Hearing damage is one of the most common — and most preventable — occupational health problems in UK construction. It creeps up over years, it's irreversible, and by the time a worker notices it, the damage is done. The Control of Noise at Work Regulations 2005 put a clear legal duty on employers to assess and control noise, yet noise is one of the areas contractors most often overlook because you can't see it and nobody bleeds on the day.
If your work involves cutting, grinding, breaking out, chasing walls, using cartridge tools or running plant, this one's for you. Here's what the regulations actually require, when a noise assessment is triggered, and how to keep your site right on the day an inspector asks.
What the Control of Noise at Work Regulations require
The regulations don't ban noise — they require you to manage it. The duty is to assess the risk to your workers' hearing, eliminate or reduce noise at source so far as reasonably practicable, and provide hearing protection where needed. Crucially, the law works around exposure action values and an exposure limit value.
These are based on daily or weekly average exposure (LEP,d) measured in decibels A-weighted, plus peak sound pressure for sudden loud noises:
- Lower exposure action value: daily/weekly average of 80 dB(A), peak of 135 dB(C). At this point you must assess the risk, provide information and training, and make hearing protection available on request.
- Upper exposure action value: daily/weekly average of 85 dB(A), peak of 137 dB(C). At this point you must reduce exposure by organisational and technical means, establish hearing protection zones, and hearing protection becomes mandatory.
- Exposure limit value: 87 dB(A), peak of 140 dB(C). This must not be exceeded — and it's measured taking hearing protection into account.
A simple rule of thumb from the HSE: if you have to raise your voice to be understood by someone about 2 metres away, noise is likely to be around 85 dB(A) or more. If you have to shout at 1 metre, you're probably above 90 dB(A). That's your on-site trigger to do something.
When you actually need a noise assessment
You need to make a suitable and sufficient assessment when your workers are likely to be exposed at or above the lower exposure action value. On most construction sites, that threshold is crossed the moment anyone picks up a grinder, breaker, or cut-off saw. So for the majority of trades, the honest answer is: you need one.
The assessment doesn't have to be a laboratory measurement exercise. For many jobs, you can estimate exposure using the manufacturer's declared noise data for the tools plus how long they're actually used across the day. The point is to identify who is exposed, to what level, and what controls you'll put in place. This sits naturally alongside your other task risk assessments — see our guide on whether you legally need a risk assessment if you're unsure where noise fits.
Controlling noise on site — the practical order
Hearing protection is the last line of defence, not the first. The regulations expect you to work through the hierarchy:
1. Eliminate or reduce at source. Choose quieter tools and methods. A downward pressure on the ear starts with the equipment spec at procurement.
2. Engineering controls. Damping, silencers, enclosures, low-noise consumables (some cutting discs are markedly quieter than others).
3. Organisational controls. Rotate tasks so no one person soaks up the whole day's exposure. Keep noisy work away from other trades. Limit the time tools run.
4. Hearing protection. Ear defenders or plugs — the right attenuation for the noise, properly fitted, worn consistently.
5. Hearing protection zones. Above the upper action value, mark the area, sign it, and enforce that protection is worn.
Noise rarely travels alone. The same tools that damage hearing usually throw off vibration and dust too. It's worth reviewing your approach to HAVS monitoring and your COSHH controls for silica at the same time, because you're often managing the same task.
Health surveillance and training
Where workers are regularly exposed above the upper action value — or above the lower value and there's a reason to be concerned (for example a worker who's told you their hearing is already affected) — you must provide health surveillance, typically audiometry. Keep the records, act on the results, and adjust controls if hearing loss is detected.
Every exposed worker also needs information and training: what the risks are, what the action values mean for their job, how to use and look after their hearing protection, and how to report problems. A short, focused briefing does this well. A toolbox talk on noise is one of the easiest wins here — it's on record, it's quick, and it puts the message where the work happens.
The records that keep you covered
When it comes to noise, paperwork isn't box-ticking — it's the evidence that competent people assessed the risk and acted on it. Aim to have:
- A written noise risk assessment identifying who's exposed and at what level.
- The control measures decided and who's responsible for them.
- Hearing protection issued, with the attenuation rating recorded.
- Hearing protection zone signage and enforcement notes.
- Health surveillance records where required.
- Evidence workers were briefed and trained.
A task-specific noise risk assessment gives you a proper starting point rather than a blank page — you'll find one in the risk assessments library, and it pairs neatly with the inspection and monitoring forms in the Site Monitoring Bundle for logging protection issued and zone checks.
Common mistakes
- Assuming ear defenders solve everything. They're the last resort. An inspector will want to see you tackled noise at source first.
- Ignoring cumulative exposure. Ten minutes of grinding here and there adds up across a shift. It's the daily total that matters.
- Over-protecting. Too much attenuation can isolate a worker from warning shouts and reversing alarms. Match protection to the level of noise.
- No health surveillance. If you're regularly above the upper action value and you're not doing audiometry, you have a gap.
FAQ
Do I need to physically measure noise with a meter?
Not always. For many tasks you can estimate exposure using manufacturers' declared noise data and how long tools are used. Measurement helps where exposure is borderline or the environment is complex, but a reasoned estimate can be suitable and sufficient.
Is hearing protection enough on its own?
No. The law expects you to reduce noise at source and through organisational controls first. Hearing protection is the last line of defence, and above 85 dB(A) it becomes mandatory alongside — not instead of — other controls.
When does health surveillance become a legal requirement?
Where workers are regularly exposed above the upper exposure action value (85 dB(A)), or above the lower value where there's a particular concern about their hearing. Audiometry is the usual method, and you must keep and act on the records.
Does a self-employed contractor need to worry about this?
Yes. If you're exposing yourself to high noise levels you should still assess and control the risk — hearing loss doesn't check your employment status. And if you bring anyone else on site, the duties apply fully.
Get your noise paperwork sorted
Loud work is everyday work in construction — but hearing loss doesn't have to be. Start with a written assessment, control noise at source, and keep the records that show you did. The Site Monitoring Bundle covers noise, HAVS, welfare and plant checks in one purchase, or if you want every template — risk assessments, RAMS, monitoring and toolbox talks — SafetyPod membership gives you unlimited access for £69 a year. Templates support competent people; the judgement on site is still yours.