Vibration at Work in Ireland: Employer Duties for Hand-Arm and Whole-Body Vibration

Employers in Ireland must assess and control the risk from hand-arm and whole-body vibration, and the rules include fixed numerical exposure action values and limit values. One point first, because it catches people out: the standalone Control of Vibration at Work Regulations (S.I. 370 of 2006, made under the 2005 Act) have been replaced. The current vibration rules sit in Chapter 2 of Part 5 of the Safety, Health and Welfare at Work (General Application) Regulations 2007 (S.I. 299 of 2007), regulations 133 to 142. The Health and Safety Authority (HSA) guide to that chapter says the 2007 Regulations took effect on 1 November 2007 and replaced the 2006 vibration regulations. This guide is for employers, managers and HR or finance staff in Dublin and elsewhere who oversee workplace safety.

Under regulation 133, mechanical vibration means vibration occurring in a piece of machinery or equipment, or in a vehicle, as a result of its operation, so it can arise wherever staff use hand-held tools, operate machinery or drive vehicles at work. If you employ people who do any of this, vibration should be part of the hazard identification that sits behind your safety statement and risk assessment.

What the Regulations mean by vibration

Regulation 133 of the 2007 Regulations (read on the Law Reform Commission's revised-acts site) defines two kinds of mechanical vibration:

• Hand-arm vibration is mechanical vibration transmitted to the hand-arm system that creates risks to health, including vascular, bone or joint, neurological or muscular disorders.
• Whole-body vibration is mechanical vibration transmitted to the whole body that creates risks, particularly lower-back problems and spinal trauma.

"Mechanical vibration" is defined as vibration occurring in a piece of machinery or equipment, or in a vehicle, as a result of its operation. The HSA guide adds that long-term, regular exposure to hand-arm vibration is known to lead to potentially permanent and debilitating health effects, and that regular, long-term exposure to high levels of whole-body vibration is linked to lower back pain.

Exposure action values and limit values

Regulation 135 sets the numbers. Each is a daily exposure standardised to an eight-hour reference period, which the HSA guide calls A(8):

Exposure is to be assessed or measured on the basis set out in Schedule 6 (Part A for hand-arm, Part B for whole-body). Per the Irish Statute Book text of the earlier 2006 regulations and the HSA guide, those methods are based on ISO 5349 for hand-arm vibration and ISO 2631-1 for whole-body vibration. These are the figures read on the Irish revised-acts page for regulation 135; check the current text on the official page before relying on a number.

The HSA guide explains the "eight-hour" idea with a simple example: 3 m/s² for eight hours equals 3 m/s² A(8). The guide adds that shorter exposures give a lower daily figure and longer shifts a higher one.

The two values do different jobs. The action value is the trigger for doing something. The limit value is a ceiling that employees must not be exposed above.

Assess the risk (regulation 136)

Where employees are or may be exposed to mechanical vibration risks, the employer must make a suitable and appropriate assessment. The regulation says:

• Daily exposure is assessed by observing specific working practices, by referring to information on the probable vibration levels of the equipment, and, if necessary, by measuring in line with Schedule 6.
• A competent person must plan and carry out the assessment, at suitable intervals.
• Particular attention must go to the level, type and duration of exposure; the action and limit values; employees at particular risk; indirect effects from interaction between vibration and the workplace or equipment; manufacturer information; replacement equipment designed to reduce exposure; whole-body vibration beyond normal working hours; low temperatures; and health surveillance information.
• The findings, and the steps taken to comply with regulations 137 to 141, are recorded in the safety statement as soon as practicable.
• The assessment and any measurement must be reviewed at suitable intervals, and when the circumstances in section 19(3) of the 2005 Act apply.

The regulation does not fix a review interval. The HSA guide (December 2007) suggests revisiting the assessment at least every three years, and sooner if risk is high or better equipment becomes available. Treat that as HSA practical guidance, not a legal deadline.

The HSA guide lists people who may be at particular risk, including those with existing hand-arm vibration syndrome, diabetes, carpal tunnel syndrome, neck or back problems, recent surgery, or an internal or external prosthetic device, and also mentions young people and pregnant workers. Regulation 137 requires measures to be adapted for any employee at particular risk.

Eliminate or reduce exposure (regulations 137 and 138)

Regulation 137 requires employers, having regard to the general principles of prevention in Schedule 3 to the 2005 Act, to ensure so far as is reasonably practicable that risk from vibration is eliminated at source or reduced to a minimum.

Where the assessment shows an exposure action value is exceeded, regulation 138 requires technical or organisational measures, or both, suited to the activity. The employer must consider:

• alternative working methods that reduce exposure;
• work equipment with suitable ergonomic design that produces the least vibration for the task;
• auxiliary equipment, such as seats and handles, that reduces the risk of vibration-related injury;
• maintenance programmes for equipment, workplaces, workstations and systems of work;
• the design and layout of workplaces and workstations;
• information and training so that equipment is used correctly and safely;
• limits on the duration and intensity of exposure;
• work schedules with adequate rest periods; and
• clothing to protect employees from cold and damp.

The HSA guide gives practical examples: substituting or mechanising the task, keeping chisels and abrasive discs sharp or replacing them, planning several shorter periods of exposure rather than one long one, and avoiding the cheapest tools. It also says anti-vibration gloves should not generally be relied on to provide protection from vibration. For whole-body vibration it points to operator training (adjusting speed to ground conditions, setting seats and controls, choosing low-risk routes) and to maintaining roadways, suspension, tyres and seats.

Vibration controls work alongside, not instead of, manual handling measures, since whole-body vibration is specifically associated with lower-back problems.

If the limit value is exceeded (regulation 139)

Subject to the transitional and exemption rules, employees must not be exposed above the relevant limit value. If the limit is exceeded despite the measures taken, the employer must take action to bring exposure below it, identify the reason, and amend the technical and organisational measures to prevent it happening again. Regulation 134 gave extra time (to 6 July 2010, or 6 July 2014 for agriculture and forestry equipment only) for certain older equipment first provided before 6 July 2007. Those dates have passed, so do not rely on them today.

Regulation 142 allows the Authority to grant exemptions by certificate in writing in limited cases, such as whole-body vibration in sea and air transport, or where exposure is usually below the action value but varies markedly and averages below the limit value over 40 hours in a week. These require the Authority's involvement.

Information, training and health surveillance (regulations 140 and 141)

Employees or their representatives must receive information and training covering the control measures, the action and limit values, the assessment and measurement results and the potential for injury from equipment, how to detect and report signs of injury, when health surveillance is available and its purpose, and safe working practices.

Regulation 141 requires appropriate health surveillance to be available to employees whose risk assessment shows a risk to health, including those exposed above an action value. Employers must:

• use the results in preventive measures;
• keep a health record for each employee under surveillance and give employees access to their own record on request;
• provide records to the Authority when it requires them, and notify it in writing and hand over the records if the business ceases trading.

If a registered medical practitioner attributes an illness to work-related vibration, the employer is told the opinion (but not the reasons), and must review the risk assessment and controls, consider advice including reassignment to work without further exposure, and arrange continued surveillance for similarly exposed employees.

On timing, the HSA guide says that for hand-arm vibration above the action value surveillance should start at a baseline stage, then at six months, then usually annually. For whole-body vibration it says there are no reliable early-detection tests and recommends self-reporting and annual questionnaires for high-risk operators. Again, this is guidance rather than regulation text.

A practical approach for employers

Our suggestion, which is not a legal requirement:

• List every vibrating tool and vehicle in use, with who uses it and for roughly how long each day.
• Ask suppliers for the manufacturer's vibration information for each item of equipment, and use it when buying replacements.
• Compare estimated A(8) values with the action and limit values in the table above, and measure where the estimate is uncertain.
• Record the outcome and the controls in the safety statement, and put the review date in a diary.
• Make it easy for staff to report tingling, numbness, white fingers or back pain early.
• Keep a note of any incident or injury so you can check the position on reporting. Our guide to accident and dangerous occurrence reporting explains the general system. Check with the HSA whether a particular vibration-related illness is reportable.

Learnsignal's offices are off Baggot Street in Dublin, and we offer in-person training from there. For current details, see our CPD pages.

Frequently asked questions

Is there a separate Irish vibration regulation I need to follow?

The 2006 stand-alone regulations (S.I. 370 of 2006) were replaced when the General Application Regulations 2007 took effect. The vibration provisions are now regulations 133 to 142 and Schedule 6 of S.I. 299 of 2007, as amended.

What are the hand-arm vibration limits in Ireland?

Regulation 135 sets a daily exposure action value of 2.5 m/s² and a daily exposure limit value of 5 m/s², both standardised to an eight-hour reference period.

Do I have to measure vibration?

Not always. Regulation 136 allows assessment by observing work practices and using information on probable vibration levels, with measurement "if necessary". A competent person should carry out the assessment.

Are anti-vibration gloves enough?

The HSA guide says anti-vibration gloves should not generally be relied on for protection from vibration. Reducing vibration at source comes first under regulation 137.

Does the law say how often to review the assessment?

Regulation 136 says at suitable intervals and when the section 19(3) circumstances arise. The HSA guide suggests at least every three years as practical guidance.

Review your vibration risks against the current regulation text and HSA guidance, and record what you decide in your safety statement.