The Control of Noise at Work Regulations 2005 protect UK workers from noise-induced hearing loss. They set three trigger levels measured as a daily personal noise exposure averaged over 8 hours: a Lower Exposure Action Value (LEAV) of 80 dB(A), an Upper Exposure Action Value (UEAV) of 85 dB(A), and an Exposure Limit Value (ELV) of 87 dB(A) measured at the eardrum after hearing protection is taken into account. At LEAV the employer must risk-assess and provide hearing protection on request. At UEAV they must reduce exposure (applying the hierarchy of control), provide and require hearing protection, designate hearing protection zones, and provide health surveillance. The ELV must not be exceeded. Following a transition period, the regulations applied fully to music and entertainment from April 2008. HSE guidance L108 is the practical reference document.
Noise-induced hearing loss is the most common occupational disease nobody talks about. It doesn't show up suddenly. It doesn't stop you working. It just slowly takes the top end out of speech, and then conversation, and then most of what makes a room a room. By the time it's noticed, it's permanent. The Control of Noise at Work Regulations 2005 exist because the science on how to prevent this is settled, and the cost of doing so is small — but the discipline required is constant.
This guide explains how the regulations work in practice, the three trigger levels that drive the duties, the five things employers have to do, the hierarchy of control they have to follow, and the 2008 extension that brought music and entertainment venues fully into scope.
The Control of Noise at Work Regulations 2005 replaced the 1989 regulations they were named after, lowering the action levels in line with EU directive 2003/10/EC. They sit alongside the Health and Safety at Work etc. Act 1974 and the Management of Health and Safety at Work Regulations 1999.
| Legislation / guidance | What it requires |
|---|---|
| Health and Safety at Work etc. Act 1974 | General duty under Section 2 to ensure the health, safety and welfare of all employees, including hearing. |
| Control of Noise at Work Regulations 2005 | Three trigger levels, five duties, hierarchy of control, hearing protection requirements, health surveillance. |
| Management of Health and Safety at Work Regulations 1999 | Risk assessment of all work activities, including noise exposure where reasonably foreseeable above LEAV. |
| HSE ACOP L108 | Approved Code of Practice and guidance to the regulations. The reference document for compliance. |
Noise damages hearing in two ways: cumulative exposure (gradual hearing loss across years of moderate noise) and peak pressure (instant damage from explosive sounds). The regulations address both. Cumulative exposure is measured as a daily personal noise exposure averaged over an eight-hour working day, in dB(A). Peak pressure is measured separately, in dB(C).
The regulations create three thresholds, and the duties on the employer ratchet up at each one. The thresholds are not subtle — cross one and a different set of obligations comes into force.
| Level | Daily exposure | Peak pressure | Duties triggered |
|---|---|---|---|
| Lower Exposure Action Value (LEAV) | 80 dB(A) | 135 dB(C) | Risk assessment, information and training, hearing protection on request, health surveillance for those at higher risk. |
| Upper Exposure Action Value (UEAV) | 85 dB(A) | 137 dB(C) | Programme to reduce noise exposure, mandatory hearing protection, designated hearing protection zones, mandatory health surveillance. |
| Exposure Limit Value (ELV) | 87 dB(A) | 140 dB(C) | This level must not be exceeded. Calculated after taking the protective effect of hearing protection into account. |
The detail that catches employers out is the asymmetry: the action values (LEAV and UEAV) are measured at the worker's ear without hearing protection, but the limit value (ELV) is measured with hearing protection in place. So a worker can be exposed to 95 dB(A) of ambient noise lawfully, provided their hearing protection brings the exposure at the eardrum below 87 dB(A) and provided all the duties at UEAV are also being met.
Every 3 dB increase represents a doubling of sound energy. The jump from 80 to 87 dB(A) is roughly a five-fold increase in energy. The trigger levels are not arbitrary — they are the points at which epidemiological evidence shows hearing damage starts to accumulate at a population level.
Where any exposure is likely to be at or above the LEAV, the employer must carry out a noise risk assessment. The assessment has to identify who is exposed and to what levels, by reference to either measurements or reliable published data on the equipment in use. It is reviewed when work changes and at least every two years for ongoing exposures.
HSE expects measurements where exposure is likely to be near or above the UEAV. Estimating from manufacturer data is acceptable for screening but not as the basis for control decisions in higher-noise environments. Real-world exposure is often higher than manufacturer ratings predict, because of room acoustics, multiple sources, and the way operators actually work.
Where exposure is at or above the UEAV, the employer must put in place a programme to reduce exposure, applying the hierarchy of control (see below). This is not optional. "We give them ear defenders" is not the answer the regulations want at this level — it is the lowest tier of control, only acceptable where higher tiers cannot reasonably be applied.
At LEAV, hearing protection must be made available on request. At UEAV, it must be provided and worn. Hearing protection has to be suitable: rated for the actual noise spectrum (most overestimate their attenuation in the real world), comfortable enough to be worn for the full exposure period, and compatible with other PPE such as helmets and respirators.
HSE has been increasingly explicit that over-protection is also a problem. Cutting noise levels at the eardrum below about 70 dB(A) means workers can't hear warnings, alarms, or colleagues, and tend to remove the protection. The objective is adequate, not maximal, attenuation. Where the workplace is loud but variable, electronic level-dependent earmuffs that compress dynamic range are now widely used as an alternative to passive protection.
At UEAV, the employer must designate hearing protection zones and mark them with the standard signage. Anyone entering, including visitors and contractors, must wear hearing protection. The zones need to be physically demarcated, not just labelled on a plan — signs at entrances, line-marking on floors where useful, and active enforcement during walk-arounds.
Workers exposed at or above the LEAV must be given information about the risks, the results of the risk assessment, the controls in place, the symptoms of hearing damage, and how to use the equipment provided. Training is initial and refreshed when arrangements change.
Health surveillance is required for any worker likely to be regularly exposed at or above the UEAV, or those exposed at LEAV who are at higher risk (existing hearing damage, ototoxic medication, certain genetic predispositions). It typically takes the form of audiometry on a recurring basis, with results notified to the worker and aggregated trends reviewed by the employer.
The regulations require a structured approach to reducing exposure, in this order. Lower tiers are only acceptable where higher tiers are not reasonably practicable.
Most non-compliance findings involve employers jumping straight to tier 5 because it's cheap and visible. The regulations require evidence that higher tiers have been considered first and either implemented or shown to be impracticable. "We assessed and decided protection was the only option" is a defensible position; "we issued protection without considering anything else" is not.
When the 2005 regulations were introduced, music and entertainment sectors were given a transition period. From April 2008 they came fully into scope, which brought a substantial population of workers into the regulatory framework: orchestral musicians, sound engineers, DJs, club staff, festival crews, theatre technicians, fitness instructors running music-led classes.
The duties are the same. The practical compliance challenge is different. You can't tell an orchestra to play more quietly. You can't apply standard hearing protection to a violinist without affecting the work. The HSE guidance for the sector (Sound Advice) acknowledges this and encourages controls like:
Many small venues and event production companies still have weak compliance in this area. Health surveillance is uneven. Hearing protection provision is often limited to the main FOH crew rather than being extended to bar staff, security, or stagehands who are exposed for similar durations. This is the area where enforcement activity has increased fastest in the last few years and where audit gaps are most common.
Equipment ratings are taken in standardised conditions. Real-world exposure is often higher because of room acoustics, multiple sources running together, and the way operators actually work. Sites that base their assessment on data sheets alone tend to underestimate exposure and miss the UEAV trigger.
Defenders are issued, signs are posted, and compliance is treated as solved. Spot checks reveal workers wearing them around their necks, or with the cups not properly seated, or for the noisy hour but not the quieter ones that still cross the threshold. The regulations are not satisfied by the issuing of equipment; they are satisfied by exposure actually being controlled.
Audiometry is run for the first year, then quietly drops off the calendar. Or it is run, but the results are not aggregated, so no-one notices that a particular shift or work area is producing measurable hearing loss. The surveillance is meant to feed back into the assessment; without that loop, it is paperwork.
The duties extend to all venue staff, not just performers and FOH technicians. Bar staff at busy nightclubs are routinely exposed at UEAV and above, often without health surveillance, often without provided hearing protection. Tribunal claims and HSE interest in this area have increased noticeably in recent years.
Workers using power tools are exposed to both hand-arm vibration and noise. The two regulatory regimes (Control of Vibration at Work 2005 and Control of Noise at Work 2005) have parallel structures. Sites that comply with one but not the other often have the same workers in scope of both — the assessments should be done together. Worker-facing training is most effective when it covers both at once: our Noise and Vibration Awareness course is the right level for the operative population, covering exposure mechanisms, symptoms, hearing and circulation health, the hierarchy of control, and the worker's role in flagging early warning signs.
Lower Exposure Action Value (LEAV) at 80 dB(A) daily, Upper Exposure Action Value (UEAV) at 85 dB(A) daily, and Exposure Limit Value (ELV) at 87 dB(A) measured after hearing protection is taken into account.
Yes. Following a transition period, the regulations applied fully to music and entertainment from April 2008. The duties are the same as for any other sector.
No. The hierarchy of control requires elimination, engineering controls and administrative controls to be applied first. Hearing protection is the last tier, not the default.
When work changes substantially, and at least every two years for ongoing exposures.
Yes. Designated hearing protection zones apply to anyone entering, including visitors and contractors.
Audiometry — structured hearing tests — carried out at recruitment and at regular intervals afterwards for workers exposed at or above UEAV.
For employers, the practical test is simple. Walk the site. Identify where you have to raise your voice to be heard at one metre — that's roughly LEAV. Identify where you can't hold a conversation at all — that's at or above UEAV. Then ask whether the controls in place go beyond hearing protection. If they don't, the regulations are probably not being met, regardless of what the paperwork says.
The walk produces three things you can act on: a list of areas where protection signage is needed, a list of areas where source or path engineering should be reviewed, and a list of workers who probably need to be in health surveillance. None of those are difficult to address; what makes them hard is that they accumulate when no-one walks the site for a year.
If your organisation has noise exposure and you're not sure where it sits against the trigger levels:
For worker-facing training, our Noise and Vibration Awareness course is the right level for the operative population — covering both regulatory regimes in a single session. For broader workplace H&S management training that covers noise alongside other workplace hazards, our IOSH Managing Safely course is widely used at line manager level. The NEBOSH National General Certificate covers noise in greater depth as part of its workplace health module. Call us on +44 (0) 3300 569534 for tailored advice on the right training for your team.
For related guidance, see our PPE Regulations guide — hearing protection sits in the wider PPE compliance framework — and our 5 Steps to Risk Assessment, which sets out the assessment methodology that feeds into noise compliance.
