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Posted By Nick Gilbert
Sorry if this seems to be a very basic question but we have an area on one of our plants which has a noisy pump (~91dB(A)) at 1m. Its not an area which is normally occupied but people could walk through it occasionally. I appreciate that the area should be demarcated and signed appropriately but would it be necessary for employees to wear hearing protection for the very short time they'd be near it. Their Lep,d would normally be very low as most of their time would be spent in a control room. The Regulations and guidance that I've read refer to cases where employees are working for long periods in noisy areas where the first or second action levels could be exceeded - this wouldn't be so in this instance. Also what sign would be required?
Thanks, Nick.
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Posted By Neil Tonge
Despite the fact that employees don't work near the pump and their average daily exposure would be below the action levels requiring PPE, temporary threshold shift or other problems such as acoustic shock could happen even if exposure is brief.
I personally would demarkate the area as an EPZ and provide disposable ear plugs at the entrances to the area housing the pump. It is far better to be safe than sorry and after all once hearing has been damaged there is no cure!
Hope this helps,
Neil
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Posted By Andy
Nick,
Remebering the usual hierarchical measures, ie tackle source first;
Is the pump new or old?
Has anyone inspected it?
Is it maintained?
Is it replaceable?
If the issue can be resolved this way, it will be far easier and perhaps cheaper in the long run that issuing ear protection and enforcing it properly which sounds difficult and dont forget the other possible costs of damage.
Regards
Andrew.
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Posted By Jim Walker
I'm with Andy on this.
Noise at Work regs state noise should be at lowest practicable level.
PPE is always to control residual risk.
Maybe the pump is trying to say something like "if I don't get maintainance I'm going to die".
Some simple engineering solutions have got to be seen(heard) to believed, a bit of damping costing pennies could get that noise down tenfold.
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Posted By Paul Leadbetter
Nick
EPZs only have to be declared when the second action level is likely to be exceeded (that is what the Regs say). The second action level is 90dB(A) averaged over an 8 hour working day. If exposure times to the noise in question are very short and there are no other noise sources, then your employees' noise exposure will be under the second action level and no action is required.
Paul
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Posted By Neil Tonge
Whilst I appreciate what Paul is saying, do you want to merely comply with the letter of the law or prevent damage to your employees hearing?
If the area around the pump is not named an EPZ and for some reason (nearby maintenance work for instance) an employee spent long enough in the vicinity of the pump to exceed their daily exposure limit and their hearing was subsquently damaged, a court would take a dim view of the defence that the area was not demarcated an EPZ because the area was a throughfare and not an area people worked. Especially in light of the fact that you know for a fact the pump produces noise in excess of the second action level.
Paul is right strictly speaking but I wouldn't like to justify not putting up a sign and providing 9p disposable plugs in court when trying to defend a noise induced hearing loss claim.
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Posted By Nick Gilbert
Thanks for the advice everyone - it has helped. I just wanted to get the facts straight before advising the area manager. I'm told the pump is not saying 'maintain me I'm worn out' just 'I'm a big pump and can't help being noisy!' But that's yet to be established for certain - will recommend further investigation and some insulation if that's possible without affecting its operation.
Best Regards.
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Posted By Nick Gilbert
Sorry, couple more posts whilst I was making my last one - I can see both of the points made by Paul and Neil, when I read the Regs it does refer to areas in which the 2nd action level would be exceeded but that would seem to apply more to a work station where someone is exposed for long periods (or I guess a very high noise level for a shorter period) neither would appear to apply to this case and I've not read any guidance that advises on the correct approach when a person may only be exposed for say 30 seconds. The problem with Neil's approach is that if we do post signs and provide hearing protection we then have to enforce its use yet it would seem highly unlikely that we'd achieve very good compliance when exposure duration is so short and a high level of supervision isn't feasible. The answer really has to be to reduce the noise level!
Best Regards.
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Posted By Smurfer
I have to agree with Paul on this one. The action level is based on a time weighted average, as with OESs and MELs. What you're suggesting is even if exposure is for as little as ten seconds then RPE should be compulsory. We all know that exposure levels fluctuate dramatically about a mean - that's why OESs have a STEL and Noise has a Peak Action Level. There seems to be no reason to take the other extreme and suggest that exposure to an Leq over 10secs is the same as an Lepd over 8 hours.
Andy
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Posted By Nick Gilbert
But what happens when there's other work going on in the area such as maintenance work as Neil suggests - if there are no warning signs then its quite possible there'd be an over exposure. It seems like the signs are needed but for transient exposures, ie passers by, the requirement wouldn't have to be enforced - is that feasible?
Nick.
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Posted By Paul Leadbetter
If a mandatory safety sign is posted, its instructions must be enforced unless one wants to be accused of hypocrisy (or tail covering).
Paul
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Posted By Martyn Hendrie
I suspect that there is an element of "take action to ensure we are covered" in some of the responses.
The noise calculator in the HSE web site is a useful tool and indicates that an exposure of 91dB(A) would take 6hours 21 minutes to reach the second action level and 2 hours to reach the first action level.
I would suggest that the workers are informed and instructed of the general risk noise poses and suitable hearing protection made available for their use. Designating an area as a "hearing protection zone" and then not enforcing it could cause problem that is unnecessary.
You should ensure that you record your assessment of risk and the outcome of that asssessment.
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Posted By Tom Chen
read all the response, and suggest the following solution:
1) first try reduce noise level
2) if impossible, a post read "noise pollution area, if expose time over 2 hours, ear protection is a must"
anyway, risk assessment should be done and recorded.
Hope it helpful.
Tom
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