Health and Safety
Executive / Commission
Freedom of information
SIM 03/2007/08
Author Unit/Section: Manufacturing Sector
Version No:: 2
Target Audience: All FOD Staff
This SIM informs operational staff about the hand-arm vibration (HAV) and noise control project being carried out during 2006-08. In Year 2 of this project (2007/08) particular emphasis will be on noise, with some continuation of the HAV work carried out in 2006/07. The project consists of Programme Directed Inspections, investigation of health surveillance provision, local promotional events and national communication activities, focusing on securing the adoption of control measures and strategies to reduce exposure to HAV and noise, and increasing the uptake of health surveillance. This work contributes to the Noise & HAV Programme within the FIT3 Strategic Programme.
1. Ill-health due to occupational exposure to hand-arm vibration and noise continues to be significant. 900,000 employees in the UK are exposed to vibration above the exposure limit set in regulation. 1.1 million employees are exposed to levels of noise above the upper action value set in regulation, and relying on PPE to protect their hearing. Noise-induced hearing loss and hand-arm vibration syndrome (HAVS) account for 50% of new successful industrial injuries compensation claims, and over 50% of claims for compensation through the civil courts for occupational diseases.
2. New regulations on vibration were introduced in 2005, replacing HSE's established guidance on the subject. New regulations on noise come in to force in April 2006, setting reduced action levels.
3. A major aim of the accompanying guidance for both sets of regulations is to emphasise that risks from HAV and noise can in many cases be tackled by the adoption, on the part of the duty holder, of established control measures and strategies.
4. To promote these aims a HAV and noise control project is running during 2006/07 and 2007/08. Activities in 2007/08 will focus primarily on noise. Some of the activities initiated in 2006/07 on HAV will continue in 2007/08. The campaign is a project contributing to the Noise and Hand-arm Vibration Programme, within the Fit3 Strategic Programme.
5. The aims of the campaign are:
6. The objectives of the second year of the project (2007/08) are:
7. Targets for 2007/08 are activities presenting unnecessary noise exposure in manufacturing (specifically, in concrete products, plastics and rubber and woodworking) and construction. Whilst the main activity will be on noise, for HAV it is intended that activity will continue in heavy fabrication, foundries and construction, with inspectors dealing with HAV when encountered using the approach outlined in OM 2006/07.
8. Programme Directed Inspections will be carried out in manufacturing sector targeted areas. Appendix 1 of this SIM provides notes for inspectors carrying out inspections on noise. Inspections should be carried out when specific high noise risk processes are encountered in the target premises. The high-risk processes of interest are identified in Appendices 2 (concrete products), 3 (plastic & rubber) and 4 (woodworking). See also paragraph 22 for other programme interventions in woodworking. These Appendices provide further briefing for inspectors, and can be left with duty holders if necessary.
9. Inspections on noise in construction will be carried out where noise is an issue. Interventions should focus on securing the adoption of measures to eliminate or reduce noise exposure by technical and/or organisational means, and reducing the reliance on personal hearing protection.
10. On encountering identified high noise processes, inspectors will, with the aid of the information in the Appendices to this SIM, be able to form a judgement as to whether the upper exposure action value (a daily personal noise exposure of 85 dB) is likely to be exceeded. If so, the alternative working methods and exposure reduction measures listed in Appendices 2 to 4 should be used as the basis for an intervention to secure compliance with Regulations 6(1) and 6(2) of the Control of Noise at Work Regulations 2005, i.e. to ensure that exposures to, and risks from, noise are as low as reasonably practicable.
11. Alongside the intervention to secure the adoption of reasonably practicable control measures, inspectors should deal with other matters surrounding the management of noise risks where high exposures are unavoidable, including selection of work equipment, selection and use of suitable hearing protection, information, instruction and training, and health surveillance.
12. In 2006/07 the project made use of ‘advocates’, FOD inspectors providing a locally-based link between the FOD inspection activities and the project team, and to support colleagues. The existing advocates will be invited to continue their support for the project, or, where this is not possible or additional advocates are needed, Heads of Operations will be invited to provide nominations from within their commands. The community of advocates will be provided with specific training in their role, and will be supported in turn by the project team. The advocates in each region need to be clearly identified at the beginning of the year. Delays in nomination will delay the training sessions to be provided by the project leaders.
13. An important aspect of the project is that Inspectors are providers of intelligence to the Project Team in order to facilitate further work under the N&V Programme and to broaden HSE's understanding of what may be reasonably practicable for control of noise. It is intended that advocates will liaise with inspectors to facilitate the following up, by N&V Specialists, Occupational Health Inspectors or Corporate Medical Unit as appropriate, of examples of:
14. Four regional noise control surgeries will be held, in addition to the HAV control surgeries carried forward from 2006/07. These events will be organised in conjunction with the Engineering Employers’ Federation (EEF) and lead by N&V Specialist Inspectors.
15. The intention of these events is to provide practical advice to dutyholders on controlling risks from noise, by means of case studies highlighting good practice controls measures and strategies. It is intended to develop and present relevant case studies on planning for control, implementing established controls, developing new controls and managing health surveillance.
16. Where exposure to noise is likely to be above the upper exposure action value, guidance is that health surveillance of the affected employees is required, and inspectors should ensure compliance with Regulation 9 of the Control of Noise at Work Regulations 2005. Inspectors should refer to Occupational Health Inspectors where dutyholders report difficulty in securing suitable health surveillance, and where the quality of health surveillance provided or the feedback and use of the results of health surveillance give cause for concern.
17. OHIs will also undertake proactive work on both noise and HAVS health surveillance, including inspection of dutyholder compliance. This work, co-ordinated by FOD Corporate Medical Unit (CMU), will involve using intelligence gathered by HSAOs to target inspection of dutyholders and occupational health providers. Inspections of occupational health providers will concentrate on advising them on procedures and competence. Analysis of the results of this work will inform the development of HSE strategy to improve health surveillance provision. CMU will provide briefings to Occupational Health Inspectors and HSAOs as necessary on their role in the project.
18. There will be continuing communications and stakeholder engagement events to support the campaign, described in more detail in the Noise & Vibration Programme Communications Plan. These include HSAO-organised free seminars (SHAD-type events), particularly targeted at SMEs, distributed nationally throughout the 2007/08 according to target audience and demand (likely to be held in locations not yet targeted by the project). The HAV/Noise control project is planned to continue into 2008/9 and communications activities will continue according to demand.
19. As outlined above, HSAOs will contribute to delivery of communications events, and will assist in target inspection of dutyholders and occupational health providers in relation to health surveillance. In particular, this latter activity should be planned at the beginning of the year. Guidance and support for HSAOs in relation to their work on this project will be provided by the Project Team and the N&V Programme operational interface, who will agree the activities of the HSAOs with their local management.
20. COIN recording details will be notified by FOD.
21. This project is being managed by the FOD N&V Pool. Contact the project managers Bruce Appleton (VPN 525 2509) and Tim Ward (VPN 523 3985) for more information.
22. The Disease Reduction Programme is carrying out a HSAO intervention in respiratory disease in the woodworking industry. For further information see SIM 03/2007/07 or contact Brian Coggans VPN 521 7218.
1. This Appendix provides information for inspectors carrying out Programme Directed Inspections on noise as part in the N&V Programme's control project in 2007/08 in the target sectors: concrete products, plastics and rubber and woodworking. In combination with Appendices 2 [44Kb], 3 [43Kb] and 4 [43Kb] it forms the basis of the training material for this campaign. Appendices 2 to 4 contain sector-specific information on HSE's expectations for compliance with the Control of Noise at Work Regulations 2005. This information will also be published on HSE's noise web pages so that the same information is available to dutyholders.
2. Table 1, column 1, of the relevant Appendix lists work processes that are known to result in high noise exposures and for which technical and/or organisational control measures have been identified. Inspectors should carry out a Programme Directed Inspection on noise, following these guidelines, when one or more of these processes is encountered and where daily exposure times are such that exposures above the upper exposure action value are likely (see below).
3. Daily personal noise exposure is dependent on the noise level and the exposure duration and should be assessed by the employer using representative noise data (which may be from measurements in the workplace). However, for the work activities covered by this campaign, it will usually be possible for employers and inspectors to establish whether the upper exposure action value is likely to be exceeded by using the information in Table 1, columns 1-4, in the relevant Appendix, and knowledge of daily exposure duration. This should be sufficient to establish whether the relevant duties in Regulation 6 (elimination/control of exposure), Regulation 7 (hearing protection), Regulation 8 (maintenance and use of equipment), Regulation 9 (health surveillance) and Regulation 10 (information, instruction and training) apply.
4. The technical and organisational measures for reducing noise exposure listed in Table 1, column 5, of the relevant industry-specific Appendix have been established as good practice in the industries concerned and will often be reasonably practicable, depending on local circumstances. The list is not exhaustive. Inspectors should seek to secure compliance with Regulations 6(1) and 6(2) through interventions to ensure that, where reasonably practicable, the employer adopts suitable measures to eliminate noise exposure or make it as low as reasonably practicable (ALARP)
5. Employers must manage noise risks, including where technical and organisational control measures cannot be implemented immediately, or residual risks remain after all reasonably practicable measures have been taken to eliminate/minimise noise risks. In these cases, if exposure is likely to exceed the upper exposure action value, employers must ensure that exposure is ALARP and risk is controlled. This will require an appropriate combination of measures such as selection of suitable work equipment, maintenance, selection and use of suitable personal hearing protection, providing employees with information, instruction and training and limiting exposure time. Regulations 6, 7, 8 and 10 apply. Table 2 of the relevant Appendix contains further information
6. A suitable health surveillance programme must be in place for employees whose noise exposures are likely to frequently exceed the upper exposure action value (or whose health is at risk and their exposure is between the lower and upper action values). This should allow for any new cases of noise-induced hearing loss (NIHL) to be detected and diagnosed, for existing cases to be monitored and for adequate information to be fed back to the employer. There should also be a clear policy for the future management of affected employees. Regulation 9 applies. Any concerns over quality or availability of health surveillance services should be recorded for follow up by an Occupational Health Inspector
7. The information in Appendices 2 to 4 will be made available on the HSE website and copies of the Appendices may be left with dutyholders. The right hand columns contain references to more detailed guidance, case studies, and other information and includes material from sources other than HSE. Links to the relevant locations on the internet are provided wherever possible, and it is anticipated that all the material referred to will be made available online before inspections begin.