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Noise health surveillance below action levels

Published by Safety Net Team

January 28, 2022


We have employees who have to use various items of powered tools to undertake their work activities. One employee has requested that we undertake health surveillance for them in relation to noise exposure even though our assessment indicates noise levels are below the legal action values. Are we obliged to provide such health surveillance?


Under the Control of Noise at Work Regulations 2005, employers have a duty to eliminate or control the risks from exposure to noise or reduce exposure to as low as reasonably practicable.

Under Regulation 9 of the above regulations, if the risk assessment indicates that there is a risk to the health of his employees who are or are liable to be exposed to noise, “the employer shall ensure that such employees are placed under suitable health surveillance, which shall include testing of their hearing”.

The aims are primarily to safeguard the health of workers (including identifying and protecting individuals at increased risk), but also to check the long-term effectiveness of measures used to control risks to health.

It is important to note that this requirement is not linked to any of the exposure action values set within the regulations. The key to the requirement is whether the risk assessment indicates a risk to workers’ health — that is from exposure to noise without taking into account the noise reduction provided by hearing protection.

Guidance to the regulations then states that “there is strong evidence to show that frequent exposure above the upper exposure action values can pose a risk to health”. It then recommends that employers provide health surveillance to workers frequently exposed above the upper exposure action values.

Where exposure is between the lower and upper exposure action values, or where employees are only occasionally exposed above upper exposure action values, the guidance recommends that employers should provide health surveillance if the assessment has identified that an individual may be particularly sensitive to noise and noise induced hearing loss.

This can be identified through past medical history, audiometric test results from previous jobs, other independent assessments or a history of exposure to noise levels exceeding the upper exposure action values. Some employees may also indicate a family history of becoming deaf early on in life.

As the exposure action values are not being exceeded, it is highly unlikely that health surveillance is required in this case, but it may be advisable to keep the situation under review and more specific medical evidence sought as to the individual’s sensitivity.

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