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Can hearing protection be taken into consideration with regard to deciding whether audiometry tests are required under Reg 9 of NAWR? The guidance is quite woolly? Paragraph 105 "If the risk assessment indicates there is a risk to health" references paragraph 31 not more appropriately 30 in the guidance I'm actually struggling with the meaning of paragraph 105 which states "Regulation 9 (1) requires you to provide suitable health surveillance where the risk assessment indicates a risk to workers' health, ie a risk from exposure to noise without taking account of the noise reduction provided by hearing protection (see paragraph 31) I'm reading this as a risk to health after hearing protection has been applied? So in a nutshell if noise measurement for daily exposure has been recorded at 86dB; and all techincal measures have been implemented in reducing noise; is health surveillance required after hearing protection worn will considerably lower the risk to health?
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you conduct health surveillance to demonstrate your applied controls e.g. hearing protection are working
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 2 users thanked Roundtuit for this useful post.
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Rank: Super forum user
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you conduct health surveillance to demonstrate your applied controls e.g. hearing protection are working
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2 users thanked Roundtuit for this useful post.
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Originally Posted by: Roundtuit  you conduct health surveillance to demonstrate your applied controls e.g. hearing protection are working
I guess I worded my query wrong
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If your RA determines noise levels require controls then you need to conduct audiometric monitoring. If you do not have noise issues at site you do not need audiometry.
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Rank: Super forum user
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If your RA determines noise levels require controls then you need to conduct audiometric monitoring. If you do not have noise issues at site you do not need audiometry.
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The paragraph you quoted states quite clearly (for a reg) that you do not include the hearing protection provided in your exposure calculations, so it is risk to health before hearing protection is worn.
The audiometery test are to show if the hearing protection is working as it should, so to include what you think the hearing protection provides as part of your assessment then no one would ever be tested!
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Originally Posted by: Dazzling Puddock The paragraph you quoted states quite clearly (for a reg) that you do not include the hearing protection provided in your exposure calculations, so it is risk to health before hearing protection is worn.
The audiometery test are to show if the hearing protection is working as it should, so to include what you think the hearing protection provides as part of your assessment then no one would ever be tested!
Clear as mud to me (the other Regs and guidance on not taking hearing protection into account I get) but....Para 105 to me reads:
provide health surviellance if "risk from exposure to noise".....there is a risk......"without taking account of the noise reduction provided by hearing protection" (see paragraph 31, not 30 see below).....there is still a risk after hearing protection applied Paragraph 31 (referenced)
Regulation 4(5) explains that the only exeception when this reduction can be taken into account is in relation to the exposure limit values (regulation 6(4)).......
Paragraph 30 (not referenced) "Note that the requirements in the Noise Regulations relating to assessment of risk and exposure, actions to take to reduce risk and exposure, and the levels at which they are required to be taken do not allow you to take account of the reduction of noise provided by hearing protection" Regulation 9 doesn't reference exposure action values and reading the HSE Topic Inspection Pack on Noise just states 85dB UEAV (not with or without protection) Just questioning what I've took for granted over the past 20 years! Thanks for all taking their time to reply!
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Think about what you are actualy doing by providing the hearing protection - the potentialy damageing sound levels are still present so the risk(although i would prefer to say hazard) still exists, all you are doing is reducing the chances of the individulay being exposed to that hazard if they use the hearing protection provided. In other words they are still exposed to the hazard but the conscquences are less becuae of the hearing protection, if it work. so the health monitoring is required to monitor your control.
I am not clear what your confusion is.
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Rank: Super forum user
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Paul I realise that the guidance can be read in two ways, but suggest that you approach this from first principles and forget what the Regs and guidance say. You do your noise assessment and conclude that Worker A is exposed to a level of X which is Y dB(A) above the relevant limit in the Regs. So you go out and buy some ear defenders which are marketed as offering MOST users Y+1 dB(A) attenuation. Audiometry helps tell you that the ear defenders being used do NOT give Worker A Y+1 dB(A) ACTUAL protection. This could be for multiple reasons. Your original assessment might have been flawed. Worker A's job has changed. The ear defenders might not fit Worker A as well as the design intended. Worker A may not be properly using them all the time (with lots of possible reasons for this), the ear defenders may have deteriorated and are less effective than they were when originally taken out of the box etc. Worker A may also be sustaining hearing damage for reasons outside their work environment, including simply getting older. Health surveillance is like PPE, a last line of defence (though in this case the hearing protection is the last line but one!).
If audiometry flags up a problem it gives you a chance to do something to protect Worker A. If you don't do that audiometry you don't get that chance.
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Rank: Super forum user
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Originally Posted by: 102paul So in a nutshell if noise measurement for daily exposure has been recorded at 86dB; and all techincal measures have been implemented in reducing noise; is health surveillance required after hearing protection worn will considerably lower the risk to health?
If you have reduced the noise to less than actionable levels, and verified this with a noise survey, then you do not need to carry out health surveillance (although you may still choose to). However, if the noise levels in the factory are still above actionable levels you must carry out health surveillance. This is whether hearing protection is used or not (although of course it should be). As correctly stated above, this is to ensure the PPE being used is suitable and sufficient. Remember we can never rely on PPE as a control on its own, it must be the last resort, after training, supervision etc. Therefore it would come after health surveillance, not before on the hierachy.
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