Influencing companies to purchase lower noise tool consumables Chris Steel 1 Health & Safety Executive Queen Elizabeth House, 1 Sibbald Walk, Edinburgh, UK EH8 8FT Antonia Hawker 2 Health & Safety Executive Science Division Laboratories, Buxton

ABSTRACT This paper shows how targeted basic research and existing regulations can influence dutyholders (business owners) to use lower noise consumables on their power tools (saws, drills, grinders). We will show; (1) how existing regulations should change buying habits, (2) how target basic research inform enforcement, (3) why lower noise consumables should be the standard in some industries, (4) how to influence industry through advice and, (5) potential enforcement. New data will show it is possible to get a 5 dB reduction by buying the right combination of grinder products. The paper describes a regulatory method that combines research and enforcement to reduce noise risk. The paper may be of interest to, health and safety regulators, tool manufacturers, noise consultants, and purchasing managers. 1 Introduction

We will show how targeted basic research and existing regulations are used to influence dutyholders (business owners) to buy lower noise consumables for their power tools. If dutyholders buy lower noise consumables, the risk of noise induced hearing loss will be reduced. When visiting a construction site, you see noise being created by hand-held power tools. Hand-held grinders are used to cut, sand, fettle, and grind. The dutyholder thinks the jobs or tasks cannot be changed because the chance to do this was when the building was being designed. There are quieter tools, but for the jobs and tasks on site angle grinders are the only suitable tool. It is not possible to rotate the workers and hearing protection is being used. This leaves one control method; is it possible to buy angle grinders or consumables that make less noise? Health and safety inspectors find these issues every day when visiting construction sites. Those responsible for the risks did not know they had to look for quieter tools; or did not know quieter tools were on the market; or could find noise levels but did not consider their importance. Health and safety regulations in Britain expect dutyholders to buy the quietest machines, power tools and consumables that can do the required job efficiently. Research backed evidence would help them select the best low noise tool for the job.

1 c/o chris.steel@hse.gov.uk

2 Chris.steel@hse.gov.uk

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Buying quiet can achieve significant risk reduction because a drop of 3dB in the exposure levels halves the risk. If dutyholders buy the quietest product when they can replace a tool, machine, or consumable they should see a reduction in noise. Some workplaces use lots of large noisy fixed ma- chines, so it takes longer to achieve change. But construction workers are usually exposed to noise from small handheld power tools which can be easier to change. How do we get dutyholders to buy quiet? How can we find out what makes a power tool quieter? How can we get this information to the dutyholders so they make the right decisions? How can we use health and safety regulations to reduce the risk of hearing loss? Using grinding discs as an example, we will outline an approach called ‘control efficiencies.’ The approach checks the feasibility of a control measure, how viable it is to take enforcement and what kind of enforcement is appropriate. We will show; how existing regulations can change buying habits; why lower noise consumables should be the standard in some industries; how targeted research in- forms compliance; how to influence industry through information and guidance; and, how to outline enforcement expectations. 2 How existing regulations and guidance change buying habits

Dutyholders should buy quiet; it is required by the Control of Noise at Work Regulations 2005 (CNWR) [1]. Buying quiet means buying or hiring machines, tools and consumables that can do the job efficiently at the lowest level of noise. CNWR Regulations 6(3)(b) states [1]: The actions taken by the employer…shall be based on the general principles of prevention set out in Schedule 1 to the Management of Health and Safety Regulations 1999 [2] and shall include consid- eration of choice of appropriate work equipment emitting the least possible noise, taking account of the work to be done. Doing the following should be enough to meet the regulations [3]: 68 Considering noise when re-equipping can be the most cost-effective way of reducing noise expo- sure. For many types of equipment there are models designed to be less noisy. If your workplace contains just one noisy machine, the noise exposure reductions from substituting a quieter machine can be immediate. If you have many noisy machines, a positive purchasing/hiring policy which takes noise into account when selecting machinery will assure you of noise exposure reductions in the medium to long term. 69 You should be able to identify quieter machines from noise information supplied with equipment. You may want to ask potential suppliers for information on the noise emission of machines under the conditions of intended use and use that information to compare machines. Where you find it is not possible to purchase machinery which achieves workers’ noise exposures below the EAVs (Exposure Action Value), you will find that keeping a record of the reasons for the purchasing decision made will help guide future action, e.g., by providing those responsible for future machine specifications with information on improvements that are needed 166 When hiring or buying equipment you should consider manufacturers’ noise information along- side other factors (e.g., general suitability, efficiency). Be cautious when using manufacturers’ noise emission data. You should make sure that the data are representative of the way you intend to use the

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equipment. Comparing the noise data from different machines of the same type can help you to select quieter equipment for your workplace. More detail is given on the HSE website [4] Your ‘buy quiet’ policy should involve the following:

 consider at an early stage how new or replacement machinery could reduce noise levels in

the workplace – set a target to reduce the noise levels if possible  make sure you specify a realistic noise output level for all new machinery, and check that

tenderers and suppliers are aware of their legal duties  produce a list of machinery suitable for your intended use and their suppliers

Ask the potential suppliers about the likely noise levels under the particular conditions in which you will operate the machinery, as well as under standard test conditions. If you ask the same question to all suppliers, you can compare information. Noise output data will only ever be a guide as many factors affect the noise levels experienced by employees, but it will help you to buy quieter machines. You should also:

 ask for a statement from all companies who are tendering or supplying to say their machinery

will meet your company noise target specification  only purchase or hire from suppliers who can demonstrate a low-noise design, with noise

control as a standard part of the machine, not as a costly optional extra  check that your noise specification is met when the machinery is delivered and installed on

site  keep a record of your decision process and reasons if noisy machinery has been purchased

with information about where improvements are necessary to help prepare future machine specifications  ask your trade bodies to highlight noise problems to your suppliers. If you suspect the manu-

facturer’s noise information is poor, report this to your market surveillance authority  tell other employers in your industry when you find quieter machinery

You may want to include a penalty clause in your contract if guaranteed noise emission values are exceeded. There are regulatory requirements on the suppliers of machinery. An outline of the duties on machin- ery and tool manufacturers are set out on HSE’s website [5]. The Supply of Machinery (Safety) Regulations (SMR) [6] require new equipment to be designed so the risks from noise are reduced to the lowest level. This includes accounting for technical progress in noise control and supplying information about noise risks. 3 How targeted basic research informs enforcement.

Regulators can use research to test new controls and promote the ones that work. The problem with new noise controls is that it can take a long time to check their feasibility and viability. Feasibility makes sure the new control works and it actually reduces noise exposure. Viability checks the new control is worth adopting. It is ‘reasonably practicable’ (the impact of a control measure on risk against the overall cost to industry) and the regulator can ask for it to be used. The approach outlined in this paper is called control efficiencies, outlined in Figure 1.

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Figure 1 – Control Efficiencies approach for establishing expected risk controls

1. Establish intelligence . Research and literature reviews of a specific control solution. 2. Feasibility check. Performance testing and impact prediction, practical limitations on

use/adoption.

GATE. Decision point for resourcing further development. 3. Gather and Review. Gathering scientific evidence and commissioning measurement re-

search. 4. Determine control. Check control works both in laboratory conditions and in workplaces

and is reasonably practicable. 5. Test and confirm. Publish , via research events and academic publications.

GATE. Decision point for determining the benefit and practicability of control and com- mitment of further resources. 6. Design Leading indicators. What makes up the control solution needed to prevent ill health. 7. Publish Controls. Explain controls and provide guidance on application with supporting re-

search reports.

Control Efficiencies 1 Establish intelligence 2 Feasibility r GATE 3Gather&] [4 Determine [| Review Control 1 3 Test & Confirm GATE (CL Sbesenteeainginaeators [5 7 Publish | [BEmbedin] | 9Agree Controls || industry} | ee & Brief r GATE 10 Enforce TiReview

8. Embed with Industry. Support adoption of controls within industry through guidance, face

to face promotion and articles in trade press to raise awareness. 9. Determine enforcement expectations. Initial enforcement expectations are set out in oper-

ational guidance to support inspectors applying HSE’s Enforcement Management Model based on what is required to achieve control and compliance with the law, and what poor control and non-compliance looks like.

GATE. Agreeing activities to establish the improved control expected. 10. Enforce. A range of activities which focus on the industry, task, or tools where the change

is needed, which include publicity campaigns, targeted inspections and where necessary, prosecution. 11. Review. Assess the impact of the improved control and whether compliance is being sus-

tained in practice, feeding back into further targeted information or enforcement if needed.

4 Why lower noise consumables should be the standard in some industries

Consumables are the working end of a power tool: the cutting head, blade, drill bit, moil, disc, or abrasive belt. Lower noise consumables should be expected in some industries because: 1 They may be the only reasonably practicable way to reduce noise. Industries where most of the noise exposure comes from the use of handheld power tools rely on hearing protection because it is not possible to distance the worker from the tool or to enclose the tool. 2 Noise levels given by power tool manufacturers do not always represent the tool in use. HSE research [7] showed 26% of the chainsaws tested in a market surveillance project did not clearly show the noise hazard. 3 The dominant source of noise for many power tools is the interaction of the consumable with the material being worked. HSE data from 1995 showed that hammer drills boring into con- crete produce noise levels of around 102dB(A) at the operator’s ear [8]. 25 years later, even allowing for significant developments in power tool design, hammer drills doing the same task produce 101dB(A) at the operator’s ear [9].

4.1 Angle Grinder Example The use of a noisy power tool is the accepted standard in some industries. A clear example is the use of hand-held grinders for the removal of welding slag on metal in the construction industry. When using flux coated welding processes, slag lines can develop along the length of the weld. These lines need to be removed. The contents of the flux can make some slag lines more difficult to remove than others and for these, a grinder is normally used. For this removal process:

 It is not always possible to use an alternative welding process which does not result in slag lines forming.  There is no alternative design process that would end the use of the power tool. Large, auto- mated machines are suited to making similar items over and over so may not be suitable in construction steel fabrication.

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 It is difficult to set up a controlled workspace. Removal of welding slag happens in workshops and on site. The location of the weld on the workpiece can be different each time and the location of the work piece can change.  Angle grinders are a commodity product. If alternative methods are expensive (i.e., more than £50), they are considered less practicable.  Angle grinders are ubiquitous. They are found in most workplaces and are a go-to tool for several other tasks (descaling, bevelling, sanding, cutting, removing welding splatter, polish- ing).

The following shows how angle grinders were evaluated against the first stages of the control effi- ciencies approach.

Establishing Intelligence . We saw grinder disc manufacturers claiming reductions in hand-arm vibration exposure. This information came to us via dutyholders asking whether these claims were valid. While check- ing the vibration data on the manufacturers website it was found that some also claimed lower noise levels. We contacted the manufacturers and asked them to confirm their noise results. They were prepared to stand by their data and have their products independently tested. We assessed the data and believed it was worth further investigation. Feasibility We sent a research request to our Science Division team to look at the vibration and noise performance of the sort of consumables used on angle grinders. We wanted to repeat the man- ufacturers tests and assess the practicability of the consumables. We also investigated the size of the problem, the potential impact of the improvement and the cost to industry. Gathering existing Data, Testing in-house reviewing and confirming performance The research results were reported in HSE report Lower Emission Solutions for Angle Grind- ers [10]. A summary of the noise data is reproduced in Table 1 below.

Table 1 – Lower Emission Solutions for Angle Grinders, Noise results

Machine Inserted tool Noise dB(A)

Grinding

Standard 125 mm Standard 100

Standard 125 mm 60 grit Flap disc 89

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Table 1 – Lower Emission Solutions for Angle Grinders, Noise results

Machine Inserted tool Noise dB(A)

Standard 125 mm Fibre disc and rubber backing pad 95

Standard 125 mm Ceramic grinding disc 98

Standard 125 mm 40 grit flap disc 87

Cutting

125 mm standard Standard cutting disc 87

125 mm standard Carbon disc 87

125 mm standard Diamond disc 98 Table 2 outlines which consumable is best for vibration, dust, and speed of use.

Table 2 – Assessment of practicability issues

Wheel Lowest vibration Lowest noise Lowest dust Quickest

Standard disc

Flap disc 

 

Fibre disc and rubber backing

pad

Ceramic disc 

The results suggest that some grinding and cutting discs can be quieter. Rubber backing pads made a difference of around 5dB but cost about £19 however this is a single purchase so can be used many times. It is likely that it could be used as a control measure in steel fabrication where grinders are use often enough to justify the cost but where other control measures are not practicable. How do we present this information to industry, check the viability of the controls, and get it adopted? 5. How to influence industry through advice

Section 11(2)(c) of the Health and Safety at Work etc Act 1974 states [11]: The Executive (HSE) shall— make such arrangements as it considers appropriate to secure that the following persons are provided with an information and advisory service on matters relevant to those purposes and are kept informed of and are adequately advised on such matters - (i)government de- partments, (ii)local authorities, (iii)employers, (iv)employees, (v)organisations representing employ- ers or employees, and (vi)other persons concerned with matters relevant to the general purposes of this Part. The HSE implements Section 11(2)(c) through a wide range of information including regulations, codes of practice, publishing guidance (websites or documents) and, where appropriate through direct engagement with industry and third parties. The control efficiency approach helps drive the adoption of improved controls. This is achieved through action 6,7 and 8 from the flow chart in Figure 1.

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5.1 Design Leading Indicators A leading indicator is “ Something that provides information that helps the user respond to changing circumstances and take actions to achieve desired outcomes or avoid unwanted outcomes. Their role is to help improve future performance by promoting action to correct potential weaknesses without waiting for demon- strated failures.” [12] Leading indicators tell us that ill health could occur if a risk is not managed. A leading indicator could be a workplace noise survey showing that noise is typically above the upper action value because control measures are not in place. Lagging indicators tells us that control was not achieved. A lagging indicator would be a diagnosis of work induced hearing loss. For angle grinders a leading indicator for the prevention of hearing loss could be based on the duration of poorly controlled work, for example, the risk is increased when, grinding welds with diamond discs for more than 20 minutes on at least 3 days out of 5. But it could also be based on the process, for example grinding more than 3.2 lineal metres of welding per day for at least 3 days a week. 5.2 Publish Information about Controls Initial publishing highlights a risk and its control measure. Data and expected control measures can be published in academic and trade journals. For the grinder example, publication would target people with an understanding of workplace noise or an interest in metal work. The publication of this paper at Internoise is part of the initial publishing process, although it is secondary to its main purpose of outlining the control efficiencies approach. If no significant problems are raised, the control can be published by the regulator. Publicising the control measure in the regulators own information may be the start of raising aware- ness or it could reinforce parallel industry information. This may start with the regulators website and over time become included in codes of practice, but this would depend on the outcome of the next element in the approach. 5.3 Embed with Industry The control method is adopted by trade associations and professional bodies. A typical output from this is a trade association fact sheet, guidance document or membership code of practice. It is a chance for the regulator to get more feedback on the practicability of the control and to find the areas of agreement between stakeholders. Talks or presentations undertaken by the regulator would also high- light the practical application of the control method. If significant concerns are raised, it is possible that the adoption of the control would be reviewed and reconfigured. The regulator may provide explicit endorsement of the final industry held advice product or support it indirectly. There is policy on the use of the regulators logo [13] in Britain. However, a limited endorsement is often suitable, e.g. “The Health and Safety Executive provided support to the ……in producing this guidance, which is aimed at improvements within the Workplace Noise Consultancy industry. This guidance may go further than the minimum you need to do to comply with the law regarding health and safety” Adopting a control measure may require time to bed in depending on the scale of the issues. Depend- ing on the size of the risk and the industry, and the reach of the relevant trade associations and re- sponse from dutyholders, this could take months or years.

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6. Potential enforcement.

The control efficiencies approach includes developing the basis for enforcement by inspectors. For a new control measure, we often set out our initial enforcement expectation (IEE) in likely risk scenar- ios, although inspectors take account of a wide range of indications when considering enforcement action. The process we use relates to part 9 of the flow chart (Figure 1). HSE enforcement must be consistent, proportionate, targeted, transparent, and accountable. [14]. The Enforcement Management Model [15] is the tool HSE uses to meet these standards. 6.1 Angle Grinder Consumables as an enforcement example

The following explains how the HSE Enforcement Management Model (EMM) could be applied to requiring lower noise angle grinder consumables (NOTE. This is a theoretical example): Which regulation applies?

In the grinder example our leading indicator (See Section 5.1) is using a grinder enough to put the operator above the upper exposure action value. This means Regulations 6(2) applies. If any employee is likely to be exposed to noise at or above an upper exposure action value, the employer shall reduce exposure to as low a level as is reasonably practicable by estab- lishing and implementing a programme of organisational and technical measures, excluding the provision of personal hearing protectors, which is appropriate to the activity. [1] How does Regulation 6(2) relate to lower noise equipment? The companion Regulation 6(3) describes ways to achieve Regulation 6(2) (see Section 2). One of the control measures is sourcing lower noise equipment but specific tools or consum- ables are not mentioned. This is because the regulations are not prescriptive, they set goals and dutyholders are expected to look for ways to achieve those goals. The use of alternative grinding discs as a reasonably practicable control measure would typically be given as advice. How significant is the risk? Noise is considered a serious ill health effect and the likelihood of someone developing work induced hearing loss before retirement should be nil or negligible [16]. Figure 2 shows the risk gap matrix used by HSE. Any assessment starts by assessing the exposure before hearing protection is used. For our example, the likelihood of ill health is ‘possible’ if a grinder is used regularly and frequently for more than 20 minutes each day. This is based on the LEP,d (Daily exposure level over 8 hours) exceeding 85dB.

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Figure 2 HSE Noise Topic Pack risk gap matrix

TIRELIHOOD, “APPLICATION? oescrrron a wieroneratton | prowasie | possiie | REMOTE | vegas seRi0us | — noise noveeD oscteae® | Leectt6o1 | Leoct008e | Lost vent | Meamngioss | ‘Saisie | (rae ES ‘*

The size of the risk gap between the expected benchmark risk and the actual risk is then as- sessed, shown in Figure 3. If the bench-mark standard is nil-negligible risk of serious ill- health/injury and the actual risk of serious ill-health is possible, then the risk gap in HSE’s EMM is ‘extreme’.

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Figure 3 – HSE Risk Gap Model

What enforcement would be suitable? Inspectors take account of the relevant standard of control expected. Standards are considered either:  defined (e.g., set out in a regulation or approved code of practice),  established (e.g., set out in HSE guidance or industry codes of practice),  interpretative (e.g., put forward by HSE or derived from first principles).

Hearing protection is already well established as an expected control for the risk of hearing damage. Requiring lower noise consumables in a particular scenario would be considered an interpretive standard based on opinion, often of a specialist inspector. However, if the use of rubber backed grinding discs was common in industry practice, this would then be considered an ‘established’ standard. Figure 4 shows the initial enforcement expectation for inspectors would be an improvement notice and prosecution would be considered if the control is con- sidered “established”.

‘Consequence | Ukeinood cm im = | See ri Possibie | | standard £3 Probable [seman [Renae BB |e" Poe 22 Probable 28 | Seo [Remote 2 |pesorar [rosso = ew Probable Tiahoad Pssble [Remote | Nueg Consenence Serious personal injury

Figure 4. HSE Initial Enforcement Expectations

Other factors and the general standards and conditions of the workplace and duty holder’s arrangements affect the final enforcement decision, which may result in a lower or higher level of enforcement. Enforcement & Review The last stages of the control efficiencies approach are to enforce and review. Enforcement is taken by inspectors appointed under the Health and Safety at Work etc Act and would be based on lower noise consumables being reasonably practicable control measures. Inspectors may encounter this issue during:

1 Targeted inspection programmes. For example, inspections focussing on steel fabrica- tion workshops where grinding of welding slag is likely to be in use. Targeted cam- paigns can be extended if there is evidence of poor control. 2 Specialist led interventions. Specialist inspectors may use their in-depth knowledge of risks and expected controls to assess compliance for more complex issues. 3 Any intervention by an inspector. All inspectors would respond to risks of serious ill- health/injury during any inspection or investigation when they come across an absence of control (e.g. grinders but no use of lower noise consumables).

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We review our enforcement to confirm HSE’s Enforcement Policy Statement considering issues such as:

1 Is the standard being consistently complied with? 2 Has industry fully adopted the control or are some dutyholders resisting implementing the expected control measure? 3 Is there some unexpected issue preventing things being done differently? 4 Has the industry agreed that a control is reasonably practicable, but failed to ensure workers are implementing the control measure? 5 Is further influence required through extended or enhanced regulatory interventions? 6 Can industry do more to ensure implementation?

7. Conclusion

Our aim was to show how targeted basic research and existing regulations can influence dutyholders (business owners) to use lower noise consumables on their power tools.

Risk gap | Standards Initial enforcement Consider ‘expectation prosecution? (to secure compliance with the law) Extreme | Defined iproverent Notice ‘Established | Improvement Notice Improvement Notice interpretative |

We outlined an approach to enforcing new control measures (noise related or otherwise) based on evidence and analysis, preferably with support from industry to start taking up improved controls, in line with HSE’s Enforcement Management Model. This process is called control efficiencies. To illustrate this process, we used the work undertaken by HSE Science Division on noise from angle grinder consumables. We showed that using fibre discs with rubber backing pads can reduce noise by around 5dB, but more consideration is required before establishing this in industry as an enforceable standard in a wide range of potential circumstances. If found to be broadly reasonably practicable, HSE could consider enforcing its use where grinders are used and workers are at risk. Test data alone is not enough for something to be considered a reasonably practicable control. New controls may be too expensive, cause other hazards or have limited uses. Ensuring new controls are adopted needs to be targeted on the industries where the risk is most likely to be realised. 8. Acknowledgements

We would like to thank the help of HSE Science Division for their support in this work. M Molloy for her help in developing the control efficiencies approach and M Calcutt for reviewing the paper. 9. Disclaimer The views expressed in this paper are those of the authors alone and do not necessarily reflect HSE policy.

10 References

1 HMSO, Control of Noise at Work Regulations, Statutory Instrument, Crown Copyright, London (2005). 2 HMSO, Management of Health and Safety Regulations, Statutory Instrument, Crown Copy- right, London (1999). 3 HSE, L108, Controlling Noise at Work - the Control of Noise at Work Regulations 2005 – Guidance on Control, Third Edition, The Stationary Office, Norwich (2021). 4 HSE Website, How can I choose quieter equipment and machinery? htt ps://www .hse.gov.uk/n oise/ch oosequieter.htm, Bootle, (2022). 5 HSE Website, Advice for Manufacturers, https://www.hse.gov.uk/noise/advice-for-manu- facturers.htm, Bootle, (2022). 6 HMSO, The Supply of Machinery (Safety) Regulations, Statutory Instrument, London (2006). 7 Hawker A, Patel J, Market surveillance – Chain-saws: Comparison of noise hazard reported in instructions with real-use noise hazard, Health and Safety Research Report, Buxton (2022). 8 Ferguson I, 73/1995 Dust and noise in the construction process, HSE Contract Research Re- port, HMSO, London (1995). 9 Shanks E, Hunwin G, Brueck E, Steel C, Noise and hand-arm vibration exposures and cur- rent control practices in the construction industry. Report Number HG/2020/08, HSE Sci- ence Division, HSE Buxton (2020).

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10 Hawker A, Lower emission solutions for angle grinding Report Number HG/2021, HSE Sci- ence Division, HSE Buxton (August 2021). 11 HMSO, Health and Safety at Work (etc.) Act 1974, Statutory Instrument, Crown copyright, London (1975). 12 Rogers A, Evans R, Wright M, Leading indicators for assessing reduction in risk of long la- tency diseases, RR734, HSE Books, Crown copyright, Norwich (2009). 13 HSE website, Statement of principles for joint badging/endorsing third party guidance, https://www.hse.gov.uk/resources/third-party.htm , Bootle (2022). 14 HSE, Enforcement Policy Statement, DRAFT Enforcement Policy Statement (hse.gov.uk), Published online, Bootle (2015). 15 HSE, Enforcement Management Model – Operational Version 3.2. Enforcement Manage- ment Model - Operational (hse.gov.uk), Published online, Bootle (2013). 16 HSE, Topic Inspection Pack- Noise, Internal publication, https://www.hse.gov.uk/foi/inter- nalops/fod/inspect/noise.pdf , Bootle, (Revised May 2008).

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