HSE puts waste and recycling sites on their inspection plan

Local authorities operating waste transfer stations and recycling facilities may want to take a fresh look at their noise management arrangements following HSE's recent focus on occupational noise and hearing protection. While most dutyholders associate noise inspections with hearing loss, inspectors are increasingly interested in another question: Can workers hear safety-critical warning signals while wearing hearing protection?

This issue is particularly relevant in large scale waste and recycling environments, where employees often work alongside loading shovels, telehandlers, reversing vehicles, compactors as well as large transfer machinery. In these settings, hearing protection may be essential, but if it prevents workers from detecting reversing alarms, vehicle movement warnings, fire alarms, or communications, it could introduce a safety risk. HSE guidance specifically warns against over-protection that reduces sound at the ear to unnecessarily low levels and may make warning signals difficult to detect.

Recent HSE inspections found that many employers had not checked whether workers wearing hearing protection could still hear the warning signals that keep them safe. According to HSE, this was one of the most common gaps identified during visits to noisy workplaces. HSE reported that around 95% of employers inspected had not verified that workers could detect important warning alarms while wearing their hearing protection. That finding is likely to attract attention from inspectors visiting larger waste and recycling facilities. Ask your workers “can you hear safety critical signals while wearing your hearing protection, if they say yes that is good, if they say no, then review their hearing protection or your safe systems of work.

HSE, has also been promoting the CUFF approach as a simple way for employers to assess whether hearing protection is working in practice. The message asks employers to check the Condition of hearing protection, whether it is being Used correctly, whether it is Fit for Purpose, and whether it properly Fits the Ear. HSE inspection findings suggest that shortcomings in all four areas remain common across industry.

Noise inspections are also examining broader compliance with the Control of Noise at Work Regulations. Inspectors may ask whether workers receive suitable information, instruction, and training, and whether employers have introduced health surveillance for workers regularly exposed to high levels of noise.

Importantly, inspectors are unlikely to view hearing protection as the complete solution. HSE continues to emphasise that personal hearing protection is the last line of defence and should not be used instead of engineering or organisational noise controls. Employers should be prepared to explain what steps they have taken to reduce noise at source and minimise exposure wherever reasonably practicable.

Chris Steel, Principal Specialist Inspector (Noise & Vibration) at Health and Safety Executive