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stevedm  
#1 Posted : 27 September 2025 10:07:00(UTC)
Rank: Super forum user
stevedm

I am having a wee clear out of papers and came across an instance that I thought worthy of debate...I don’t normally post because of the trolls..but looking for intelligent open debate…lets see.

Situation is this:

  • Paint shop using a combination of several organic solvents.  Noise survey says hearing protection required (+85dBA).  Some patchy compliance, but generally all use 3m foam ear buds.
  • Hearing surveillance completed - notes a slight threshold shift in paint shop operatives. - Query solvent induced hearing loss (Ototoxicity).  Temporary measure use over the ear hearing protection to attempt to reduce ear exposure to chemicals, retest surveillance in 3 months.
  • HSE Inspector - visits site (New inspector - just finished training).  Gives site improvement notice for overprotection.  Local manager doesn't explain for fear of further notices.
  • Management team don't want the hassle so don't challenge they just comply with the notice.
  • Hearing surveillance notes permanent threshold shift in paint shop employees - so they change OH supplier...and start the records again - which means new hearing baseline for already affected employees.

I broke this down.

  • Noise Survey & Mapping – Supplier 1 – completed as required NAW 2005.
  • Hearing Surveillance – Supplier 2 - completed as required – OH Guidance/ HSE categorisation.
  • CoSHH Compliance  - In house – completed as required – COSHH 2015
  • HSE Inspector – Only looked at noise compliance  - NAW 2005.

Had Supplier 2 not done their job (You can argue that it wasn't thier job to highlight but they did) and highlighted the potential ototoxicity and suggested a solution, albeit temporary, nobody would have known (yes there is a point here that Occupational Hygiene Assessment for air exposure needs to be done, but wasn’t). 

I see lots of instances where compliance needs a number of disciplines, to coordinate and ensure employees are safe from immediate and future health impacts.  In most instances these are separate studies and relies on the employer to bring it all together, which is where, as in this case, it can fail (in this case on the surface the employer was trying to do all the right things).  It also brings in the issue of our regulator who, in this example narrowly, looked at the Noise regulation compliance. 

How do we best bring all of this together to ensure that we truly protect employees from exposure to harm, short and long term?

A Kurdziel  
#2 Posted : 29 September 2025 14:53:16(UTC)
Rank: Super forum user
A Kurdziel

Here is a review from the US National Library of Medicine  https://pmc.ncbi.nlm.nih.gov/articles/PMC4693596/  which collates information about Ototoxicity. Essentially although this phenomenon has been recognised for years detailed information about it is patchy, particularly in workplace setting where it seems hearing lose is always assumed to be related to noise exposure. Most understanding of the ototoxicity comes it being a side effect of  various types of drug treatment. Interestingly it is mentioned in EU directives as a possible source of hearing loss but not in the   Noise at Work regulations which only refer to noise. I suppose that the HSE would tell that this comes under COSHH but I have never seen it mentioned in any SDS  and there is no Hazard Statement  under GHS either relating to hearing loss.

stevedm  
#3 Posted : 29 September 2025 16:42:58(UTC)
Rank: Super forum user
stevedm

thanks AK...I think I am ok with the ototoxicity and what it means...and that is probably a red 'hearing' (sorry couldn't resist)...if companies have individual assessment and don't generally have the competence to bring them together, or just having the checks done to 'comply' and having a regulator not looking at the issues in the round...how can we protect our people from longer term harm or are we really protecting our people?  

It is a number of years ago now but particular instance caused me to walk away from the client ..and bordering on reporting the inspector (but was advised against it)...maybe all these 'ex-inspectors' would like to chip in? 

Roundtuit  
#4 Posted : 30 September 2025 08:23:52(UTC)
Rank: Super forum user
Roundtuit

Stented58 reported for adding your own link to the provided link

thanks 2 users thanked Roundtuit for this useful post.
peter gotch on 01/10/2025(UTC), peter gotch on 01/10/2025(UTC)
Roundtuit  
#5 Posted : 30 September 2025 08:23:52(UTC)
Rank: Super forum user
Roundtuit

Stented58 reported for adding your own link to the provided link

thanks 2 users thanked Roundtuit for this useful post.
peter gotch on 01/10/2025(UTC), peter gotch on 01/10/2025(UTC)
peter gotch  
#6 Posted : 01 October 2025 11:54:39(UTC)
Rank: Super forum user
peter gotch

Hi Steve

Just one of the many problems that can be exacerbated when people look at each different type of risk in isolation and don't look at the overall picture.

I do think there ARE occasions when it makes sense to focus in one type of risk on its own, as long as the findings of that assessment are then integrated into an overall assessment of working conditions.

This particular issue is made more difficult in part due to the continuing emphasis of many organisations AND their Safety Bods on treating occupational health risks as an afterthought at best.

Add in the fact that one has to play two separate numbers games - 1. What the noise exposure is and 2. What the exposure (via variious routes) to hazardous substances is, with lots of IFs and BUTs to consider and it would be very tempting to just put the issue into the "too difficult" box.

Overall I think that as a society in Britain (and other places) we continue to give far too little attention to occupational health risks, and perhaps in part that is because the rules are less easy to define as simple rules.

When the first EC Directive on occupational exposure to noise was still being negotiated I got the job of accompanying "The Minister" on a factory visit and at the end of that visit the predictable debate took place about where the "first" and "second" "action levels" should be set [but equally predictably no debate about where the "peak action level" should be set.

So the consensus would end up at 85dB(A) and 90 dB(A) each as an 8 hour Time Weighted Average at a time when the scientists were saying broadly (I can't remember the Standard Deviations on the numbers which were presumably "central estimates") if we exposed a worker to 85dB(A) for a working life of 40 hours a week, and 40 years then they had an 11% chance of sustaining significant hearing loss, with that percentage going up to 25% (one in four!!) if the level was at 90dB(A).

We would never have a debate about a machine that had a more than one in ten chance of signficantly injuring a worker if they worked on the machine for their lifetime - we would say "guard it PROPERLY"!!

In contrast there is a tendency to be less robust when it comes to the occupational ill health which might not present for months, years or decades.

Of course, a few years later than my day with "The Minister" the EC got round to negotiating a second Directive on occupational exposure to noise and the regulatory levels came down to 80 and 85dB(A) - which translates as saying that we STILL think that it may be OK to give a worker a more than one in ten chance of sustaining signficant hearing loss over a lifetime.

Which in itself is hard to swallow. You are now reminding us that there are also other factors at play. Those perhaps even easier to assign to the "too difficult" box.

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