Hidden Noise: if you’re concerned with noise at work you’re probably looking in the wrong place

Jun 14, 2022 | 0 comments

The Control of Noise at Work Regulations (CNAW) were introduced in 2005. As we know, they replaced the 1989 regulations and made the significant advances of

  • reducing action levels
  • accounting for weekly noise exposures
  • mandating hearing surveillance

The 1989 regulations were built to support the original 1974 Health and safety at Work Act specifically to address the risks posed by noise in the workplace.

So whatever the debate around your preferred approach to surveillance and monitoring of hearing at work (and let’s face it: everyone thinks the horse they are riding is the fastest), hearing health in the workplace today is a progressive evolution and significant improvement on what went before.

  • Millions of workers have legislation, plus clinical and practical support to protect their hearing health under the concept that people should not exchange their health for their employment.
  • There is a framework for employers and healthcare providers, creating a level playing field with an accepted baseline standard of care.
  • This means that a significant proportion of workers today have better awareness and better protection about hearing healthcare than previous generations.
  • There is a small army of professionals dedicated to supporting good (hearing) health.

Evolution never stops

Even Hearing Care Evolves - WorkScreen

Improving more than finches & tortoises since 1859

Life does however move on. And where the broad-brush regulatory system created in 2005 succeeds, there are significant exceptions and differences within the workforce. These worker cohorts are exposed to noise, yet not obviously covered by CNAW.

This unwelcome development leaves many employees in the UK at risk to harm – and potentially at some of the most formative stages of their lives.

Three groups of hearing surveillance client

WorkScreen was devised to make hearing tests at work more accessible, so that everyone who should have a hearing test at work can get one. Our experience is of working with three groups of client:

  1. The establishment: the knowledgeable repeat procurers of hearing surveillance either looking to update or improve what they’ve done before.
  2. The first-timers: typically smaller companies stepping up a gear, these organisations have often had a change of personnel keen to improve conditions or may have had a recent visit from an HSE inspector or their insurer who have noted non-compliance.
  3. The enlightened few: this group of unexpected calls make our day. Ordinarily these guys would be on the very periphery of the HSE’s radar – if at all. Their interest in hearing health is often a result of an initiative driven by the staff themselves or HR team.

These 3 groups are generally accounted for and picked up by the HSE. It is often said that around 1 million workers in the UK are at risk due to noise* – they are the metal bashers out there and are scrutinised by the HSE (a responsibility shared with Local Authority Environmental Health Officers (EHO)). Whichever way you look at it, these places are accepted as noise environments or are characterised by noisy occupations.

In short, our experience is that places that actively manage noise at work somehow fit in a box which signifies elevated noise risk. This means the noise that employees are exposed to is self-evident and can generally be experienced, evaluated and monitored by a third-party.


Changes to the workforce and workplace

Workers and the work environment is more diverse than ever - noise is hiding in there

Older, plugged in, at home, flexible: work ain’t what it used to be

A lot has happened since CNAW was created nearly 20 years ago – the context and composition of our workforce has changed considerably:

  • The workplace is less controlled: peaking at over 60% during the pandemic, working from home – with all those Teams and Zoom meetings – is now a normalised work pattern. (**)
  • Older people are now working: since mandatory retirement was scrapped in 2011, 11% of the over 65s work . (***)
  • Less of us are on the tools: Manufacturing jobs have declined by 13%, accounting for 2.7M jobs (7% of the workforce in 2019), down from 3.1M (10%) in 2005. (****)
  • New sectors have boomed: online shopping has grown from under 5% of UK shopping to around 30%. Making it over 12 times larger, if our maths is right. This has driven growth in logistics and delivery, distribution and warehousing.
  • We’re plugged in at work: Earphones are acceptable in many offices to concentrate or communicate – Limitear calculate 7.6M workers are at risk using figures provided by HR Director Magazine.
  • Hearables and earphones are commonplace: Hearables are the fastest growing consumer electronics sector ever according to respected industry analyst and tech leader Nick Hunn.

The sum of these changes is that since 2005, we are older, more desk-bound, more plugged in, more at-home and increasingly benefitting from staff working in centralised logistic services. Meanwhile, the effects of noise will be felt for longer as we listen longer and work longer – often across diverse careers.

Introducing the most important group of workplace hearing test client

These changes mean that there is a another – and very large – group of hearing surveillance clients out there: the group that hasn’t called yet.

These organisations don’t realise that the law exists, don’t realise it applies to them or they’re not even aware of noise as a risk. They may also be outside of the HSE’s remit due to their size or sector, which means enforcement is the responsibility of the Local Authority’s EHO’s – with varying degrees of success. This all means that these employees are at greater risk of hearing damage, with attendant wellness, health, safety and productivity issues.

Should we be concerned about the 1M or the 29.9M?

Noise is not the preserve of the workplace (if it ever was) – nor is it the preserve of manufacturing.

29.9 million Britons are at work in other sectors {*****}: Tourism, entertainment, hospitality logistics (including drivers) are now even more significant parts of the economy. If you are in any doubt, cast your mind back to the fuel shortages in 2022, caused by a shortage of HGV drivers. Other casual work and growing self-employment means that the traditional noisy occupations are a smaller and declining proportion of the UK workforce – even if they are increasing productivity.

It should also be noted that flexible workers tend to be both older and younger than the “norm”. With twice as many (25,000) coffee outlets in 2019 as 2009 {******}, it is easy to understand how large organisations employ large numbers of staff who work flexibly and who may therefore be more vulnerable. Yet, these companies have the resources to address staff welfare in a co-ordinated manner.

Hidden Noise – coming to an office near you

Defining Hidden Noise is a human story….

Imagine if you will, some real-world examples of hidden noise. Perhaps you may not have to imagine very hard at all:

  • Joe is a senior manager and works from home – headset on all day. The radio is on between calls. And he uses the same earphones to listen to the cricket or music between calls or in the gym. Plus some ad-hoc noise exposure during the rest of the day: a spot of hoovering at lunchtime, is not unknown.
  • Felicity works in an open plan office analysing data – she could equally be coding websites though. Plugged in, online, earphones on and music playing….. she is the height of graduate industriousness as her comfy cans and banging tunz keep all that unwanted office noise out. The truth is that no-one else has any idea what is going on inside those earphones, or what she’s listening to (the chances it’s Brahms at 50dB is probably low). As a reminder, these headphones may do hearing damage in minutes. The reality is likely longer, but considerably less than the working day. In the evening she is not a gamer, unlike her male colleagues on Call of Duty, but she does go clubbing to destress.
  • Ralph is a student coffee shop server who hops between shifts serving coffee and pulling pints. Sometimes it’s long hours and sometimes it’s quiet enough, but at others the music in the pub has got to rise above the packed bar – which means plenty of shouting. None of which is as ear-piercing as a pair of iced-coffee blenders going on two feet away during busy coffee shifts – when the steam frother is not squealing or jugs of frothed milk banging on the counter. With these blighters going, hearing damage could take place in 2 hours. And that is without considering the drive-through headset on Saturdays…..

We could go on: the delivery driver with his cab radio. Or the part-timer in the online dispatch warehouse. Or the retired facilities engineer on site part-time….

Even if measuring noise is possible in the scenarios above, getting a clear picture of an individual’s exposure is tough, due to the highly variable work patterns. Which means all of the above workers could be unaware of their exposure to significant – unquantified – noise without protection. This is the root of Hidden Noise:

Hidden Noise is potentially damaging noise that cannot be easily detected, monitored or controlled because the noise exposure – or the workers themselves – are not evident to a responsible third party.

In effect, Hidden Noise results when potentially damaging sound – or the people affected – are hidden. Hidden Noise is unlikely to stop when you leave work, blurring the lines between responsibility and also challenging the 8hr model of daily exposure.

The human story here is that it is very difficult – by definition – to know how many people are exposed to Hidden Noise. But WorkScreen is comfortable asserting the actual figure of UK workers at risk due to Hidden Noise is multiples of the accepted figure of 1.1million staff – yet the risks and impacts are consistent.

A Wish List for Noise Management

Which means that this article has been a very extended suggestion that

  1. Great work has been done, but there’s lots to do.
  2. We need to equalise the misplaced pre-occupation on the few well-protected in Noisy Occupations and not the many at risk due to Hidden Noise, who are more numerous, may be more vulnerable and have equal rights.
  3. The biggest intervention we can make is noise awareness and accessibility – and specifically around Hidden Noise.
  4. Some sectors are poorly serviced due to their regulatory set up.


Some items from the WorkScreen wish list:

How much noise exposure are you getting during online meetings?

Not uncommon for a day’s work.

  • Better recording of noise and safety – e.g. noise related accidents and illness.
  • Baseline hearing assessments for all joining work.
  • Review regulatory responsibilities and sectors.
  • Engagement and a toolkit for Environmental Health Officers and Local Authorities to support their work managing noise – and Hidden Noise – in the workplaces they are responsible for.
  • Junking the traditional focus on hearing loss as the major problem associated with hearing in favour of a more inclusive expression that is more reflective of the risks in the general population.

WorkScreen will be working with WHO’s Make Listening Safe Initiative and the UKHCA community to dive deeper into our wish list and the specifics of Hidden Noise, as well as the manifestations and impacts for individuals and organisations today.

If you’d like to contribute or discuss Hidden Noise in your work, please contact us.


With thanks to Clare Forshaw, Stephen Wheatley & Tom Parker

{*} hse.gov.uk

{**} www.finder.com/uk/working-from-home-statistics

{***} www.ons.gov.uk/

{****} researchbriefings.files.parliament.uk

{*****} www.ons.gov.uk/

{******} • UK coffee shop count 2019 | Statista