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What follows on this page is a submission made to the National Health and Safety 

Commission. It was made in response to a call for responses to a National Discussion 

Paper on proposed changes to the National Standards on Noise for this country. 

WHAT A LOT OF NONSENSE. IN THIS SUBMISSION THERE WERE INTRODUCED NEW 

CONCEPTS AND SOME ITEMS THE MEANING OF WHICH WOULD BE UNKNOWN TO 

THOSE OTHER THAN MY EX-STUDENTS. 

THESE AND THE LACK OF RESPONSE SHOW THAT THE SUBMISSIONS WERE NOT 

EVEN READ.

THERE WERE IN FACT NO DISCERNABLE CHANGES MADE TO THE SO CALLED 

PROPOSED AMENDMENTS.

This is an utter disgrace and should not be allowed to 

continue

It is a complete disregard for the health, safety and 

welfare of workers in this country.

WHAT ARE THE GOVERNMENT, THE OPPOSITION, 

AND THE UNIONS GOING TO DO ABOUT IT ??????     

WHAT ARE YOU GOING TO DO ABOUT IT ?????

I WAS TOLD IN PUBLIC THAT IT WOULD BE 12 YEARS BEFORE THEY COULD DEVISE 

SUCH A STANDARD FOR CALL CENTRES

Mervyn K. Vogt

B. Comm., B.Ed., G.Dip.E&IR., Dip. Ed., A.C.T.T.

42 Rosemary Crst Pines Forest Victoria 3200 Ph. 03 9786 5308. Fax. 03 9776 8754

My Sword is the COURAGE to speak. My Shield is the TRUTH itself

Reply to

National Code of Practice for Noise Management and Protection

of Hearing at Work

Draft 3dEdition 2004

M.K. VOGT

Occupational Noise

But human society creates a special problem even for those with perfect hearing - the problem of 

unwanted sound, of noise which is as much a hazard of our environment as disease, germs, or air pollution.

Hallowell. Davis M.D. Director of Research Central Institute for the Deaf St. Louis.

The current Standards document NOHSC Occupational Noise Standard and the Drafted amended document addresses the matter of Industrial noise and the prevention of the damaging of hearing. This is of course understandable and correct, it is not however complete. Besides suggesting modifications of the proposals as I will do so later in the document I would contend that there is an urgent need for inclusion by way of either integration or by addendum of another new area of concern for which standards must be established and published.

In this country and in this communication age one of the most significant occupations in terms of numbers is telephone consultants. Call centres in which such consultants are concentrated have become numerous in this country. Their hearing, voice and intellect are their fundamental tools of trade and indeed of their every day life. The technology with which they must work is at the stage of development where it requires that they be almost literally chained to their workstations like the rowers in ancient slave galleys. Without the full use of ears, voice and intellect they would be like rowers without their arms or legs.

The soundscape is therefore elemental to their occupation. There are components of their soundscape which are either different from or in addition to those of other workers, for instance of the manufacturing or construction sectors. The concepts and language of Communications Theory and practice are a vital element in this occupation and area of concern. Currently there are to the best of my knowledge no national standards which have been set in this country for this industry.

It is notable that call centres world wide have high staff turnovers, a high rate of staff burn out and very high levels of unplanned absences. I would suggest that regulation in this area would go a long way to reducing these undesirable traits. It would give benefits not only to

M.K.Vogt 01/24/04 1

the employees concerned but also significant savings to the employers in training costs, sick leave as well as increasing staff job satisfaction and commitment to the company.

Headsets fitted with a microphone are for the most part standard equipment in major call centres. The result is that one ear, usually the left ear, is constantly occluded. This can lead to heat build up in the favoured ear. Alternation of the ears is generally not a solution due to the question of brain lateralization involved in the information processing. Temperature affectsthe speed of transmission of sound. With an occluded ear the temperature will raised and the risk of damage is increased

The headsets should be required to be fitted with proper noise limiters to minimize the risk of acoustic incidents from noise lb) and noise (c) origins

National Standards should be set for the performance of limiters and headsets and for elements of their design. Where possible preference should be given to limiters which give notice of battery condition

With present technology Acoustic Incidents may not be totally eliminated and can be painful. Such incidents can cause hearing damage and tinnitis, and may even cause damage to the eardrum.

Limiters will require monthly checking for the battery levels and that settings have not been altered. They should be tamperproof sealed.

Where there are high staff density levels the operators themselves may of a necessity generate an unavoidable but unacceptable level of ambient (a) noise

Fitting of acoustic cups on the microphones will assist in reduction of voice levels in communicating with customers.

Headsets and handsets in use create hygiene problems and the possibility of transmission of fungal and other infections.

It is therefore important that there is a regular program of replacement of cups and earpieces and that proper antiseptic wipes are readily available.

It is important that consultants always use their own headsets and do not interchange especially where they are assisting with calls.

Where possible the design of the workplaces and workstations should minimize the ambient Noise (a) levels.

Metering of the ambient noise level is necessary periodically and where there are perceived changes in the levels.

The suggested maximum permitted average ambient Noise(a) level should not exceed 50db as recorded by the appropriately weighted meters. However the ultimate test should be the perception of the operators in conjunction with the OH&S representatives and the management in "effective" consultation.

M.K.Vogt 01/24/04 2

Within call centre workplaces the use of mobile phones should be restricted to those which have be proven not to cause acoustic interference and shriek.

There should be a national awareness program to sensitize the calling public to the concerns of proximity of mobiles in use and the proximity of electrical equipment in the generation of Noise(b). This might be done partly through the use of Recorded Voice Announcements (RVA)-

Noise induced DisStress

In order for there to be a good level of understanding or the stressor factors or Stresscape there should he familiarity with the Communication Models of Shannon-Weaver, and of Vogt The work of a phone consultant may be inbound, outbound or a combination of both modes.

Outbound work often involves sales work which is by nature high tension and highly competitive and with a high level of tension and DisStress. Telephone medium places heavy if not sole reliance on hearing. Noise in phone consultant communications situations is not only acoustic but involves such elements as culture and linguistic mismatch as can be seen from the Vogt Model. Where these constitute mismatches with the operator they create a DisStress field. Managerial and computer monitoring systems may also add to the DisStress field. where acoustic noise in each of its forms is an added stressor. Each of the stressors are cumulative.

Inbound call centre work involves support and maintenance. In the vast majority of cases callers are stressed and seeking solutions to problems. The use of queuing, computer triage and RVA's frequently mean considerable delays. Customers will come to the situation with a high degree of DisStress. As a consultant will handle on average in excess of 100 calls per day there is an anticipated very high DisStress level. Most of the elements involved for outbound operatives as mentioned above apply here as well. Acoustic noise of all types are therefore cumulative DisStressors and should be reduced as far as is possible.

Setting National standards in this area of Occupational noise for call centres and telephone operators is not easy however it can be done. The communications factors and the acoustic noise element can be highly subjective, therefore the subjects themselves must be involved in the assessments.

The assessment of the problems should be a co-operative team effort. It should involve the individual operator or operators, the elected OH&S representative and the management assisted where necessary by experts in the appropriate field to achieve a satisfactory solution.

The National Institute for Occupational Safety and Health (NIOSH) the USA regulatory authority under instructions from the Congress to investigate Stress at Work. Under Job Conditions That May Lead to Stress NIOSH includes environmental factors such as noise and ergonomics. It says " Stress sets off an alarm in the brain which responds by preparing the body for defensive action.................. The response is preprogrammed biologically. Everyone responds in much the same way................ Further it states "But when stressful situations go unresolved the body is kept in a constant state of activation, which increases the rate of wear and tear to the biological systems, Ultimately fatigue or damage results, and the ability of the body to repair and defend itself can become seriously impaired. As a result, the risk of injury or disease escalates." NIOSH lists chronic cardiovascular disease, musculoskeletal disorders, and psychologic disorders as stress related outcomes. M.K.Vogt 01/24/04 3

Public Education

 

The public should be encouraged to report excessive line noise (c) to the carrier company fault division.

The public should be educated to turn down TV Radio and other competing noise (c) sources when speaking to others

To switch off mobile phones in the proximity of landline phones when calls are being made To be especially conscious of proximity to electrical machinery and internal power lines when calling especially on cordless phones

 

 

Definitions

Noise is defined as unwanted sound. In communications terms it is those

things which interfere with the transmitted signal and with communication. An unwamted disturbance within a transmission. Noise decreases the signal to noise ratio

Noise (a) : ambient noise in the background of the workplace environment

Noise (b) : ambient noise in the background of the customer environment

Noise (c) : is that which is generated in the transmission process frequently

through faulty equipment

Signal : the variable parameter that contains information

Signal to noise ratio : the ratio of the amplitude of the signal to the mean amplitude of the

noise. In communications the greater the ration the higher the greater the ease of perception of the information transmitted

 

Stress : the response of an organism or entity to stimuli or perceptions

which conflict with its aims or comfort. The effects may be positive or negative. Where it is negative in effect we will use the term DisStress. Also defined as: A mentally or emotionally disruptive or upsetting condition occurring in response to adverse external influences and capable of affecting physical health, usually characterized by increased heart rate, a rise in blood pressure, muscular tension, irritability and depression.

Job DisStress : the harmful physical and emotional that occur when the

requirements of the job do not match the capabilities, resources or needs of the worker. Job DisStress can lead to poor health and even injury

 

 

 

 

 

M.K.Vogt 01/24/04 4

Suggested amendments to the Draft document as presented

Piii Foreword penultimate dot point :

reinstate " facilitating and coordinating national research."

There would need to be forceful reasons for eliminating this ftinction and these words. In which case reasons should be given

Final dot point :

Delete "government" insert "all stakeholders"

I would suggest that OH&S should ideally be a cooperative effort of equal all concerned.

Piv Preface after "(NIHL)" insert: "and occupational noise induced ailments (NIA)" and make the necessary grammatical changes.

It would be appropriate to add a paragraph at a convenient point in relation to NIA and the inclusion of Phone consultants and Call Centres

In the penultimate paragraph after "workplace" insert" " , and work related"

In the final paragraph, line 2 after "workplace" insert "in relation to NIHL"

In the final paragraph insert a new final sentence " VVhere the workplace involves phone consultants and call centres the maximum ambient noise levels should not exceed 50 decibels

P 3 Objective 2.1 after "loss" insert the words "and other noise induced ailments"

3.2 needs amendment to take into account the fact that phone based operators do have hearing limiters and there still needs to be taken into account the noise levels emanating from the phone or headsets both before and after filtration..

4.1 should be amended by way of addendum "Disease is taken to include

noise induced stress.

P10 Definitions Consultation Add a further definition.

"'Effective Consultation' means where the decisions taken are an accommodation of

the positions of all the stakeholders. Where the term consultation is used effective consultation is intended."

The requirement for consultation in all industrial matters in practice has become a nonsense. Without the qualification given there is little consultation taken in good faith.

Add a further definition

"'Competing Noise' means that noise which reduces the signal to noise ratio

'Employee Representative after "matters" insert the words "and union representatives with knowledge or expertise in OH&S matters"

OH&S representatives will on occasion need expertise and advice from their unions which have expertise or access to specialists and specialist information. i

M.K.Vogt 01/24/04 5

'Excessive Noise' add another sentence " It also means Excessive Noise which significantly lowers the signal to noise ratio."

'Personal hearing protectors' add another sentence "It also means a device attached to a handset or headset to limit the volume or modulate otherwise damaging frequencies."

'Risk' add a further sentence "or harm to the mental or physical well being of the person."

After n'Workplace' add a further definition

'Workstation' Furniture, space, and equipment at which operators habitually perform specific work functions such as telemarketing or consultancy.

 

General Principles

5. 2 (a) after "loss" delete "and" insert "," after "tinnitus" insert "and noise induced stress."

5.2 (d) after "through" insert "effective"

Strategies

5.4 after "redesign" delete "and" insert "education and,

Education has elements which are in most cases more desirable than just training. Education requires understanding rather than rote learning, it also by its nature involves two way communication rather than a dictatorial environment. In the long run education is broader in its application and effects. If necessary as a professional educator of considerable standing an d experience I am prepared to expand on this matter if necessary.

Consultation

5.5 insert as the first word in the sentence "Effective"

5.6 insert before "consultation" in the first line "effective"

5.7 penultimate line delete the word "established"

There are those woraplaces where consultative processes have not been followed in the past therefore previous bad practices would be condoned through the use of the word established.

5.8 (c) after "noise-induced" insert "stress and health problems,"

5.9 (g) do not delete "and education"

Removal of the word education will be seen as offensive by those who are educated. 5.10after "noise-induced" insert "health problems and"

I would recommend that there should be inserted a clause which deals with the now increasing use of Temporary and agency staff. I would respectfully suggest that there should be a stated requirement for there to be an induction which includes the provisions mentioned in this Standard.

M.K.Vogt 01/24/04 6

6.5 (i) do not delete "and education"

6.5 (k) after "machines insert "and other potential noise hazards"

Items 7.1 and 7.2 are welcome additions

7.6 1 would recommend a review period of three years rather than 5.

This recommendation is made in view of the rate of change of technology and information especially in tertiary industries.

7.6 (d) delete words after "arrangements" insert "in noise prone areas"

 

 

ENGINEERING TREATMENT OF THE TRANSMISSION PATH

13. after "listeners" delete ", in this case the employees,"

even casual visitors to the environment of the workplace are entitled to protection under the law

ADMINISTRATIVE CONTROL MEASURES

By way of addendum

9.6 Where employees are in a noise induced stress environment administrative measures such as job rotation. job redesign, and serial multitasking may be considered.

PERSONAL HEARING PROTECTORS

10.1 After "wear," insert "or use "

This would cover the use ofphone limiters which are not actually worn. 10. 13 DO NOT DELETE THE WORD EDUCATION 1 1. DO NOT DELETE THE WORD EDUCATION

11.1 delete "training is" insert "Education and training are"

after "requiring" insert "education and"

11.2 insert the word "Education and training" in the heading and the first sentence.

It is notable that the "aims of' (b) are in fact educational rather than training. Furthermore it is notable also that the "objectives are not stated in Magertian terms and would be more accurately stated as "aims'

11.3 replace "training" with "program"

11.4 delete "being trained"

11.6 delete "training"

11.6(b) after "hearing" insert ", stress and health"

M.K.Vogt 01/24/04 7

11.6(c) after "noise-induced" insert "health,and stress problems"

 

Mervyn K. Vogt

OH&S Representative

CEPU Representative

President of Vic. WBA

Lecturer in Education, Educational Technology, Ergonomics and Forecasting(ret)

 

M.K.Vogt 01/24/04 8

 

 

 
 
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