A CRITICAL EXAMINATION ON THE EFFECT OF NOISE POLLUTION ON ENVIRONMENT AND HEALTH


ABSTRACT
The environment is our global home, there is need for it to be preserved and protected. It is within this environment that both natural and non-natural things are found.[1] There are so many variables through which pollutants can reach human beings, not only the air we breathe, the water we drink, the food we eat but also the sound we hear. Noise pollution constitutes an element of the general environmental pollution problem in Nigeria mostly in the city. This City nuisance makes the environment unhabitable. Once an environment is no more habitable, it becomes polluted an unhealthy for human being. The bane of this paper it to. This paper opts to critically examine the effect of noise pollution on human Health and environment. It implored a doctrinal method of research which gave a conceptual definition of noise, exhaustively discussed the sources of noise pollution and its effect on environment and Health. The paper concluded and made some recommendations which if implemented, would help to control and noise pollution on the environment.


INTRODUCTION
            Noise is defined in different ways depending on the person, place and time. It is a matter of semantics. Generally Noise is a sound especially a loud or unpleasant one. It is also a series or confusion of load sounds, irregular fluctuations accompanying a transmitted signal. It is any loud or disagreeable sound.[2] Chamber’s Dictionary[3] defines Noise as harsh disagreeable sound, and defines noise pollution as an excessive or annoying degree of noise in a particular area.   
            Noise is a number of tonal components disagreeable to man and more or less intolerable to him because of the discomfort, fatigue, disturbances and in some case, pain it cause.[4] Noise, according to the Wilson committee of the United Kingdom is “some undesirables by the recipient”.[5] The Advanced Learner’s Dictionary[6] defines noise as loud and unpleasant sound especially when undesired.
            The problem then lies on how much sound causes environmental noise pollution. Scientists[7] are of the opinion that the concept of noise should not only lie on individual perception, but should be highly perceived in terms of frequency and intensity based on objectivity.[8] This objective perspective according to the scientific school must have standards of measurement and yardsticks of general assessment. Unfortunately the law has failed in proffering any explanation along that line. Noise pollution is a type of energy pollution in which distracting sounds which are clearly audible  may result in disturbing any natural process or cause human harm. Consequently, noise is unwanted sound. Special metres[9] have therefore been designed to measure tolerable and intolerable sound (noise) other than the subjective tests of individual hearers.
Noise pollution is one of the environmental hazards affecting human as well as climate. It is a price we have to pay as city dwellers. Even in rural areas, it is difficult to find an exclusive area where the only sound heard are those produced by nature. All forms of noise, especially community noise and workplace (or industrial) noise exist in the country.[10] Human beings, animals, plants and even inert objects like building and bridges have been victim of the increasing noise pollution caused in the world. Noise has become a very significant stress factor in the environment to the level that the term “noise pollution” has been used signifying the hazard of sound which consequences in the modern day development is immeasurable.[11] Though not physically visible, noise has been a major catalyst to climate change and practically sources of human health catastrophes globally.
            Therefore, from the foregoing, it may rightly be summed up that noise is an unwanted pollutant introduced directly or indirectly into the environment usually at 80-85db level and at which sound becomes so painful and of deleterious effect and harm to living resources, hazard to human health and sea amenities.[12] A major distinction between sound and Noise is that sound is regarded as noise when it becomes a sources of inconveniences to another.[13]
            Noise pollution is not peculiar to developing countries alone, it is a common occurrence and of highest magnitude in most of the advanced countries. For instance, China until the third Century B.C of it’s existence had used noise for torturing instead of hanging men for dangerous crime.[14] Similarly in India, not until of late when most of the people do not consider noise as pollutant and take it as part of life routine, noise was before considered gravious just like any other serious crime.[15] To the researcher, noise is an unwanted sound irrespective of its level which irritates or annoys the recipient.

Sources of Noise Pollution
            It has been observed that city populations are growing faster than infrastructure can adapt in Nigeria.[16] No wounder Suni Ehi writing on the same issue stated that:
Residents of our big cities are increasingly going through the gradual process of partial deafness. Their sensitive eardrums are daily being bombarded by a continuous barraged of environmental  noise over flowing from ear-shattering, drum-size speakers of mosques and churches, from hammering neighbours musical system, from the shrill horns of motorists, from piercing sirens of escorts, from strident eruptions of drug peddlers; from thunderous weekend open parties; and worse now, from harsh explosions of numerous record and cassette selling kiosks[17]
Urban dwellers are subjected to varying kinds of noise disturbances mostly occasioned by neighborhood noise vibrated by record cassette players[18]. Noise disrupts the tranquility of the environment and can affect climate and health negatively. Amongst the common sources of noise pollution that can affect health negatively and contribute directly to climate are:
1.            Electricity Generating Plants: Electric energy occupies the top grade in energy hierarchy as it finds innumerable uses in homes, industries, agriculture and in some nations, transportation. Nigeria’s electricity power situation is very poor because of erratic power supply. As a result, there is an upsurge in the use of electricity generating plant with its attendant noise pollution on the environment and Human Health. Most workplaces and homes use generating plants 24 hours in alternative to power supply.[19] The noise from generated plants in Nigeria couples with it’s accompany smoke emission (emission of carbon monoxide which is deadly) to the sky has greatly contributed to the breaking of the Ozone layer in the sky[20] and the deadly carbon monoxide has killed some people in different places.  
2.            Vehicular Traffic Noise Engine and pressure Horn
Increase in vehicular traffic is also a source of noise pollution around the globe especially in most urban cities around the world. The passage of trains and airplanes makes the case even worse. Aviating noise results from landing and take off of aircrafts at odd times. The situation is also getting seriously alarming with increase in traffic density on city roads.[21]  The emissions of smoke from cars are of great concern to the changes we are currently experiencing in the climate of this country. The case of Adediran v Interland Transport Ltd[22] is in support of this fact.
3.            Construction/Industrial Noise: The use of heary machines and other equipment in construction industries generate noise in no small measure. The need to meet with demand of the basic necessity of living,[23] the construction of buildings, highways and city streets causes a lot of noise. Pneumatic hammers, air compressors, bulldozers, loader, dump trucks and pavement breakers are the major sources of noise pollution in construction sites. This account for why noise is regarded as the most widespread industrial hazard today.[24] All emits one classes of Smoke or another which are all contributing to the current change in climate.[25]
Motors and compressors used in the industries create a lot of noise which adds to the detrimental state of noise in Nigeria. Plumbing, generators, air conditioners, fans etc also create a lot of noise in the building and add to the prevailing noise pollution[26]. There has been some pronouncement[27] by the courts which supports these facts.

OTHER SOURCES OF NOISE POLLUTION
Other sources of noise pollution that are not contributing directly to climate change but contributes indirectly and have some negative effect on human health are:-
4.      Noise from Religious Worship Institutions: - Nigeria is a multi religious society and is therefore prone to religious activities. These activities manifest in congregational worship in various forms. The congregational worship are held in mosques, churches and other non-conventional areas like residential and workplaces in the daytime and even throughout the nights.[28] Sometimes, one is woken from sleep by religious prophetic utterances and invitation to prayers and programmes.
Noise of significant levels is generated from these congregational worships with the use of heavy public address systems and intensity of the voice of the worshipers oozing from inside. However, despite the thunderous nature of the noise and its adverse effect on human health, the government has shield away from aiding the issue. For example, a bill to control noise emission from religious places in kwara State was met with strong opposition and eventually, the idea was dropped.
5.            Household Noise: Household equipments, such as Vacuum cleaners, mixers and some kitchen appliances are noisemaker of the house. Though they do not cause too much of problem, their effect of noise emitted on human health cannot be neglected. Furthermore, noise can be generated from neighborhood consisting of neighboring apartments and noise within one’s own apartment.[29]
6.                  Hawking Noise: People while hawking do not realize the difficulties they caused to others and themselves. There can be loss of hearing, stress level may go high and even mental instability. Hawking unnecessarily while driving or stationed in a place has become a trend these days and one while driving or stationed can hear it very well at the traffic signals.[30] In the case of Moore v Nnado,[31] the court ruled in favour of the plaintiff where he complained of excessive noise generated by the defendant in his palm wine bar by playing his stereogram unreasonably loud until late every night. This was held to be an actionable nuisance and the plaintiff was entitled to relief.
Effects of Noise Pollution on Human Health
      Concern about the adverse effects pollution on health and environment have resulted in measure to reduce and or abate it. However, the health impact of noise pollution are not likely to decrease unless appropriate action is taken. The purpose of Section 22 of NESREA Act is to minimize the adverse impact of noise without placing unreasonable restrictions on development or adding unduly to the costs and administrative burdens of business.[32] Environmental degradation brings about significant pressure on the climate and on human health.
      The said Section 22 of NESREA Act[33] provides as follows:
1.                  The Agency shall, on the commencement of this Act, in consultation with the appropriate authorities:
a.                  Identify major noise sources, noise criteria and noise control technology; and
b.                  Make regulations on noise, emission, control, abatment as may be necessary to preserve and maintain public health and welfare.
2.                  The agency shall enforce compliance with existing regulations and recommend programmes to control noise originating from industrial, commercial, domestic, sports, recreational, transportation or other similar activities.
3.                  A person who violates the Regulation made pursuant to sub-section(1) of this section commits an offence and shall on conviction be liable to a fine not exceeding N50,000 or to imprisonment for a term not exceeding one year or to both such fine and imprisonment and an additional fine of N5,000.00 for every day the offence subsists.
4.                  Where an offence under sub-section (3) of this section is committed by a body corporate, it shall on conviction be liable to a fine not exceeding N500,000.00 and an additional fine of N10,000 for every day the offence subsists


Noise can have a significant effect on the environment and on the quality of life enjoyed by individuals and communities. Therefore, Exposure to noise pollution can affect human health in the following circumstances:
1.                  Hearing loss in fetus and Newborn
The ear is the best detector of noise and therefore the organ most likely to suffer harm from it. It is true that people vary in their response to loud sound but repeated exposure to sounds above 80 to 90 decibels can lead to gradual loss of hearing. For instance, pregnant women exposed to noise in the market place, road, vehicle, workplace (etc) may result in noise-induced hearing loss and other health hazards on fetus.[34] The baby’s hearing is damaged and the baby may have hormonal disturbances as well as birth defects.[35] Expert study found that children with high-frequency hearing loss tested at 4 to 10 years of age were more likely to have been born to women who were exposed consistently to occupational noise in the range of 85dB during pregnancy.[36] This goes to establish the fact that the excessive noise pollutant has adverse effect on health of a child in the womb.[37] The National Concord[38] reported that persistent noise created by a street disc manufacturer in a strictly residential area of Ikeja forced residents to leave their homes in order to keep away from the deafening noise coming from the factory.
            Noise can have so many adverse effect which include not only damage to hearing as has been discussed but also disruption of normal activity and as a sonic boom, can also cause physical damage to structures.[39] The most common and best understood psychological effect of noise is this hearing impairment either temporary or permanently. The amount of permanent hearing loss produced by sufficient exposure to high level noise depends on the nature of the noise, the time distribution of a particular exposure, the local duration of the exposure over a lifetime and the individual susceptibility. For essentially continuous type of noise, such as that in many factories, enough research has been done to permit some statistical prediction of the risk which results from noise of such nature. Statistical estimate has shown that about 5% of the working population of any developed country is made deaf by their Jobs.[40] The study of the effect of Noise pollution on hearing of public transport in Lahore city of Pakistan shown that public drivers are exposed to excess noise on roads and about 75% of them are suffering from noise induced hearing loss.[41] The major cause of hearing loss is occupational exposure, although other sources of noise particularly recreational noise may produce significant deficits
2.      Disturbance in mental Health: Noise pollution is not believed to be a cause to mental illness, but it is assumed to accelerate and intensify the development of latent disorders. Noise pollution may cause or contribute to anxiety, stress, nervousness, nausea, headache, emotional instability, argumentativeness and sexually impotence, changes in mood, increase in social conflicts, neurosis, hysteria and psychosis.[42]
Population studies have suggested association between noise and mental health indicators, such as rating of well-being, system profiles, the use of psychoactive drugs, sleeping pills and mental hospital admission rates. Children, the elderly and those with underlying depression may be particularly unbearable to these effects because they may lack adequate coping mechanisms. Children in noisy environments find the noise annoying and report a diminished quality of life.[43] More disturbing is the fact that prolonged exposure to noise can affect one’s personality. When British Government researchers asked victims of noise pollution how they felt about those responsible, they spoke of hatred, revenge and even murder.[44] However, in combination with provocation, pre-existing anger to hostility, alcohol or other psychoactive agents, noise may trigger aggressive behaviour by virtue of our views with examples of this kind of behaviour.[45]
3.      Cardiovascular Effects: Noise has been associated with important cardiovascular health problems.[46] Experts have shown that noise exposure causes a number of predictable short-term physiological responses mediated through the autonomic nervous system. Prolonged exposure to noise, it is believed, can significantly alter blood cholesterol and plasma corte so low to the detriment of human health.[47] Noise is also a causal factor of some heart diseases migraine and gastro-intestinal ailment.[48]
Exposure to noise, causes physiological activation including increase in heart rate and blood pressure and thus increases peripheral vascular residence. There is rapid habituation to brief noise exposure but habituation to prolonged noise is less certain.[49] These effects begin to be seen with long-term daily exposure to noise levels above 65dB with acute exposure to noise levels above 80 to 85dB[50].
4.      Sleep Disturbance: uninterrupted sleep is known to be a prerequisite for good physiological and mental functioning in healthy individuals.[51] There is both objective and subjective evidence for sleep disturbance by noise. Exposure to noise disturbs sleep, proportional to the amount of noise experienced in terms of an increased rate of changes in sleep stages and in number of awakenings. Habituation occurs with an increased number of sound exposures by night and across nights. Also more disturbing is the fact that prolonged exposure to noise can affect one’s personality. Noise exposure during sleep may increase blood pressure, heart rate and finger pulse amplitude as well as uncontrollable body movements. They may also be after effects during the day following disturbed sleep, perceived sleep quality, mood and performance in terms of reaction time, all decreased following sleep disturbance by road traffic noise.[52]
Other primary sleep disturbances are: - difficult in falling asleep, frequent awakening, waking two early and alternation in sleep stages and depth. Although the long term health consequences of noise are inclusive, noise induced sleep loss has been found to impair task performance the next day.[53]
 Impaired task performance: There is good evidence, largely from laboratory studies that noise exposure impairs performance.[54] Thus, work tasks that require deep concentration will adversely by affected by noise as it will change the workers emotion and behavious in a number of ways.
Noise exposure may also slow rehearsal in memory, influence processes of selectivity in memory and choice of strategies for carrying out tasks. There is also evidence that noise may reduce helping behaviour, increase aggression and may reduce the processing in social cues seen as irrelevant to task performance.[55]
Measure to reduce/abate Noise Pollution
                        Due to the ignorance of Nigerians on the fact that there exist a close nexus between noise pollution and health, little or no attention is paid to the control of noise pollution in the country. The execution and implementation of the law as regards environmental pollution is never implemented to the letters. It has been observed by writers that the persistence of this problem could endanger the future stability of human health and could aggravate the human health catastrophe in the fast growing cities in Nigeria.[56]
            The most comprehensive and global enactment on the protection of the working environment against noise pollution was enacted in the convention held in Geneva[57] under the auspices of the United Nations. The convention gave rise to a document[58] simply known as 1977 working environment convention.[59] This convention requires the parties to adopt in all their economic activities, national laws and regulations to protect against hazards in the working environment from air pollution, noise and vibration. Pursuant to these, different countries including Nigeria have developed secondary legislations to guard against noise pollution but the problem with Nigeria as the researcher had mentioned before now is that of execution and implementation of the laws to the letters.
            Be that as it may, dampening the sources of noise level or making its noise characteristic less annoying are typical first approach to noise control.[60] This could only be achieved through zoning. An industrial layout, construction site, market and vehicle/ loading and repair stations should be sited at a distance from residential places . Also the use of quiter machines and appliances though costlier than second handed ones that produces excessive noise and pollute the environment should be encouraged. Technological Advancement measure and natural protection should also be taken to abate noise through the use of gargets like insulator and sound proofing to doors, walls, ceiling using ear protection and planting of vegetation for arbsorbtion of sound.

Recommendations
Notwithstanding the fact that some agencies, Non governmental organizations (NGO), statutes has made provisions safeguarding the environment against the deleterious effect of noise, it is significant to evolve  a more proper approach to address the issue considering the adverse effect it has on human health and environment. This paper recommends amongst others, measures already inforce, the enactment of a laws by the national Assembly to combat noise pollution aggressively in Nigeria and that such bill should be stepped down at various state and local government respectively. There should also be an adoption of plan control measure which involves the separation of Land Use into noise sensitive and noise insensitive.
Secondly, there is need for public enlightenment, education and sensitization on the hazards associated with noise pollution and its nexus with human health.
Thirdly, since the rate of pollution increases inline with population increase, there is need for review of environmental polices, plans and programmes for noise pollution in Nigeria. This will help to bring up suitable plans, programmes and policies that can address current issues relating to the effect of noise pollution on health and environment.
            In addition to these, principles of good neighbourliness the following should be adopted:-
a.            Consider your neighbours when you do something nosily and inform them before hand.
b.            Co-operate when asked by a neighbour to reduce noise.
c.            Not to carry out noisy work or use domestic appliances that are noisy at night.
d.            Not to play music at a level that annoys your neighbour.
Finally, some provisions of the noise control and abetment Act, 1977 which is an Act of  the United State should be adapted to put in place a regulatory agency who would assist in the measurement, control and enforcement of the laws to achieve a desired goal.  


[1]A, Akinbode Introductory Environmental Resources Management,  Daybis Limited, 2002, pp1-2.
[2] See Collins Australian Pocket English Dictionary at p. 573.
[3] 21st Century, Chamber’s Dictionary, 2nd edition.
[4] A.D, Hamza ‘Noise pollution regulatory measures for protection of Ecosystem” faculty of law journal 2007-2008, vols 3 & 4 p.32.
[5] The Wilson’s committee was set up in England in 1963 to examine the problem of Noise pollution.
[6] 2nd edition.
[7] One of such scientist is Glover who gave evidence in the case of Hasley v Esso petroleum (1961)2 AER 149
[8] See Halsey v Esso petroleum (Supra).
[9] Like the dawmeter used by Glove in Halsey’s case (supra).
[10] Daily Times May 11,1990 p.4.
[11] Mahammed Javed Aslam, “Effect of Noise Pollution on Hearing of public Transport Drivers in Labore City” (2008) Pakistan Journal of medical science, vol. 24 nos. 1 p.1.
[12] Sound is measured by its frequency. The rate of sound is called frequency and is measured in Hartz (HZ) and sound pressure  measured in decibel (dB). See A.J, Alawode Stephen J.T. and G.J, Adeyemi “Health safety and environmental issues in Nigeria Manufacturing and Processing Industries” (2008) Journal of Engineering and Applied Science p.636 . A normal ear in healthy young person can detect sounds with frequencies from 20H2 to 20,000 HZ, while dogs can hear high-pitched sounds up to 50, 000HZ. Noise measurement are expressed by the term sound pressure level (SPL), which is logarithmic ratio of the sound pressure to a reference pressure and is expressed as a dimensionless unit of power, the (dB), the reference level is 0.0002 microbars, the threshold of human hearing.
[13] J.A Mohammed (Supra)
[14] B.S Kapoor and K, Singh, ‘Noise the insidious Killer’, The Tribune of 25 November 1995 p.5.
[15] G.K, Nagi,  M.K, Dhillon and G.S; Dhlwal ‘Noise Pollution’ Common Wealth Publicater’, New Delhi 1999.
[16] Ezedum, chucks E ‘Urbanization, Global warming and Health’, Nigeria Journal of Health Education (Njhe) vol. 16 no. 1 June 2012.
[17] Sonni Ehi Asuelarian, ‘The Challenge of  Noise to Public Health’ (The Guardian, 5th December, 1984) p.9.
[18] Neighborhood noise affects the residences or occupants of a building in a particular locality and such noise is usually generated from music, motor parks, generating plants, intruder alarm, churches and mosques.
[19]T.O; Akinbulire P.O, Oluseyi, C.O.A  Awosope and O.I; Okoro Data-Based Analysis of power system crisis in Nigeria, takinbulive@unilag.edu.ng; poluseyii@unilag.edu.ng; cawosope@unilag.edu.ng and oiokoro@hotmail.com p1-2, COA Awosope; ‘Power  Demanded but Not Supplied; ‘The Agonizing Roles of Emergency Power of Lagos,’  Inaugural Lecture series; 2003,P.B. Oyebolu; ‘That We May Have Light’ Eleventh October Lecture, Nigerian Society of Engineers, (1992).
[20] Nigeria is facing a very serous erratic electricity supply. All governmental efforts to meet the need of the populace in this premises proved abortive. The industries and most people whom their sources of livelihood depend on electricity find generating plant an inevitable to meet their needs.
[21] There is astronomical increase in rural-urban migration in Nigeria. A significant of urban population use motorized transportation. The noise generated from these is enormous as to affect Human Health.
[22] (1991) 9 NWLR pt 214 p.155 Sc.
[23] The need to build a modern city with up to date amenities has led to the installation of series of machines that uses diesel which produce higher smoke emission while working.
[24] ‘Noise and you’ Awake November 8, 1997, p.7
[25] Rushmer v polsue (1906) 1 ch. 234, Halsey’s case (supra)
[26] M., Deepak  ‘Noise pollution, sources, Effects and control’ (2009) 18th Nursing www. Legalserviceindia. Com/article/noise. htm.
[27] Tebite v Nigeria marine and Trading co ltd  (1971) IUILR 432, Halsey v Esso Petroleum co  (supra) 145, Ige v Taylor Woodrow Nig. Ltd (1963) LLR 140
[28] A Journey through most urban cities in Nigeria will reveal the springing up of places of worship in virtually
     every corner of the cities.

[29] H.  Niemann et al, “Noise-induced Annoyance and Mobility Results from the Pan-European lares study”  
    (2009), Noise Health journal vol. 8 pp 63-79.
[30] Goods are now advertised and sold in vehicle using loud speaker even in promoting goods and services, Banks, GSM providers, Local herb sellers, transporters to invite intending travelers are very prominent in Nigeria.

[31] (1967)FNLR 156, Khorasandjian v Bush (1999) 3 WLR 476CA

[32] See Blackstone’s planning law practice 1999, Blackstone’s press limited p.1011. See also the guidelines and Standards for Environmental Pollution Control in Nigeria.
[33] National Environmental standards and Regulations Enforcement Agency (Establishment) Act, 2007.

[34] Normal growth, premature and intrauterine (inside womb) growth retardation.

[35] See generally, Awake! November 8, 1997, p.7.
[36] L, Redolph, CS Forest, ‘female Reproductive Toxiocology,’ in Lapou  J. ed. Occupational Medicine (Norwalk CT: Appleton & League, 1990) p. 279 and Paul M, (ed), ‘Occupational and Environmental Reproductive Hazards, A guide for clinician’ (Williams and Wilkins, 1993), p.6.

[37] L.B, Arlene ‘The increase in noise pollution: what are the Health Effect and the Harmful of Noise’ http://www.findarticles.com. In 1982, the United State of America issued a warning that pregnant mothers should not work in Noisy industrial plants.

[38] National Concord of 11th June, 1984

[39] Theodore Okonkwo The Law of Environmental Liability, Afrique Environmental Development and education, 2nd edition 2010 p.391.

[40] See FEPA mimeograph vol.1 cited in C.A. Omaka , ‘Municipal and International Environmental Law’ Lions Unique concepts, Lagos Nigeria, 2012 p. 282.
[41] M.Y, Hussian , A.Q, Ghaffar Qureshi & Imran, ‘Road Traffic Noise level at different locations of Fuisalabad’ (Pakistan)(2002) International Journal of Agriculture & Biology p.6 and J.A, Mohammed ,A.S Mohammed & B. Amna, ‘Effect of Noise pollution on hearing of Public Transport Drivers in Lahore city’ (2008) Pakistan Journals of Medical Science vol. 24 N1
[42] Passchier-Vermeer ‘Noise: A health problem’, (2002) Environmental health Perspectives http://www.noisehealth.org.

[43] S. Cohen, G .W. Evans martin, D. Stokols, D.S. Karntz,  Behaviour, Health and Environmental Stress, (New York Press, 1986) p.25.

[44] C.A, Omaka municipal &international environmental law (Supra) p282.
[45] N, Cohen Sweinstein ‘Non-Auditory effect of noise in Behaviour and Health’ Journal of. Social issues, 1981 at 3, pp 36-70.

[46] World Health Organization concluded that the available evidence showed suggested a weak association
      between long-term exposure above 67-70dB and hypertension.
[47] NIPSS at a workshop organized by Nigerian Environmental Society, Lagos 1988.

[48] See law relating to noise by sharp and Jennings. Chap .l and also Clarke and Lindsey on Torts 15th Edition.

[49] See M. Valet, J. Cagnexix & J.M. Clairet, ‘Health Rate Reactivity to Aircraft Noise after long term Exposure’
     in G. Rossi, (ed) Noise a public Health Problem (Centro Recherche  Studio Amphiton, (83) 963.

[50] Ibid note 11.
[51] See A.H. suffer, Noise and its effects, Administrative conference of the United States (1991)
     www.noise.library/suffer. Babisch w.noise Babisch and Health Education: Health 
     perspective (2005) http:www.pubmedcentral.nih.gov/artic/erender.feg article 1253720.

[52] A.S. Stephen & P.M. Mark ‘Noise Pollution: Non-auditory Effect on Health’ (2003) British Medical Bulletin
    Vol. 68 p244.

[53] L.B. Arlene, ‘The Increase in. noise pollution: what are the Health Effects’ www.med-scape.com/vewarticle

[54] (Supra)
[55] D .M. Jone, A.J. Chapman and T .C. Auburn, ‘Noise in the Environment social perspective’ (1981) Journals of  Applied Science and Physiology pp 43-50 at 46.

[56] Most of Nigerian cities are becoming highly populated due to urbanization, thus human activities are more of
   sources of noise therein. (Abuja, Lagos, kano, Kaduna, Port Harcourt, Cross River, Ilorin, Ibadan, Enugu etc).

[57] 20th day of June 1977

[58] Geneva 20-26 June 1977 inforced 11 July, 1979 SMTE 482 (ILO Convention No (48) Art 1 (1) & 4(1).

[59] Convention concerning the protection of workers against occupational Hazards in the working Environment
    due to Air, Noise and vibration 1977.
[60] Theodore Okonkwo The Law of environmental liability, Afrique Environmental Development and Education (AEDE) 2010, 2nd edition p391.
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