The Control of Noise at Work Regulations 2005 are the UK rules that require employers to prevent or reduce the risk of hearing damage from noise at work. They apply to almost every workplace, and warehouses, workshops and factories are among the places where they matter most: forklifts and powered trucks, compressed air, power tools, conveyors and roller shutters all add up over a shift. This guide explains the three action levels, what employers must do under regulations 5 to 10, and where storage for hearing protection fits in.
What are the Control of Noise at Work Regulations 2005?
The regulations (SI 2005/1643) are made under the Health and Safety at Work etc. Act 1974 and came into force for most sectors on 6 April 2006. They replaced the earlier Noise at Work Regulations 1989. The duty is to protect people from the risk to their hearing from exposure to noise, and the Health and Safety Executive publishes guidance in L108, Controlling noise at work, which is the best plain-English reference for what the law expects in practice.
The duties are owed to employees and, so far as is reasonably practicable, to other people who may be affected by the noise, such as agency staff, contractors and visitors. The regulations sit alongside the Management of Health and Safety at Work Regulations 1999, which set the general duty to assess risk.
The noise action levels and limit values
The regulations work through three trigger levels. Each is expressed two ways: as a daily or weekly personal noise exposure, which averages the noise over the working day or week, and as a peak sound pressure, which captures sudden loud impacts such as hammering or a compressed-air blast.
| Level | Daily or weekly exposure | Peak sound pressure | What it triggers |
|---|---|---|---|
| Lower exposure action value | 80 dB(A) | 135 dB(C) | Risk assessment, information and training, and hearing protection made available to anyone who asks for it |
| Upper exposure action value | 85 dB(A) | 137 dB(C) | A programme of noise control, hearing protection that must be worn, hearing protection zones, and health surveillance |
| Exposure limit value | 87 dB(A) | 140 dB(C) | A limit that must not be exceeded, taking account of the protection that hearing protection provides |
The exposure limit value is the one people most often misread. It is measured at the ear after allowing for the hearing protection being worn, so it is not a licence to issue earplugs and carry on. If people are exposed above the limit, the employer must take immediate action to bring exposure down and find out why the limit was exceeded.
HSE gives a rough rule of thumb for deciding whether a closer look is needed: if people have to shout to be understood by someone two metres away, the noise may be at or above the upper action value, and if they struggle to hold a normal conversation at that distance it may be around the lower value. It is a prompt to assess, not a measurement.
What employers must do: regulations 5 to 10
- Regulation 5, risk assessment. Where employees are likely to be exposed at or above the lower exposure action value, you must assess the risk to their hearing. That means identifying where the noise is, who is exposed and for how long, and what could be done about it. The significant findings must be recorded if you employ five or more people, and the assessment should be reviewed if it is no longer valid or if circumstances change.
- Regulation 6, eliminate or reduce exposure. Risk from noise must be eliminated at source or, where that is not reasonably practicable, reduced to as low a level as is reasonably practicable. Hearing protection is the last resort, not the first control. Typical measures include buying quieter equipment, maintaining machines, isolating or enclosing noisy processes, and limiting the time people spend in the noisiest areas.
- Regulation 7, hearing protection. Where exposure reaches the lower value, hearing protectors must be provided to anyone who asks. At the upper value they must be provided and worn, and the employer must mark hearing protection zones with signs and, where practicable, restrict access to them.
- Regulation 8, maintenance and use of equipment. Noise controls and hearing protection must be kept in good working order and used as intended, and employees must use them and report defects.
- Regulation 9, health surveillance. Employees who are regularly exposed above the upper action value, or who are at risk for another reason, must be placed under suitable health surveillance, which in practice means hearing checks.
- Regulation 10, information, instruction and training. People exposed at or above the lower value must be told about the risks, the controls in place, how to use and look after hearing protection, and how to report problems.
Noise in a warehouse or workshop: where to look first
You do not need a sound level meter to start. Walk the site and list the noisy tasks and machines, then ask who is close to them and for how long. Common sources in warehouses and workshops include:
- Powered handling equipment such as forklifts, stackers and powered pallet trucks, particularly in enclosed areas where noise builds up.
- Compressed air lines, guns and blow-offs, which produce sharp peaks of noise.
- Power tools, grinders, saws and impact tools at workbenches.
- Metal-on-metal impacts, such as dropping steel tools into drawers, slamming locker doors or dragging cages and trolleys across a concrete floor.
- Dock doors, roller shutters, conveyors and extraction fans.
If the assessment shows the noise is well below the lower action value, record that conclusion and the reasoning, and review it when equipment or layout changes. If it is close, a competent person can take measurements. HSE guidance covers how to measure and how to treat the results.
Reducing noise before reaching for hearing protection
Regulation 6 puts control at source ahead of hearing protection, and the same hierarchy that applies to other hazards applies here. Practical measures for a warehouse or workshop include:
- Buy quieter. Noise output is a legitimate selection criterion when choosing work equipment. Where equipment is provided under PUWER, think about noise alongside suitability, guarding and maintenance. Our guide to PUWER explains the wider duties.
- Maintain it. Worn bearings, loose panels and dry castors all make equipment louder than it needs to be.
- Separate people from noise. Move noisy processes away from where people work, and use barriers or enclosures where that is practicable.
- Limit time and numbers. Rotate tasks so that nobody spends a full shift in the noisiest area.
- Design out impacts. Controlled-close drawers, cushioned shelving and handling aids can cut the clatter of metal tools and parts being dropped or dragged.
Hearing protection storage
Where hearing protection is needed, the PPE at Work Regulations 1992 also apply. They require employers to provide suitable accommodation for PPE when it is not in use, and to maintain it in efficient working order and good repair. Ear defenders and earplugs that are left on a bench, in a pocket or in a damp coat end up dirty, damaged or lost, and then either do not fit or do not get used. Our guide to the PPE at Work Regulations 1992 explains the duty in more detail.
Storage does not have to be elaborate, but it should be somewhere clean and dry, close to where the protection is needed and easy for users to find. Depending on the site, that might mean:
- A compartment in a personal locker for staff who carry their own ear defenders or reusable earplugs.
- A lockable industrial cupboard for issuing spare hearing protection and replacements at a workstation or dock office.
- A shelf, drawer or panel in a workshop storage system next to the noisy machine, so protection is at hand before the machine is switched on.
Whatever you choose, make it part of the routine: check items for damage before each use, replace worn ear cushions and headbands according to the manufacturer's instructions, and take anything damaged out of use straight away.
Hearing protection zones and signs
Where noise reaches the upper exposure action value, the employer must designate hearing protection zones and mark them with the mandatory ear protection sign. Where it is practicable, access to these zones should be restricted. Think about what this means for your layout: a zone has to be clearly bounded, so that someone walking in knows when they have entered it, and hearing protection needs to be available at the entrance rather than at the other end of the building.
Common mistakes to avoid
- Handing out earplugs without doing a noise assessment first.
- Relying on hearing protection when the noise could be reduced at source.
- Assuming one measurement is enough, when new equipment, extra shifts or a different layout can change exposure.
- Ignoring peak noise from sudden impacts and compressed air because the daily average looks acceptable.
- Forgetting agency workers, visitors and contractors who pass through noisy areas.
- Providing no suitable storage, so hearing protection ends up lost, dirty or damaged.
- Skipping training, so people do not know how to fit hearing protection properly.
Where to find the official guidance
The regulations are on legislation.gov.uk as SI 2005/1643, and HSE publishes L108, Controlling noise at work, together with practical noise pages for employers. If you have a particularly noisy process, take advice from a competent person who can measure exposure and recommend controls. This guide is general information for UK workplaces and is not legal advice.
Related reading: Workplace (Health, Safety and Welfare) Regulations 1992 and Manual Handling Operations Regulations 1992.