NIHL Programs must include Personal Dosimetry

The Minister of Labour, Ms Mildred Oliphant, has issued Government Notice R889 in Gazette Nr 41065 on 25 August 2017 in which she included personal noise dosimetry as a supplementary control measure required in Regulation 7(2) of the Noise Induced Hearing Loss Regulations under the Occupational Health & Safety Act, 1993.

In terms of this notice, and effective on the date of publication, (25 August 2017), all employees who infrequently enter noise zones, must be subjected to the dosimetry analysis of their exposure in accordance with SANS10083 and where their exposure level over an 8 hour working day exceeds the allowable threshold, must be included in the hearing conservation program.

The Notice does however not prescribe who these employees are, other than identifying their movements as they are not working:

a) in another area with the approximate equal noise level, or

b) in a fixed location (such as an operating console or workstation)

We can therefore summise that these individuals move around from one section to another during a normal working day, and their “normal” workstation are outside of a similar noise environment.

From experience I have learnt that the Safety department will take the easy way out and create a blanket dosimetry policy for “moving personnel”, and whilst this is good news for Approved inspection auhorities, it is bad news for employers if the process is not addressed properly and will result in costs that may not be necessary.

Doing it the right way, requires competence in Occupational Noise Measurement & Hearing Conservation, an understanding of the anatomy of the human ear and how it is effected by acoustic properties of the work environment. It may not be necessary to consult an Approved Inspection Authority from the outset.

We recommend employers follow the following approach:

Identify “incidental staff” that would meet the criteria set above.

The HR department should have a job description for each employee or job title. Identifying these individuals should be the first step in an effective approach. It could be cleaners, maintenance workers, QA/QC staff, Security Staff (Contractors too), Safety Officers & Reps, etc etc. It will largely depend on your own organisation.

Identify the Noise Areas they will be required to enter.

From the group identified in the first step, select a few employees and consult with them regarding their daily movements, from one location, through another etc. From this information you would be able to identify who actually is required to enter a noise zone based on their jobs. (Visiting a colleague for a quick social chat is not part of normal duties and is also counter-productive).

Finalise a Short-list of Incidental staff

Some incidental staff may walk around on the premises or workplace, but never need to enter a noise zone. There is no need to include these employees in the NIHL program, as they are not exposed at all. Only include staff that may be exposed – in other words, there is a high probablity of exposure.

Consult with your  H&S Committee / Representative or Union representative on the proposed action going forward.

The inclusion of incidental staff is not negotiable as it is now a legal obligation, but it is important to convey this message to employees via their elected representatives to ensure co-operation. The purpose of such a consultation process is to inform employees about their possible participation and subjection to personal dosimetry and the consequences of the results obtained during these tests. Many employees may view it as an invasion of their privacy or management’s motives to exclude them from certain tasks. It would therefore be important to convey the purpose of the dosimetry program and why it is a different detection method than static measurements of normal noise surveys.

Set exposure time limits

Once you have a clear idea of who to measure and where to measure the noise exposure, you can contact an Approved Inspection Authority (AIA) to perform a baseline evaluation on a target group of employees.

As noise exposure is time based, the AIA would be able to assist you in setting up time limits during a day, as the maximum time allowed inside a noise zone.  Where the noise level is 90dB(A), measured over an 8 hour period, any reduction of time will lower this level substationally, but it is not linear. Halfing the time will not reduce it from 90 to 45.

Dealing with Visitors & Contractors in noise zones

Legally speaking, you are the employer of a contractor while they are on your premises, unless you have an agreement with the contractor to ensure they comply with the regulations and your own internal safety rules and procedures. If a contractor is required to work in a noise zone, it would be in your interest to ensure they have their own NIHL program and that all their employees are included in audiometric screening before and after the project or contract period.

Visitors on the other hand, should not be allowed in noise zones unless they wear the required hearing protection equipment as if they were a full time employee.

Management entering Noise Zones

One of the biggest challenges of any NIHL program is to persuade employees to wear their earplugs or earmuffs. When executive or senior managers enters a noise zone, it is mostly for short periods and often without the need or hearing protectors. However, the example set by management will go much further than the need for discipline and expensive training and awareness programs. It will become a culture.

While noise measurement is a means for detecting adverse health effects in noise zones, noise levels can be reduced in a variety of ways. Feel free to contact us for a complete assessment of your company. Our Safety Engineers may be able identify areas where noise can be reduced by applying engineering design methods.


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