Give noise a voice so it can be better understood. Sebastian Wschiansky 1 Federal Office for the Environment (FOEN) Noise and Non-Ionising Radiation Division Aircraft, Industrial and Shooting Noise Section Monbijoustrasse 40 3003 Bern, Switzerland

ABSTRACT A major purpose of the European Outdoor Noise Directive (OND) 2000/14/EC is to provide to potential buyers of outdoor machinery relevant noise information to foster the purchase of low noise models, hence incentivizing manufacturers to produce over time quieter machinery. How- ever, the results of this strategy have yet to meet the expectations. Among other issues, the actual noise label for equipment subjected to the OND has been identified as an element that needs to be revised to better fulfill its guidance purpose. This paper proposes a solution to provide meaningful noise information to potential buyers in an effective way by leveraging mobile communication technology and taking in account insights about human buying behavior and habits. This proposal could also benefit market surveillance’s effectiveness and assist resellers when advising customers. 1. INTRODUCTION

The Outdoor Noise Equipment Directive 2000/14/EC (OND) is a New Approach Directive that regulates noise emissions in the environment from outdoor equipment. The objective is to improve the control of noise emission of equipment for use outdoors. 57 types of equipment are covered by the OND, mainly outdoor machinery, such as those used on construction sites or in parks and gardens. For 22 out of the listed 57 types of machinery, the OND sets mandatory noise limits to allow for placement on the EU-market. Among other requirements, the machinery has to carry visibly a CE marking as well as a “noise label” indicating the guaranteed sound power level LwA gar . Besides ful- filling a regulatory compliance requirement, the aim of this noise marking is to allow potential buyers as well as users to make informed choices with regard to equipment purchase or to mitigate the risk during the use of noisy equipment.

Figure 1: Current model of EC noise labelling (OND Annex IV)

1 sebastian.wschiansky@bafu.admin.ch

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As the OND Directive 2000/14/EC has been in force in Europe and unchanged for more than twenty years, the EU Commission has started a revision process. The revision of Annex III of the OND, which lays down the methods of measurement of airborne noise that shall be used for the determination of the sound power levels LwA, is being carried out. Proposals for a more meaningful and understandable noise label are welcomed by the Commission so they could be included in the ongoing revision process as there is a widespread consensus that the current marking hasn’t had the expected strength in encouraging customers to purchase quieter equipment.

This paper describes briefly the thoughts of the author regarding the revision of the OND label so it can fulfill more effectively its purpose towards a correct Buy Quiet behavior, while at the same time assisting resellers in advising customers as well as supporting market surveillance activities.

2. ISSUES WITH THE CURRENT SYSTEM AND THE NOISE LABEL

According to the OND, manufacturers declare the conformity of their product with the OND through a EC Declaration of Conformity (DoC) figuring the measured sound power level LwA and the declared guaranteed sound power level LwA,gar as well. For the equipment types affected by limit values (most construction machines and among gardening equipment lawnmower and lawn trimmer), the involvement of a third party Notified Body (NB) is required. These DoCs also have to be provided to the EU Commission to develop a database and monitor the development of the emis- sion values over time. Market surveillance authorities of EU Member States, randomly verify through surveys and other means that equipment falling under the OND and placed on the EU market conform to the provisions of the OND Directive. Depending on the gravity of discovered non-conformities, the manufacturer has to solve the issues or he will be asked to remove the equipment from the EU market.

The process of transferring the DOC with the noise information to the Commission for monitoring and statistical purposes has been simplified since the IT-tool “NOISE” database [2] was made avail- able a few years ago. Once validated by the Commission, each DoC receives a unique Certificate number. The upload tool ensures that manufacturers declare the required data completely, allows Notified Bodies to monitor the declaration process of their client and enables Market surveillance authorities to access the DoCs directly from within the database. The usage of the tool “NOISE” by manufacturers though is not yet compulsory. For Market surveillance authorities performing quick conformity checks at the point of sale, the database information requires them to login to “NOISE”.

For potential purchasers, the information stored in the database that could support them in choos- ing quieter equipment by comparing the noise values of different products is unfortunately not readily available. They have to rely on the noise label affixed to the equipment indicating the guarantied power level LwA gar or to dig into the use manual of the equipment which then also could contain the noise pressure value at the user’s ear Lp. This situation is unfortunately of limited value to the poten- tial purchaser for the following reasons :  Logarithmic decibel values and therefore the difference between noise values of two machines

are difficult to be correctly interpreted for people not familiar with that unit.  It has been observed that the declared guaranteed sound power level LwA gar is often quite higher

than the measured sound power level LwA. For equipment subjected to limit values in the OND, manufacturers often tend to declare the limit value itself [3]. As a result, the purchaser can be misled in the decision-making process and mistaken in acquiring and using quieter machinery. This issue, which also concerns the definition of the proper noise measurement standards and

uncertainty factor is actually discussed by experts within the frame of the actual revision of the OND.  The lack of readily available and trustworthy comparative information though is probably the

major issue for buyers, be it while researching online or at the point of sale. On websites, partic- ularly of resellers, noise information is often not available, imprecise or wrong. At the point of sale, the often augmented value LwA gar is marked on the available products, but these often tend to migrate towards the limit values of the OND. A serious comparison is not possible and there- fore the buyer doesn’t really have a meaningful choice situation. Sales personnel usually can’t help either as they generally don’t know more about how to interpret the noise information. These reasons, which can be summarized as “lack of access to meaningful comparative noise data”, are probably the main ones explaining why the actual OND label fails to trigger the proper Buy Quiet consumer reaction.

3. PURCHASING BEHAVIOUR, A KEY COMPONENT TO “BUY QUIET” SUCCESS

What drives customers to make purchase decisions ? This is a science which the marketing indus- try has perfected over decades. Proper information about key features - noise levels in our case - is of course a prerequisite. However, is it sufficient? Choosing is a complex process which involves emotions as well as facts. According to neuromarketing knowledge, more than 80% of purchase de- cisions are made unconsciously, and as such are also influenced by emotions. The importance of this “reality” certainly differs depending on the type of product, on how significant key features are per- ceived by the buyer, etc.. But it should be evident that enhancing the factual noise value with real meaning to the consumer is a key element for successful Buy Quiet endeavors. Several authors have highlighted the importance of understandable and value oriented information, in particular that the information should allow for a rating of the relevant product feature. As noted earlier by [4], making good quality comparative data available is key for future progress in Selling & Buying Quiet. Cou- pling the availability of data with an educational effort also will help consumers to purchase healthier (hence less noisy) equipment. [5]

In today’s digital environment, which has widely evolved because of the Corona pandemic lock- downs amongst other reasons, consumers search for third-party comparative product information. If, therefore, we could manage to provide customers with easy access to up-to date, understandable, meaningful, and trustworthy comparative noise data regarding the type of equipment they intend to buy, a lot would be achieved to support the proper purchasing behavior. 4. INTERGRATED SYSTEM USING MOBILE COMMUNICATION TECHNOLOGY

Based on these observations, the author postulates that there seems to be information creation, distri- bution and understanding issues :  For the end user and potential purchaser, the abstract noise value LwA,gar by itself lacks meaning

and emotional content. Its availability often only on the equipment itself limits considerably its usage for comparison purposes.  For market surveillance, the label is simply a requirement to be checked. It would be of great help

though if it could directly provide access to other data needed to verify the conformity with the OND requirements. The actual procedure and system therefore should be modified and enhanced in such a way that it allows for consumers to readily access meaningful and comparative information so they are better

equipped and motivated to acquire less noisy products. This in return would over time motivate man- ufacturers do develop quieter products. For market surveillance, if they had a simple way to access specific information in the database when controlling products in the field (shops, fairs, transit), their tasks could be executed more effectively. The modifications should in turn not add additional burden on the manufacturer but if possible, should provide some benefits and hence enhance its adoption.

This calls for a solution that allows for the different entities to access and make use of validated information stored in a central database, depending on their specific needs and access rights. This could be achieved by having a unique QR or bar-code generated for instance at the time of the DoC validation in the “NOISE” application. With this code added to the marking affixed onto the equip- ment or on marketing material, interested buyers could, via a smartphone app, be provided with in- formative and always up to date noise information, as for instance a comparison with other entries in the database for the same type of equipment. In addition, the app could educate users about what the different noise values mean, provide additional information about quiet usage of the equipment, give access to audible sound samples to inform about the sound quality … or eventually also be used to inform purchasers of a product that has been deemed as non-compliant by a Surveillance authority. To market surveillance authorities, the code would give access to all the relevant information without having to go search for the DoC in the “NOISE” database or through the cumbersome process of data collection from the manufacturer or economic operators. For resellers, the app could help their sales personnel provide quality assistance to the buyer without need of specific training.

5. CONCLUSION

This proposal for a more valuable and meaningful noise label should be discussed in the ongoing revision of the OND Directive 2000/14/EC. Some challenges with regard to data protection and im- plementation issues will certainly have to be solved. The author is convinced it could provide a stronger voice to noise information so it can be better heard/understood, in particular by customers and therefore incentivize proper Buy Quiet behavior.

6. REFERENCES

1. Directive 2000/14/EC of the European Parliament and the Council of 8 May 2000 on the approximation

of the laws of the Member States to noise emission in the environment by equipment for use outdoors, Official Journal of the European Communities L162, 3 July 2000. 2. “NOISE” database, https://webgate.ec.europa.eu/growth-portal 3. Heisterkamp, F. Quality of noise emission data: An experimental verification for outdoor equip-

ment, Internoise 2019, Madrid 16 – 19 June 2019 4. Heisterkamp, F., Sell and Buy Quiet – the extended concept to reduce noise (at work and at

home, Internoise 2021, Washington DC 1 – 5 August 2021 5. Zechmann, E. «Buy Queit» with the added benefit of considering all safety, health and cost fac-

tors Internoise 2021, Washington DC 1 – 5 August 2021