Phoenix Journal · LEV Testing
If you have to raise your voice to be heard over the extract plant, noise is already a health and safety issue - not just an annoyance. Here is what the Control of Noise at Work Regulations 2005 actually ask of you, and how to get on the right side of them.
A day that went wrong
The tell was simple - two chefs on the pass were shouting to pass an order, standing barely a metre apart.
A busy production kitchen had upgraded its canopy and bolted in a bigger extract fan to cope with a new char-grill. It moved the air beautifully. It also filled the room with a hard, droning roar that nobody could switch off for the length of a shift. The plant room next door, where the supply and extract fans sat with the gas boosters, was worse again - a wall of sound the moment you opened the door to reset a trip.
Nobody had measured any of it. The operations manager assumed noise was a factory problem, not a kitchen one. Then a long-serving kitchen porter put in a hearing-related complaint, an inspector asked to see the noise risk assessment, and the honest answer was that one had never been done. From that point the conversation was no longer about airflow. It was about whether the employer had done the things the law has required since 2006 - and the paperwork to prove it simply did not exist.
The failure here was not the fan. Powerful extraction is exactly what a heavy-cooking kitchen needs. The failure was treating noise as background texture rather than a measurable exposure with legal trigger points.
The Control of Noise at Work Regulations 2005 (SI 2005/1643), enforced by the HSE, set out duties that bite at defined levels of daily personal noise exposure averaged over eight hours, written as LEP,d. There is a lower exposure action value of 80 dB(A), an upper exposure action value of 85 dB(A), and an exposure limit value of 87 dB(A) that must not be exceeded at the ear once any hearing protection is accounted for. There are matching peak values for sudden, sharp noise - 135, 137 and 140 dB(C) - which matter more than people think in a kitchen full of clattering trays, dropped pans and slamming doors.
A rough rule from the HSE: if you have to raise your voice to hold a normal conversation about two metres apart, exposure is likely to be around 85 dB(A) or above. On the pass, next to a hard-working char-grill canopy and a big single-speed fan, that threshold is easy to cross - and easy to ignore, because everyone is used to it.
What actually went wrong, then, was a chain of small omissions. No assessment, so no idea which staff were over which value. No controls chosen on evidence, so the fan ran flat out all day whether the grill was lit or not. No information or training, so staff did not know the risk or that they could ask for protection. And crucially, no records - which is the first thing an inspector asks to see and the one thing that cannot be produced after the fact.
The numbers that trigger duties
Those three figures are the spine of the whole regime. Below 80 dB(A) you still have a general duty of care, but the specific triggers have not yet fired. At 80 you owe assessment, information and hearing protection to anyone who asks. At 85 the duties become active and mandatory - you must reduce exposure so far as is reasonably practicable, designate and mark hearing protection zones, make protection compulsory in them, and offer health surveillance such as audiometry. The 87 dB(A) limit is measured after protection is taken into account, which is why the right protection, correctly worn, matters as much as the plant itself.
The route back to compliance is not complicated, but it has to be done in order and it has to leave a paper trail. Here is the sequence that turns a bad day into a defensible position.
There is a neat overlap worth using. The same competent survey that establishes safe airflow and extraction performance is the natural moment to capture noise data, because both live in the ductwork and the plant room. If you are already looking at how your smoke control and ventilation systems interact, folding noise into that assessment saves a separate visit and gives you one coherent record of how your plant behaves.
Noise rarely travels alone. The same inspector who asks for your noise assessment will want your other control records in order too, and a kitchen that can produce clean, current paperwork on demand is a kitchen that reads as well run. If you are already disciplined about the evidence an inspector expects - for instance, how you keep your temperature and food-safety records - treat noise as the same kind of obligation rather than an afterthought. It is a hazard you can measure, control and prove you have controlled.
The reward for doing it in order is more than avoiding enforcement. Quieter plant is kinder to the people who spend forty hours a week beside it, it makes communication on the pass safer, and it usually signals a system that is properly balanced and maintained rather than one being flogged at full speed to compensate for neglect.
Questions
They apply to any workplace, including kitchens. The Control of Noise at Work Regulations 2005 are triggered by exposure levels, not by industry. A hard-working extract fan, gas boosters in a plant room and constant impact noise from trays and pans can easily push a chef or porter towards 85 dB(A) over a shift, at which point the mandatory duties apply just as they would in any factory.
There is a useful rough guide from the HSE: if you routinely have to raise your voice to hold a normal conversation about two metres apart, exposure is likely to be around 85 dB(A) or higher. That is a prompt to act, not a substitute for measurement. To establish real figures and satisfy an inspector you need a proper noise risk assessment carried out with a calibrated meter by a competent person.
No. Hearing protection is near the bottom of the hierarchy of control, not the first answer. The regulations expect you to reduce noise at source so far as is reasonably practicable - variable-speed fans, attenuators, anti-vibration mounts and acoustic lagging - before relying on protection. Protection is for the exposure you cannot design out, and above 85 dB(A) it must be provided, zones marked, and its use enforced alongside health surveillance.
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