Reclassifying ear defenders as category 3, comparable to respiratory protection products, proves the gravity of harmful occupational noise risks. From April this year, the new EU PPE Regulation to supersede the 89/686/EEC PPE Directive will be in place.
Unlike the Directive, which had to be transposed into national law by each state, the new Regulation is a binding legislative act and applies automatically in its entirety across the European Union.
As part of a new way of looking at risk, the new (EU) 2016/425 PPE Regulation recategorised hearing protection from Category 2 Risk PPE (Intermediate) under the old Directive, to Category 3 Risk (Complex).
Hearing protection is therefore now classified in a comparable way to PPE products such as respiratory protection equipment, fall from height prevention equipment and protective products against risks from contact with hazardous substances, rather than those like safety eyewear and high-visibility clothing, which remain in Cat 2.
Reasons for the change
The revision of hearing protection from Cat 2 to Cat 3 takes into account the seriousness of the risk to human hearing from harmful occupational noise exposure, as well as developments in technology since the old 1989 Directive.
Damage to hearing is a long-latency hazard because it is not immediately obvious. It is undetectable while it is happening, but by the time it is discovered, it is too late. Because of this, greater control over the manufacture and sale of hearing protection is needed to protect wearers.
While Cat 2 protection products must be submitted for test in order to gain CE approval, they don’t ever need to be retested.
Under Cat 3, however, products must be initially submitted for test, plus samples must be tested annually, unless the product is manufactured under an ISO 9001 or other accredited quality management scheme. Cat 3 products will therefore continue to meet the requirements of the latest versions of the standards.
This change will remove the use of sub-standard and possibly counterfeit ear defenders, and lead to the design, manufacture, importation, supply, sale and distribution of improved products.
Why hearing protection is necessary
The PPE Regulation includes noise under Cat 3 as a risk that may cause very serious consequences such as irreversible damage to health in the long term. Mining, manufacturing, quarrying, demolition, road-working, heavy engineering and construction are all examples of industries that use loud machinery or power tools where irreversible noise-induced hearing impairment and loss are common.
More than 10 million people in the UK have a degree of hearing loss, which can gradually creep up over many years, yet many take their ability to hear for granted and adopt the attitude that loss of hearing will never happen to them.
Exposure to undue noise at any level can be dangerous, but exposure to sound at or above 85 decibels (dB) can irreparably damage hearing over time. In addition, sound intensity doubles with every extra 3dB. For example, sounds at 88dB are twice as intense as sounds at 85dB, meaning that for every 3dB increase in volume, hearing damage can occur in half the time.
In addition, noise creates stress, interferes with communication, acts as a distraction, makes warnings harder to hear and can lead to workers feeling stressed, increasing the risk of accidents.
Hearing loss caused by noise is completely avoidable. Acoustic earmuffs, or ear defenders, are designed to protect the wearer from extreme noise in extreme environments. They cover the ear completely and are easy to fit and remove as required, so are suitable for intermittent loud noise exposure or when machinery is being switched on and off.
In the case of hearing, prevention is a whole lot better than cure, especially as there is no cure. No worker must be exposed to the average exposure limit value of 87dB, and peak sound pressure of 140dB, with or without hearing protection.
Hearing is precious. It must be looked after, both at work and leisure. However, with better regulation under Cat 3, procurers, health and safety professionals and wearers can all be reassured that their hearing protection will do the job it is supposed to do.
Read the EU Regulation 2016/425 on PPE here
Matthew Judson is technical director at JSP
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