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Evans38004  
#1 Posted : 30 March 2022 11:00:48(UTC)
Rank: Forum user
Evans38004

One of my clients has this issue:

Manufacturing plant has 4 parallel production lines / conveyor system & 6 to 8 people doing manual work loading & unloading the line. The line is about 20m in length and the teammembers totate tasks (boredom / repetritive tasks / noise cotrol).

The product being constantly manufactured is in a seperate room & once produced is fed into the main production area via the conveyor system

Noise levels in manufacturing room ranges from 70 to 90dB - access is restricted to authorsied personnel only, who are obliged to (and do) wear hearing protection - total time for production staff in this room / shift is less than 15 minutes (mainly short 30s entry to unblock conveyors).

The production team will then spend 2 hours of their days in individuals on the noisier side of the line,  noise levels range from 68 to 84dB and then spend 6 hours on the quieter packing end of the line, 65 to 78dB.

Using the HSE noise exposure calcuator, the individuals are exposed to 81dB(A) - Lep,d

Am I correct to suggest that at this level, regualr health suerviellance is NOT required for the team members?

 

peter gotch  
#2 Posted : 30 March 2022 12:19:19(UTC)
Rank: Super forum user
peter gotch

Hi Evans

Struggling to work out how someone has calculated the personal daily noise exposure as 81 dB(A) LEP,d based on the numbers you give.

However that would be above the Lower Exposure Action Value of 80 dB(A), so doesn't represent a "safe" level and what HSE suggest in terms of health surveillance is not particularly onerous.

HSE comments on its website:

"You must provide health surveillance (hearing checks) for all your employees who are likely to be regularly exposed above the upper exposure action values, or are at risk for any reason, eg they already suffer from hearing loss or are particularly sensitive to damage."

So, I suppose the Q for your client is how would they defend the claim when it comes in, if they don't do base line surveillance as a bare minimum and hearing tests would be a sensible part of a broader occupational health programme.

Particularly given that the requirement to use hearing protection is stated to be for very short duration entries into the most noisy area, I would be inclined to assume that the actual protection provided by use of hearing protection is NIL (and that's despite my taking the view that we should be proportionate in decision making).

If that exposure to a conservative 90dB(A) is really only for a maximum of 15 minutes a day, then in simple maths......

15 minutes @ 90 = 30 mins @ 87 = 1 hour @ 84 = 2 hours @ 81 = 4 hours @ 78 = 8 hours @ 75dB(A), so that may not be the primary source of exposure with or without hearing protection. [I did say "simple maths" - the doubling of exposure per 3dB increase is not exact, but close enough for most purposes]

Evans38004  
#3 Posted : 30 March 2022 13:21:31(UTC)
Rank: Forum user
Evans38004

Thanks Peter

Struggling to work out how someone has calculated the personal daily noise exposure as 81 dB(A) LEP,d based on the numbers you give. - over 120 noise measurements taken over a 3 months persion was churned into the HSE Noise exposure calculator and the 81dB(A) was churned out (even looking at worst case scenarios only were used, the calculator provided values lower than 85dB(A) !

However that would be above the Lower Exposure Action Value of 80 dB(A), so doesn't represent a "safe" level  Paragraph 103 of L108 (a) & (b) states that the daily exposure needs to be above the upper EAV - most of the employees fall under (c) between the lower and upper EAV, except we are not aware of any employee who has reported on their annual medical surveillance form that they have pre-existing hearing loss, are on certain medication or are exposed to chemicals

the Q for your client is how would they defend the claim when it comes in - they've completed a noise survey and made an assessment based on HSE guidance, as the MD states ... it will be the issue of the insurance company to deal with the claim (in my 30 years of expereince this would be settled out of court even with a robust documented safety program in place) 

peter gotch  
#4 Posted : 31 March 2022 12:40:10(UTC)
Rank: Super forum user
peter gotch

Hi Evans - MD is correct about who would be likely to be leading claims management.

You are correct that most claims are settled out of court, and in this case almost certainly would be if there is no base line data - insurance company is in an almost impossible position in terms of defending certain parts of a case.

Whether such an approach shows empathy for the workforce is another matter.

"We are not aware....."

Perhaps "We" should try harder to be aware?

Further, 120 readings may not be very many, depending on the nature of the facility. Whether 120 is enough to give a clear enough picture will depend, inter alia, on the accuracy of the meter and the competence of the person using it.

Edited by user 31 March 2022 15:23:02(UTC)  | Reason: Some clarification

Riaan Kruger  
#5 Posted : 13 June 2022 13:54:00(UTC)
Rank: New forum user
Riaan Kruger

Good afternoon, to all,

Reading through the forum it seems as the if the issue goes if hearing protection must be worn and if for how long....

Yes one can follow legislation to the T, but where does due dilligence then come in. Put yourself on those lines for 1 month, forsure you will have headaches feel dizzy and your ears will be whistling for sometime after leaving the premises. 

If you realy consider it, the possibility of claims that can reach into thousands is it worth not to spend the money on decent hearing protection. Let the employee sign for it revise the PPE policy that if they brake or loose the earmuffs they will be liable for the new ones bought and deducted it from their wages. 

If a claim arises and the company can show that they went the extra bit further as needed, it can just help. 

Is any amount of money really the loss of hearing worth?

To quote the dictionary:

"Due diligence has been used since at least the mid-fifteenth century in the literal sense “requisite effort.” Centuries later, the phrase developed a legal meaning, namely, “the care that a reasonable person takes to avoid harm to other persons or their property"

That goes for companies as well...

Have a great one.. and may you hear the sound of the birds singing at old age..

Roundtuit  
#6 Posted : 13 June 2022 14:13:18(UTC)
Rank: Super forum user
Roundtuit

Missed this one first time round.

Simple answer there is an identified hazard dependent upon PPE as a last line of control so health surveillance is required to identify any individual being adversley affected by noise and to validate the provided protection is suitable to the task.

I have noted a number of "trades" at several sites where compression fit hearing plugs are not correctly worn but "placed" at the ear to falsely demonstrate compliance with policy.

At one such site the health surveillance was invaluable in proving to one joiner (and subsequently their colleagues) of their folly in "halving" ear plugs before use. 

Roundtuit  
#7 Posted : 13 June 2022 14:13:18(UTC)
Rank: Super forum user
Roundtuit

Missed this one first time round.

Simple answer there is an identified hazard dependent upon PPE as a last line of control so health surveillance is required to identify any individual being adversley affected by noise and to validate the provided protection is suitable to the task.

I have noted a number of "trades" at several sites where compression fit hearing plugs are not correctly worn but "placed" at the ear to falsely demonstrate compliance with policy.

At one such site the health surveillance was invaluable in proving to one joiner (and subsequently their colleagues) of their folly in "halving" ear plugs before use. 

stevedm  
#8 Posted : 20 June 2022 07:07:11(UTC)
Rank: Super forum user
stevedm

I have always used...under 80 dBA Health Surveillance is not required - between 80-85 dBA Health Surveillance is advised and above 85 dBA Health Surveillance is mandatory...

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