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Posted By Dave Adams CMIOSH
Under the 2005 noise regs (7(3)) if an area is above the upper exposure action value (85 dB(A))it must be designated as a hearing protection zone (HPZ) and appropriate signage applied. The regulation also says that the employer shall ensure SFAIRP that no one enters the HPZ without hearing protection.
This is perfectly reasonable for those who are permanently in this area as the exposure limits are dose / time related. However, is this reasonable for all persons who may enter the area for 5 minutes say. With an ambient level of 86dB(A), these people will not be anywhere near the daily limits.
The quandary is if it is signed as a HPZ then you expect compliance. If the area was signed for safety specs, footwear or hard hat you would also expect compliance. The risk of eye, foot, head damage would probably be constant so everyone stands the same chance of damage - therefore PPE is justified.
Using PPE is meant to be risk based though, a 5 minute exposure (at the 86 dB(A) level) would not be a high risk. The guidance does not help and is sending me around in circles.
Especially where it also says that making the use of PPE compulsory for workers exposed below the exposure levels should be avoided, except in an HPZ. But the only difference (for under-exposed people) is the presence of the sign.
If I had any hair, I would be pulling it out!!
Any helpful advice?
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Posted By David Whaley
Dave,
We have areas similar to the one described. We opted to enforce the wearing of hearing protection on the grounds that it was easier for managers to control, there would be no exceptions. And unless you know for sure the length of time any one individual is spending in a high noise area you could be exposing them above the limit.
We have several high noise areas and people can move between them i.e. maintenance staff. When in doubt er on the side of caution.
Hope this helps.
David
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Posted By Geoff Ferneyhough
Dave,
In our Noise Prtotection Zones's we enforce mandatory wearing of hearing protection:
1. It's easier for the Supervisors / Managers to control.
2. We don't get into the discussion of why do I have to wear them when he doesn't.
3. How do you know those entering for a few minutes at at a time don't go in every hour or so for a few minutes, thus radically increasing their daily exposure.
Since you can't effectively control exposure times or noise levels the most effective method is to ensure that hearing protection is worn in all Noise Protection Zones.
Regards
Geoff
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Posted By Robert K Lewis
Dave
You have no options on this once it is necessary to define the HPZ. No person, sfrp, shall be permitted to enter without HP. For me the sfrp is about the limits of control that a company can exert over the actions of employees. Thus to erect signs but not to make any attempt to enforce use would not meet the criteria of sfrp.
As David's post suggests you cannot know the exposure of anyone individual and must therefore mimnimise all exposure potential above the limits.
Bob
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Rank: Guest
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Posted By Dave Adams CMIOSH
David, Geoff & Bob
Many thanks for your wise words. Good points, well made.
On re-reading reg 7(3) again it is clear that HP is mandatory and that there should be no execeptions.
Thanks fellas
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