Noise at Work - but is it always 'unwanted' noise?

There has been significant press coverage in recent months about noise at work in the leisure industry.  This has been heightened with the adoption of the EC Physical Agents (Noise) Directive, which requires stricter controls on noise at work.  The Control of Noise at Work Regulations 2005 will implement the Directive in the UK and are due to come into force on 6th April 2006, although the leisure industry has been given another two years to meet the new requirements.

Exposure to loud noise can cause permanent hearing damage, known as noise induced hearing loss.  Recent research suggests that 170,000 people in the UK suffer deafness, tinnitus (ringing in the ears) or other ear conditions as a result of exposure to noise at work.  Noise can also interfere with verbal communication, produce stress and affect performance.

There are currently 568,000 people employed in pubs, bars and clubs compared to 414,200 in 1992 and there are approximately 1,750 nightclubs in the UK.  A recent study by the Trade Union Congress (TUC) and the Royal National Institute for the Deaf (RNID) found that many people working in bars and clubs are being exposed to dangerously loud music.  In some cases, employees were being exposed to levels of 110 dB(A) - equivalent to being within two feet of an pnuematic drill. 

Before joining System Concepts, I worked in the leisure industry and experienced some of these difficulties first hand - not only in assessing noise levels but also in finding suitable control measures to reduce noise exposure.

Current Legislation - the Noise at Work Regulations 1989

The Noise at Work Regulations 1989 include three action levels.  The first two relate to the amount of noise that employees are exposed to for eight hours.  The first action level is 85 dB(A) and the second is 90 dB(A).  The third is a peak action level of 200 pascals, which is equivalent to about 140 dB(A).  There is no time limit on this level, as this can cause instantaneous damage.

The key obligations for employers are to: 

• Check employees’ exposure to noise
• Reduce risk of hearing damage to the lowest level reasonably practicable
• Reduce noise exposure if an employee is exposed to levels at or above 2nd Action level or peak action level so far as is reasonably practicable by a means other than personal ear protectors
• Provide ear protectors where noise levels are below the 2nd Action Level (below 90dB(A)).  At levels at or above the 2nd Action Level employers need both to provide personal ear protectors and to enforce their use
• Mark ear protection zones to indicate a requirement for wearing personal ear protectors before entering the zone.

The regulations also include details on maintenance and use of equipment and ensuring employees are given suitable information, instruction and guidance.

Problems of tackling noise in the leisure industry

There are a number of reasons why it’s difficult to control noise in leisure industry environments.

The usual definition of noise is ‘unwanted sound’ – but nightclub managers are quick to point out that their customers demand loud music and turning down the sound would lead to a loss of business.  But is this a good enough excuse?  There is also a school of thought that suggests that music ‘noise’ is less damaging than industrial noise.  Although there are plenty of deaf DJs and rock stars who may suggest otherwise.

The Noise at Work Regulations easily apply to those employees working within a factory environment, but employees in the leisure industry don’t tend to work set standard 8 hour shifts which can make it difficult to calculate exposure level limits.  Relaxed licensing laws in the future may also add to the problem.

This means that managers find it difficult to know how big the risk is to their employees.  But it is not only managers who are struggling; many LA inspectors aren’t given clear guidance on how to tackle risks associated with loud music.  I also found that older venues often had poor acoustic design and were unlikely to be updated.

So what can be done?

Management training is vital so that they can complete suitable noise assessments i.e. calculate noise levels and exposure times correctly, and implement practical solutions to reduce and control noise exposure, such as:

• Level setting – set an upper limit on noise levels
• Loudspeaker location – prevent hotspots by re-positioning speakers away from workstations and aiming them towards the dance floor
• Acoustic design – use absorbent materials wherever possible and include this as part of the design stage of a refurbishment
• Quiet areas – provide 'chill-out' space with lower noise levels, although this is potentially difficult in older venues where significant cost implications are involved
• Staff/job rotation – limit the amount of time spent in noisy areas moving staff around regularly
• Routine audiometry testing – ensure health surveillance of employees, particularly management and longer staying staff members
• Ear protection – this is the last resort but chosen correctly it can reduce noise levels significantly while still allowing staff to hear customers – a common complaint that is one of the reasons why it is often not worn.

As with all control measures, training and education are paramount.  Publicity aimed at the general public will also improve the understanding of the risks from exposure to leisure noise.

Ultimately, I believe the leisure industry will need to recognise the business implications both in terms of the risks to their employees and the costs of non-compliance.  Major changes in operating practices and an increased focus at the design stage for new builds and refurbishments will be needed before 2008 when the leisure industry has to meet the new Regulations.  These will reduce each of the first two action levels by 5 dB(A) – a significant decrease – for which the industry is not yet ready. 

The new regulations are available on the HMSO website at www.opsi.gov.uk/si/si2005/20051643.htm

For advice on how System Concepts can help you implement the Noise at Work Regulations, please contact us

First published Sept 2005