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Control of Noise


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Just wanted to check on peoples approach to management of Control of Noise in places of entertainment with particular focus on health surveillance.


Regulation 9 states than the employer SHALL carry out health surveillance, which includes audiometric testing, where the risk assesment indicates that there is a risk to employees health in terms of being exposed to noise.


I am involved in management of several venues where exposure above the upper action value occurs with around 150+ members of staff working on a regular basis. I was just interested in how people manage this aspect of Noise management as the resource involved in carrying out such a vast number of health surveillance checks would be enormous and certainly impractical.


My reading of the regs would say that the employer has to and cannot argue on the grounds of 'reasonably practicable' even though this seems a completly fitting case where carrying out such a vast number of health checks would be not reasonably practicable.


Can anyone offer an opinion or those in a similar situation, state how they manage this issue?



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I work for the Australian Opera and Ballet Orchestra, resident in the Opera Theatre orchestra pit at the Sydney Opera House. The orchestra pit is not well-designed (thanks to what should have been the opera theatre being changed to the concert hall midway through construction, so what is now the opera theatre was hastily redesigned from a concert hall) and we have major noise problems in there as 2/3 of the pit is under the stage. We monitor every production for noise levels, and if it is louder than the prescribed 85dBa per performance, then we have to alter the rosters so that players are only doing the number of shows per week which brings their noise exposure down under the limit (we have a handy table which tells us how many shows per week players can do at any given noise level). All the information from noise readings is fed into a spreadsheet which also references the roster, so that we can produce a graph which charts every player's exposure to noise over the season. We can see peaks on it (usually matinee days or double dress rehearsal days) and advise people to wear personal hearing protection where necessary, although this is a measure which is a last resort if re-rostering just isn't practical.


Players in the orchestra also get a hearing test when they first start work with us, and then are entitled to a re-test once a year; the company pays for fitted earplugs if players want them, and we always have disposable earplugs with us as well.


It's a matter we have to take very seriously, and given that noise can be quite subjective and personal, if a player comes to us and says they are suffering from the noise levels on a certain production, even though the levels are acceptable, we will alter the rosters to give them time out if necessary - not just if their levels are above the 85dBa limit.

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Although not theatre based, my previous employer was also very hot on hearing conservation programmes. This included issuing ear protection, annual hearing tests and wherever possible reducing the amount of exposure to loud noise wherever possible. Yet my hearing still got worse over my 15 year career with them.


Perhaps issuing your staff with PPE (ear plugs) and offering them hearing tests at SpecSavers would suffice?

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You may already have seen the advice in Sound Advice, the web based guidance written by the HSE & an industry wide working group. It is pretty good on most aspects of noise in the entertainments industry and has a good section on health surveillance. http://www.soundadvi...story/san6.htm#


On the reasonably practicable argument – it wouldn't fly. If you can't get the noise exposure down, then simply having lots of people at risk isn't ever going to be an excuse for not doing the health surveillance. You can't aggregate risks to argue its unreasonable to protect them. It's a cost to the employer but not unreasonable (many factories have several hundred employees who require health surveillance). Also add potentially 150 civil claims where you can't show the noise damage didn't come from their employment with you, a very unhappy insurance company, enforcement action at multiple venues and possible legal costs of being prosecuted (where there would be no defence as the requirement is an absolute one) and there is a strong argument for doing it, as well as the moral one for keeping the staff healthy! Assuming you are in the UK, If you got a visit from a LA EHO or HSE inspector I would think it would be almost certain you'd get a formal enforcement notice to carry out surveillance, as a minimum.


My experience is that, as you'd expect, control measures are key – a thorough risk assessment looking primarily at control and not accepting noise as a given - e.g working on noise exposure by noise reduction, acoustic controls, noise direction, staff rotation, acoustic areas, placement of staff and use of proper PPE hearing equipment etc – Sound Advice is quite useful in those areas and others. Not easy and others here will have practical experience that I am sure can assist you. However if you still need the surveillance, there isn't an option.

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The point that surveillance may not be necessary following risk assessment and reduction, staff rotation and exposure measures have been taken is important. Hierarchy of risk yet again.


There are companies that conduct on-site occupational health hearing surveillance who can carry out audiometry tests, keep records and manage the whole thing though I do not know about costs.


One tip I have shared before on here is that all hearing aid centres carry out free testing and I have advised any trainees to get an initial test for their own benefit there.


There are also several universities, Aston is one, which have audiometry clinics on campus for training purposes that always seem to be seeking victimsvolunteer patients for their students. I don't see why they would not be interested in ongoing research into monitoring in these sort of cases. Worth a chat anyway.


It may be worth mentioning here for the employees reading that they too have a duty to use hearing protection supplied, to monitor their own hearing and report to management any difficulties. It isn't all down to people like Ryan.


It is very good to see someone with knowledge of the problems and the regulations who is seeking solutions rather than trying to find the minimum he can get away with. Wonder why Scot628 didn't linky this site; http://www.hse.gov.uk/noise/healthsurveillance.htm Modesty?

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