Posted on: Oct. 15, 2024
HSE identified common failings, preemptive advice and resources
300% increased enforcement actions + a crack-down on rogue consultants...
Chris Steel, Specialist Noise & Vibration HSE Inspector reported the initial findings. The headline figures and intent from the results of the first 3 months of the programme include:
- 300% uptick in noise related enforcement letters and notices (does not include health surveillance shortfalls)
- Only 5% of sites test for audibility of warnings etc when using PPE (over-protection)
- Common errors in noise reports - 41% of sites use external consultants
- Noise risk assessment consultant and reporting quality checklist
- Crack down on "rogue" noise consultants
Apart from the obvious (and expected) large increase in noise related enforcement activities, one of the key takeaways from the inspection focus is the HSE desire to move organisations away from the all-to-common risk assessment checkbox mentality towards risk controls.
Our advice on this (based on seeing so many poor noise reports on our IOSH competency courses) has always been -
"Why spend so much money on placebo risk assessment reports that tell you what you already know; that you have a problem? Spend the resources on risk reduction instead..."
HSE noise inspections - the common findings and faults
Key takeaways:
- 3 fold increase in noise related enforcement actions: 29% in the form of letters, 10% in the form of notices
- Across all risks, noise was the most likely risk to require improvements in health surveillance
- Across all sites visited, 40% were above the UEAV. The figure was 11% for construction sites
- 41% of organisations use external consultants for reporting and advice
- Only 5% of sites had checked that PPE does not increase risk re audibility of warning signals etc* (our sophisticated one at HRow)
Fundamentally, this all boils down to a lack of knowledge and/or advice about what constitutes noise risk reduction best practice in your particular circumstances, whether internal or via consultants.
The following sections provide detailed advice and links to resources on what actions Duty Holders can take to determine what is and how best to implement current risk reduction best practice.
Common reporting and consultant advice failings
These include:
- No or poor advice re PPE
- Not all high noise activities identified
- Very limited advice on noise control
- Duty Holder unaware of what has been covered
- Poor noise measurement practices - including using fixed locations for risk assessment!
- Just regurgitating HSE documentation that is otherwise available for free...
HSE crack down on "rogue" noise consultants
The HSE is reviewing noise reports and intends to target poor performing consultants. The key areas of concern include:
- underestimating noise exposure
- poor measurement and calculation practices
- inadequate observation of working practices
- failure to advise on noise control where there are practical options
- falsely deeming existing controls to be adequate and offering false assurances re PPE
Where this leads to a material breach of H&S law, the HSE will take enforcement action against the noise consultant, incurring an intervention fee.
Preemptive actions you can take to avoid problems
Check the following actions to ensure that you are using current best practices.
We are on the HSE group tasked with generating advice on what you should expect from both consultants and noise risk assessment reports. View the advice and checklist and download a free copy of the guidance.
Noise control is the risk management Cinderella due to an abysmal lack of knowledge about modern mitigation technology. Long-term reliance on PPE is not permitted unless you can prove that noise control is not practical. Carrying out a Noise Control Audit is a regulatory requirement. There are also free online resources you can access to improve risk management with noise control measures you can copy and implement.
We provide template benchmark noise risk assessment and management reports for organisations that are then used either internally or by external noise consultants for all future assessments. This facilitates quality control and makes it easy to record and review changes in risk over time.
We developed and run the IOSH noise competency training course, an enjoyable and non-academic way to become a competent person on the subject. Taking noise risk assessment and management in-house can be an extremely effective way to reduce risk - and to cut costs...
