Rank: Super forum user 
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Good evening all,
Simple question, we all know about the exposure levels contained in the NAW regs and the requirements needed to be carried out at certain action levels.
I carried out a noise assessment for a particular area in my factory with 3 results having an leq of 84.3 and one having a result of 84.8. I know technically the upper limit is 85dB(A) but feel that being so close to the 2nd action level that the area should be a mandatory HPZ.
I know my peers will be looking at the fact we are under 85 and we are ok, but surely employers should be going that bit of an extra mile and set their own 2nd action level say, 83db(A)?
So, the question is... what level does your employer set to be a madatory hearing protection zone?
Thank you in advance.
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Rank: Forum user
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Hi Guru
If you are getting an 8-hour (or weekly) leq of 84, then of course some of the time it is probably exceeding 85, and some damage is being done, if only for short intermittent periods. My recommendation is to make it a HPZ, and explain why to everyone - after all, it is not going to cost a fortune to introduce hearing protection (which you would have to have available anyway once you go over 80dB) and some signs.
But can you combat the sound at source eg enclosures/screening/damping, before you make it an HPZ?
Regards
Jon
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Rank: Super forum user
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Thanks for your reply Jon,
Yea, the assessment is over an 8hour shift, and I agree that I cant guarantee that their exposure doesn't cross over the 85dB(A) threshold.
We already stock suitable ear defenders and would not incur an costing for the introduction of an HPZ. My only concern is that my peers will see its less than 85 and be quite happy not introducing such a protection zone, and during talks are very reluctant to making this area a mandatory HPZ.
I can see no way round in reporting back to the senior management team that we have no choice.
We have got a couple of companies in to providing noise reduction options, however most option will require significant investment and cant see it happening any time soon.
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Rank: Super forum user 
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Guru, you say that you got 3 readings, but only publish 2, I wonder what the other was? You say that you have measured an leq but then say this was over an 8 hour shift, so I wonder if you have really measured an lepd. I wonder if you could briefly explain your methodology?
I am not sure of the necessity of setting your own second action level, OMG, I mean upper exposure action value, at 83 when it is clearly set at 85, and that is lower than it used to be under the 89 regs. There is quite some difference between 85 and 83.
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Rank: Super forum user
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Hi Phil,
I carried out measurements using 4 doesbadges on 4 employees. They worn them over their 8 hour shift and I collated the information using the software supplied with kit.
As you'd imagine, there was tons of info generated and I was given a leq value for each person measured. the results were..
84.3 for 3 employees and 84.8
Should I be happy with this result and allow employees to be exposed so near to the 2nd action level? or should I play it safe and recommend a mandatory HPZ? Gut feeling is I should push for a HPZ, but the difficulty is management will see the fact we are under 85, and case closed.
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Rank: Super forum user
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Just a few things Leq and Lepd are quite deferent. Leq noise levels are logarithmic, and therefore as Phil has indicated there is quite some difference between 83 and 85db. Although the wearing of dosebadges may indicate individual person’s exposure levels, it may not indicate the source of the noise itself, which is an important part of the assessment procedure. The object of the exercise is to reduce the noise levels as much as is practical and not by going the other way and lowering the action level to however you see fit. Have you considered the people that will have to wear the ear protection or any additional hazards that they may present movement of vehicles, not hearing alarms, ear infections etc.
Identifying and control of the exposure source and continuous health surveillance may be an answer opposed to the compulsory wearing of ear protection.
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Rank: Super forum user
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Thank you everyone with your kind advice,
we have identified the main offenders withing the area and for us to move forward an address these will require some investment.
Money will be allocated for this, most likely next year, but in the mean time I believe going to a MHPZ is unfortunate, but the only way to go after the results I mentioned.
A queston.....should I be happy that we are under 85, albiet just, and carry on as normal unit we have the budget in place to address the issue? Or should I be sitting down with the management and recommend that unil such time the budget is in place we should make this area a MHPZ?
Personally I think the latter, but I value the opinions of the pros out there and open to direction.
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Rank: Super forum user
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Personally I am not a fan of blanket HPZ as they are (IMO) lazy if not absoultely necessary and promote non-compliance.
Remember that creating a HPZ demands that anyone and everyone entering that zone even for a few minutes has to put on hearing protection. Managers included and that sort of action does not go down well with staff and will promote non-compliance. Wearing hearing protection is not just an easy option. Most people dislike weraing hearing proetction for many reasons and if you are using those (horrible) foam jobs they won't be wearing them properly. HPZ is mandatory so are you prepared for having to enforce that (when people probably see no real reason for it in the first place)?
You have sampled hearing exposure of 4 employees, with various results. That is not enough to impose a HPZ in my opinion. If you have a noise problem then you need to get a noise survery, which will identify which employees (if any) require mandatory hearing protection and whether a HPZ is required.
Also do not forget the Regs specifically state that hearing protection is not the solution, reducing the noise at source where possible is.
From what you have said I would not support your notion to put in place a HPZ. Get a noise survey, reduce noise where you can, where the second action level is exceeded then compel certain jobs to be mandatory hearing protection, if below the second action level then give staff training on noise so they can make the choice themselves.
Don't impose a HPZ for everyone just becuase one or two employees may be close to the second action level. You could be creating a whole load of trouble IMO.
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Rank: Forum user
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It is a situation where it very much depends on the activites and operations. At the levels you are recording you would have a difficult job to defend not putting in place a HPZ as you have said it is unlikley you can afford noise reduction measures. As already previously identifed you are without doubt already having some time above the 85 level to get those averages.
Get your argument well prepared for your managers - some of the responses here are good to quote coupled with the regs. You may be surprised by their response.
If not legally then look at the moral argument. Perhaps wont work with your management but get them to also think about trying to defend it in a civil claim!!!
We have a press shop where we have sound booths around the presses, but still the noise is at a level where hearing protection is required. In consultation with our Occ Hygienist we did in this area put in place a HPZ. Interestingly the employees did not kick up a fuss and managers were supportive but we did good quality communication and Q and A sessions. We now have good discipline to ensure all employees entering the area, no matter for how long wear their ear defenders and employees who work there are quick to pick up offenders!!!!. We have placed dispensers in all convenient areas. The employees have been involved in the selection of ear protection so they cannot say the types we have specified do not suit them.
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Rank: New forum user
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From the HSE Guidance (L108). Para 44. If you assess expsoure as being close to an action value then you should proceed as if the expsoure action value has been exceeded...
Para 43. You are not required to make a highly precise or definitive assessment of individual employees' noise expsoure...
Hearing protection use is best targeted at the tasks and activities that contribute significantly to the noise exposure - in preference to blanket hearing protection zones. So find out what exactly is the significant cause (assuming that it not the case that there is just a constant level of noise).
As others have pointed out, look in to techncial and organisational control measures at the same time.
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Rank: Forum user
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Noise measurement is tricky, and if these were my readings I would round them, and only be quoting 85 dB(A)
As a consequence you would be looking at a HPZ.
However, I would strive to make changes to avoid having to impose a HPZ. As well as all the good reasons mentioned above, the use of HP at these levels has the risk of over protecting the workforce, making it difficult to hear warnings and other useful noise – like the sound of the machines. Training and discipline will also need considering.
As has been said, your 8 hour average will be made up of periods above 85 dB(A), and periods below. Can you increase the periods of quiet? (e.g. where they have their breaks). Can you reduce their periods of high exposure (e.g. you say you already know the main noise culprit – even staying a greater distance away from it may give you the opportunity to reduce to ‘safer’ levels). Job / task rotation may also work. A combination may give you the breathing space to do your engineering solutions.
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Rank: Super forum user
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Thank you all for your kind advice,
The last thing I want to do is impose a blanket HPZ. These results may give our management a wakeup call and start to take the issue seriously rather than the 'not too bothered attitude' I have had thus far.
I will sit down with the management team and have a chat about the right direction to follow, ensuring they understand what the law says.
The Joys!
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Rank: Super forum user
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In an area that has been assessed after dosebadge testing shows that employees exposure is close / exceeding 85dB(A) the NAWR states that the area should be made a MHPZ. And until such time that through engineering controls we can get below this level it should remain so.
If the area is used as a main thoroughfare for access to other areas, can you allow those passerbys to move about without using HP?
I'm of the opinion that the answer is no, however I agree that the chances of passerbys reaching anywhere near the 2nd action level is unlikely.
this arguement was put before me and I need to know where companies stand with MHPZ and passerbys. Is it permitted?
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