three numbers: two action values that trigger duties, and one hard limit. The important subtlety is that hearing protection counts towards the limit but not towards the action values. You cannot hand out earplugs and declare the problem solved.

• Assess the risk. Where anyone is likely to be exposed at or above the lower action value of 80 dB, assess it using observation, equipment data and measurement where needed. Noise Regs 2005, reg. 5.
• Control it at source. Eliminate the noise or reduce it as low as reasonably practicable. At the upper action value you need a planned programme of organisational and technical measures. Noise Regs 2005, reg. 6.
• Protection and zones. Provide hearing protection on request at 80 dB. At 85 dB provide it, make sure it is worn, and mark out hearing protection zones with restricted access. Noise Regs 2005, reg. 7.
• Surveillance and training. Provide health surveillance where the assessment shows a risk, and tell people what the risks are, what the values mean, and how to spot damage early. Noise Regs 2005, regs. 9 and 10.

The numbers worth carrying in your head

• 80 dB lower action value, with a peak of 135 dB(C): assess, inform and train, and provide protection on request
• 85 dB upper action value, with a peak of 137 dB(C): protection provided and worn, zones marked, and a noise control programme
• 87 dB exposure limit value, with a peak of 140 dB(C): must not be exceeded, and this is the only one where protection counts
• 2 m: if you have to shout to be heard at two metres for more than about two hours a day, you are probably at 85 dB or more

Source: The Control of Noise at Work Regulations 2005; HSE, Noise at work: a brief guide (INDG362); HSE, Assessing noise risks in construction; HSE, Controlling noise at work (L108).

Where the noise comes from on site

• Angle grinding and cutting. HSE puts this at 90 to 110 dB. One of the commonest jobs on site and one of the loudest things anyone does all day.
• Carpentry and formwork. Around 92 dB, well above the upper action value, and rarely thought of as a noisy trade.
• Breakers and concrete work. Chipping, drilling and grinding concrete all sit at 85 dB or more, before you add the room they are in.
• Piling. From 85 dB to over 100, and it carries right across a site to people who are not involved in it at all.
• Plant. Dumpers and rollers run at 85 dB or more, all shift, every shift.
• Somebody else’s noise. You do not have to be holding the tool. The trades working alongside the grinder get the exposure with none of the protection.
• Peak noise. Cartridge tools and heavy impacts produce sudden peaks, and those have their own separate limits at 135, 137 and 140 dB(C).
• Protection taken off for a minute. It only works while it is on. Short gaps in a loud task undo a surprising amount of it.
• Too much protection. Over-protecting isolates the wearer so they cannot hear a reversing alarm, a shout, or the machine going wrong.
• The first signs get ignored. Ringing in the ears after a shift, or the telly going up a couple of notches, are the warning rather than the aftermath.

Controls to brief your crew on

• Buy and hire on noise, not just price. Ask for the noise data before the kit arrives. It is the single biggest lever anyone on this site has.
• Change the method. A block splitter instead of a cutter, bolted instead of cut, materials ordered to size. Quieter work beats quieter tools.
• Put distance and screening in. Noise falls off with distance, so move the work, move the people, or put something solid between them.
• Time the noisy jobs. Do them when fewest people are around rather than in the middle of the shift alongside everyone else.
• Rotate and limit. Sharing a noisy task across a crew reduces each person’s daily exposure, which is what the action values are based on.
• Maintain the kit. Blunt discs, worn bearings and missing guards all make a machine louder than it needs to be.
• Mark the zones and mean it. Where the upper value is likely, sign the area, restrict access, and expect protection to be worn inside it.
• Pick the right protector, not the strongest. Enough attenuation for the level, comfortable enough to keep on, and still able to hear alarms and speech.
• Wear it for the whole task. Fit it before you start and take it off after you finish, not during.
• Take up the hearing checks and report ringing early. Surveillance is yearly for the first two years above the upper value and every three years after, and it catches damage long before you notice it.

Source: HSE, Noise at work (INDG362); HSE, Controlling noise at work (L108); Noise Regs 2005, regs. 6 to 10.

Who is competent to do this work

• Whoever carries out the noise assessment must be competent to do it, and it has to reflect the work as it is actually done rather than the quietest version of it.
• Whoever selects hearing protection needs to match the attenuation to the measured level, and to understand that over-protection creates its own risk.
• Health surveillance is run by a competent occupational health provider, with audiometry carried out by someone trained to do it.
• Everyone exposed above the lower value is entitled to information and training on the risks, the values, the protection and the early signs of damage.

Paperwork that should be in place

• The noise risk assessment, current for the work actually being done, with the significant findings recorded.
• The noise control action plan where anyone is exposed at or above the upper action value.
• Records of hearing protection issued, including the make, model and attenuation.
• Health surveillance records, yearly for the first two years above the upper value and every three years after, with any referrals acted on.
• Training records covering the risks, the values and how to wear the protection.
• Equipment noise data from manufacturers or hire companies, used when kit is selected.

Five questions to get the crew talking

1. Which job on this site is the loudest, and who is standing near it who does not need to be?
2. Do you have to shout to be heard at two metres anywhere here?
3. Is anyone getting ringing in their ears at the end of a shift?
4. Can you still hear a reversing alarm with your protection on?
5. Could any of this week’s noisy work be done a quieter way, or at a quieter time?

How to run this toolbox talk

1. Read it first and add your site detail: which tasks, which plant, which areas should be zoned.
2. Pick the moment. Start of shift, at the workface, ten minutes maximum.
3. Try the two metre test together while the noisy work is running, so people can hear the threshold rather than being told about it.
4. Ask about ringing directly. It is the earliest sign and the one people keep to themselves.
5. Pair it with the construction dust toolbox talk, since the same tools cause both problems.
6. Record who attended on the free toolbox talk sign-in sheet.

Frequently asked questions

What are the noise action values?

The lower exposure action value is a daily or weekly average of 80 dB, with a peak of 135 dB(C). The upper exposure action value is 85 dB, with a peak of 137 dB(C). The exposure limit value, which must not be exceeded, is 87 dB with a peak of 140 dB(C).

When does hearing protection become compulsory?

At the upper action value of 85 dB. Below that, at 80 dB, protection must be made available on request. At 85 dB the employer must provide it, make sure it is used, and mark out hearing protection zones where wearing it is mandatory and access is restricted.

Does hearing protection count towards the action values?

No, and this catches people out. Protection is taken into account when applying the 87 dB exposure limit value, but not when working out whether an action value has been reached. The duty to reduce noise at source does not go away because protection has been issued.

How can you tell if noise is a problem without a meter?

HSE gives a rule of thumb. If the noise is intrusive but you can hold a normal conversation at about 2 m, it is probably around 80 dB. If you have to shout to talk to someone 2 m away for more than about two hours a day, it is probably 85 dB or more.

How often should hearing be tested?

Where the risk assessment shows a risk, health surveillance should be annual for the first two years of exposure above the upper action value, then at three-yearly intervals, and more frequently if damage is detected. It is carried out by suitably trained people.

Can hearing protection be too strong?

Yes. Over-protection isolates the wearer, making it harder to hear speech, reversing alarms and the sound of a machine going wrong, which creates a new risk. Choose protection with enough attenuation for the measured level, not the highest rating on the shelf.