Germany: mandatory or offered?
| Action values | Daily noise exposure | Peak sound pressure | Health check |
|---|---|---|---|
| Lower action value exceeded | above 80 dB(A) | above 135 dB(C) | Offered: the employer must offer it. |
| Upper action value reached or exceeded | from 85 dB(A) | from 137 dB(C) | Mandatory: the employer must arrange it. |
When applying these values, the attenuation of hearing protection is not taken into account. Even if hearing protection brings the noise down to an uncritical level, the check is triggered as soon as the level at the workplace reaches the thresholds. How the daily value arises is explained in Calculating the daily noise exposure level.
Mandatory checks: before the work and regularly afterwards
The employer must arrange mandatory checks before the work starts and at regular intervals afterwards (section 4(1) ArbMedVV). The employer may only let a person do an activity that requires a mandatory check if that person has taken part in it (section 4(2)). The intervals follow the annex of the ordinance and the medical assessment; the company doctor advises on them.
Offered checks: workers decide
If the lower action values are exceeded, the employer must offer a health check. Whether it is taken up is for the workers to decide; the offered check is voluntary.
What happens during the check
According to DGUV Rule 112-194 (section 7.1), the check always includes a medical consultation with a medical history, including the work history. An audiometric examination is only necessary if it is needed for the consultation and the worker does not refuse it. The consultation may cover the choice of hearing protection, its individual attenuation and training in correct use.
EU Directive and UK regulations
- EU, Directive 2003/10/EC, Article 10: Where the risk assessment indicates a risk to health, appropriate health surveillance applies. Workers whose exposure exceeds the upper action values have the right to a hearing check by a doctor or a suitably qualified person under a doctor’s responsibility. Preventive audiometric testing must be available to workers above the lower action values where the assessment indicates a risk to health.
- UK, Control of Noise at Work Regulations 2005, regulation 9: If the risk assessment shows a risk to health, suitable health surveillance including hearing tests must be carried out. A health record is kept for each person under surveillance. If hearing damage likely to be caused by noise is found, the worker is informed and the employer reviews the risk assessment and control measures.
What the employer must do
- Determine the noise in the risk assessment and compare it with the action values.
- Arrange mandatory and offer optional health checks, involving the company doctor.
- Take the findings from the health checks into account in the risk assessment (section 3(2) of the German Noise and Vibration Ordinance).
- Provide suitable hearing protection and train workers.
What else applies when the thresholds are exceeded is in When is hearing protection required?. The consequences of hearing damage are described in Noise-induced hearing loss as an occupational disease.
Frequently asked questions
Are occupational health checks for noise mandatory in Germany?
Yes, where the upper action values are reached or exceeded (85 dB(A) or 137 dB(C)). They must be offered where the lower action values are exceeded (80 dB(A) or 135 dB(C)).
Does hearing protection count towards the action value?
No. When the values are applied, the attenuation of personal hearing protection is not taken into account.
Is a hearing test always part of the check?
No. An audiometric examination is only necessary if it is needed for the consultation and the worker does not refuse it (DGUV Rule 112-194, section 7.1).
May someone work in a noise area without the mandatory check?
No. The employer may only let the person do the activity if they have taken part in the mandatory check (section 4(2) ArbMedVV).
Sources
- German Ordinance on Occupational Health Care (ArbMedVV), annex part 3, in German
- German Ordinance on Occupational Health Care (ArbMedVV), section 4 mandatory health checks, in German
- German Noise and Vibration Occupational Safety and Health Ordinance (LärmVibrationsArbSchV), in German
- DGUV Rule 112-194, chapter 7 Use (health checks, wearing time, audibility, combination with other PPE), in German
- Directive 2003/10/EC on the minimum health and safety requirements regarding the exposure of workers to noise
- The Control of Noise at Work Regulations 2005 (UK)