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Noisy Autonomy: The Ethics of Audible and Silent Noise

Noisy Autonomy: The Ethics of Audible and Silent Noise PUBLIC HEALTH ETHICS VOLUME 14 ISSUE 3 2021 288–297 288 • • • Noisy Autonomy: The Ethics of Audible and Silent Noise David Shaw *, Department of Health, Ethics & Society, Care and Public Health Research Institute, Faculty of Health, Medicine and Life Sciences, Maastricht University, The Netherlands and Institute for Biomedical Ethics, University of Basel, Switzerland *Corresponding author: David Shaw, Department of Health, Ethics & Society, Care and Public Health Research Institute, Faculty of Health, Medicine and Life Sciences, Maastricht University, Postbus 616 6200 MD Maastricht, The Netherlands. Email: d.shaw@maastrichtuniversity.nl In this paper, I summarize the medical evidence regarding the auditory and non-auditory effects of noise and analyse the ethics of noise and personal autonomy in the social environment using a variety of case studies. Key to this discussion is the fact that, contrary to the traditional definition of noise, sound can be noise without being annoying, as the evidence shows that some sounds can harm without being perceived. Ultimately, I develop a theory of ‘noisy autonomy’ with which to guide us in discussing the public health ethics of noise and other sounds. ‘Certainly there are people, nay, very many, who will Introduction smile at this, because they are not sensitive to noise; it Our house is oddly quiet now that lockdown is over and is precisely these people, however, who are not sensitive the children are back in school. This has given me some to argument, thought, poetry or art, in short, to any kind time to think about noise. By its very nature, noise is of intellectual impression: a fact to be assigned to the annoying; unwanted sound that disturbs and causes dis- coarse quality and strong texture of their brain tissues’ tress. But noise is not only annoying; it can also have (Schopenhauer, 1851). However, it does not follow from serious health effects. Some noise is necessary, but much the fact that determining whether a sound constitutes noise in modern life is unnecessary, and people who noise is a subjective process, that the issue of noise can be create noise risk harming the physical and mental health reduced to sonic relativism. In fact, the opposite is true; of others, whether or not that noise is necessary. As such, the very fact that it is up to each of us to determine what noise is clearly a bioethical issue. we regard as a noise means that the ethical status of the Let’s start with some definitions. Noise is all around sound and who or whatever is generating it is dependent us, but noise is not simply sound. Generally, noise is on the listener’s verdict, not the producer’s. If neither the defined as ‘unwanteD’ or ‘undesireD’ sound (e.g., ‘any producer nor the listener regarded it as noise, there sound that is undesired or interferes with one’s hearing would not be an issue (at least in terms of how noise of somethinG’(Merriam-Webster, 2020)), which makes has traditionally been conceived); if both regarded it as the determination of whether a given sound is noise noise, it would also presumably not be an issue as steps sound rather subjective as it is a matter of personal would be taken to reduce the noise. The ethical issues choice, to some extent. However, one cannot choose around noise arise from the fact that someone does not not to be annoyed by a sound, much as one would like want it, while someone else does (or at least regards it as to be able to do so; that is precisely why noise can be so justified, even if potentially unwanted). annoying and why exercising one’s autonomy with re- Noise can be annoying in two main ways: it can be gard to sound can lead to conflict: one man free to shout annoying in its own right, and it can be annoying because is another’s terrorist. it prevents or diminishes enjoyment or completion of To the extent that it is a personal matter which sounds what one was doing. It is not just that the noise is annoy- are wanted and unwanted, it is true that noise is subject- ing; it is that it stops you enjoying what you would be ive; indeed, some people are not really that bothered by doing if it were not for the noise. As such, noise is a noise. Schopenhauer judged such people rather harshly: spoiler. Roughly speaking, whether noise is ethically doi:10.1093/phe/phab026 Advance Access publication on 29 October 2021 V C The Author(s) 2021. Published by Oxford University Press. This is an Open Access article distributed under the terms of the Creative Commons Attribution-NonCommercial License (https://creativecommons.org/ licenses/by-nc/4.0/), which permits non-commercial re-use, distribution, and reproduction in any medium, provided the original work is properly cited. For commercial re-use, please contact journals.permissions@oup.com NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 289 acceptable depends on whether it is necessary and thus The Harms of Noise justifiable, but before exploring the ethics in detail, we Noise is not only annoying; it costs lives. In Western should attempt to quantify the potential harms arising Europe alone, the World Health Organisation estimates from noise; as we shall see, even if a sound is not cate- that noise causes the loss of 1 million healthy years of life gorized as noise, it can cause physical harm. This raises every year (Fritschi et al., 2011). Medically, the effects of the curious point that noise can also be noise not because noise are categorized as either auditory or non-auditory. its sound is unwanted but because the medical harms The former category is rather narrow; auditory harms associated with it are not wanted. While some of the are essentially those that produce hearing loss, whether medical effects will not be encountered unless one is occupational or social in cause. In contrast, non- annoyed by the noise, others will occur regardless of auditory harms comprise a broad category that encom- whether it is regarded as noise or mere sound (this issue passes annoyance, cognitive impairment, sleep disturb- is explored more in the next section). ance and cardiovascular health. In this paper, I focus on Before proceeding, it will be useful to define what I non-auditory harms, but the term ‘non-auditory’ can be mean by ‘noisy autonomy’. Noisy autonomy is best confusing because annoyance is a conscious non- understood as our capacity for self-determination in re- auditory effect that is nonetheless directly related to lation to how noise (both audible and silent) affects our what is heard, while those affected by sleep disturbance lives; as such it is an important component of our per- may not be aware of any ill effects, making such harm sonal autonomy. In practical terms, it concerns both our non-auditory but also non-conscious. A Lancet review rights in terms of making noise and our obligations in states that: terms of considering the effects of that noise on others. Annoyance is the most prevalent community re- The subjective nature of noise as annoyance means that sponse in a population exposed to environmental there is ample room for disagreement about precisely noise. Noise annoyance can result from noise where those rights and responsibilities lie. This balance interfering with daily activities, feelings, thoughts, between rights and responsibilities is further compli- sleep, or rest, and might be accompanied by nega- tive responses, such as anger, displeasure, exhaus- cated by the fact that imperceptible or unperceived noise tion, and by stress-related symptoms. In severe can also be harmful, and we also have both a right to forms, it could be thought to affect wellbeing know this and an obligation to take it into account; and health, and because of the high number of knowledge about the effects of noise on oneself and people affected, annoyance substantially contrib- others is highly significant for noisy autonomy. utes to the burden of disease from environmental As will become clear, noisy autonomy reflects a relational noise. (Basner et al., 2014) understanding of autonomy (Mackenzie and Stoljar, 2000; Annoyance is not merely an emotional state; it also has Donchin, 2001); it concerns not only the traditional bio- physiological consequences: ‘noise exposure increases ethical conception of respect for individual autonomy but systolic and diastolic blood pressure, changes heart also acknowledges that ‘persons are inherently social and rate, and causes the release of stress hormones’ (Basner politically and economically situated beings, raised in social et al., 2014). While annoyance might seem a rather ob- settings, who learn to develop their interests and values in vious direct reaction to noise, medically speaking the conversation with other social and politically and econom- emotional stress reaction is referred to as indirect, while ically situated beings’ (Baylis et al., 2008). Indeed, noise is physiological disruption due to noise (other than hear- the perfect instantiation of our social embeddedness, as we ing loss) is referred to as a direct pathway: cannot live without making or hearing it, and noise can Potential mechanisms are emotional stress reac- harm others without even being perceived. Given the (anti- tions due to perceived discomfort (indirect path- )social nature of noise, considering it from the perspective way), and non-conscious physiological stress of relational autonomy is more appropriate than more from interactions between the central auditory traditional individualistic conceptions of autonomy. system and other regions of the CNS (direct path- way). The direct pathway might be the predom- (Such relational accounts of autonomy are increasingly inant mechanism in sleeping individuals, even at common in bioethics (Jennings, 2016) and are particularly low noise levels. (Basner et al., 2014) suited to public health ethics (Owens and Cribb, 2013).) Finally, as we shall see, noise also raises important issues Noise also affects cognitive performance and develop- regarding justice because of its differential presence in dif- ment in children (Passchier-Vermeer and Passchier, ferent environments. 2000). 290 SHAW As mentioned in the introduction, it is important to The non-conscious harms attributable to noise raise note that noise disrupts autonomy in not one, but two two interesting and interrelated issues regarding the def- inition of noise and the nature of noisy autonomy. ways. One not only does not want to hear the noise; one If noise is unwanted sound, and I hear an unwelcome wants to carry on one’s activities without them being sound, then I can accurately and reliably label that sound disrupted by the noise. For many people, it is not just as noise. Yet the scientific evidence illustrates that sound the noise itself that is annoying—it is the way in which can harm even if it is not actually annoying for an indi- noise prevents or interrupts the enjoyment of some other vidual—indeed, the medical literature refers to such ongoing activity, as already mentioned. As such, noise is sound as noise even if it is not unwanted. As such, the both intrinsically and extrinsically annoying. medical literature labels sound as noise if it causes harm, Furthermore, both the intrinsic and the extrinsic annoy- rather than simply if it causes annoyance (though this ance will increase in inverse proportion to the perceived particular point does not seem to be acknowledged any- necessity of the noise. Ultimately, ‘chronic exposure can where in the literature), changing the definition from .. .. increase the risk of hypertension, arteriosclerosis, being subjective to having some degree of objectivity. and .. . severe events, such as myocardial infarction The person who has a high noise threshold might even and stroke .. . [with] higher prevalence and incidence be hearing noise at very harmful levels without being of cardiovascular diseases and mortality in highly noise- bothered or annoyed by it; such a person is thus more exposed groups’ (Basner et al., 2014). likely to be unaware that noise he or she is generating— In addition, while noise can disturb sleep by waking whether high or relatively levels—might be annoying for people up, it can also cause disturbance without the per- others. son being aware of it: ‘Human beings perceive, evaluate, The idea that sound can be noise without being and react to environmental sounds, even while asleep .. . annoying has obvious implications for noisy autonomy. Short-term effects of noise-induced sleep disturbance What if a person is aware of sound that does not pass her include impaired mood, subjectively and objectively threshold of auditory disturbance, and she thus does not increased daytime sleepiness, and impaired cognitive regard as noise, while also unaware that those sounds are performance’ (Basner et al., 2014). Thus noise can actu- harming her? According to this person, this is not noise, ally harm people in four distinct ways: (i) it can cause but according to the medical literature, it is—at least in hearing loss (the auditory effect); (ii) it can cause stress the non-auditory sense of sound that causes harm. As and distress via annoyance; and (iii) it causes non- such, it is simultaneously a non-annoying noise (or ra- conscious physiological harm through (e.g.) heart dam- ther, sound, by the old definition), and a non-auditory age caused both by the (conscious) stress and (iv) via noise—so it is noise despite not being noise in at least direct non-conscious physiological effects on the body. two senses. Note that there can be overlap between these categories; Of course, if someone were to tell me about the non- some people may not be annoyed by a particular loud auditory harms to which I am exposed, I might well re- sound (and might not class it as noise in the traditional gard them (the sounds, not the person) as annoying, sense) but might nonetheless be physiologically harmed which could in turn lower my threshold for annoyance by it. Thus noise can be noise without being perceived at at hearing the auditory signals associated with the non- all, but also while being perceived but without being auditory harms. Ironically, of course, learning about the perceived as annoying. Table 1 summarizes these cate- potential harms could in turn increase my stress levels in gories of noise and their harmful effects. two ways; by making me worry about the non-auditory Table 1. Categories of noise and their harmful effects Nature of noise Effect of noise Perceived as noise Noise (perceived yet Non-perceived Hearing about harms of (annoying) not annoying) noise non-perceived noise Hearing loss (auditory) If sufficiently loud Possible (e.g., No No loud music) Stress and distress (indirect) Yes No No Yes Physiological harm (direct) Yes Yes Yes Yes (via stress) NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 291 effects of noise and by increasing (or creating) the stress what everyone else is doing there, and because that is associated with the sounds in question when I experience what motorways are designed for. Generally speaking, them; before, they did not annoy me, and now they may. hillsides are designated as natural spaces, which imply a However, while it might increase rather than decrease certain degree of peace and quiet. The context of noise harms done to me, telling me about the non-auditory also relates to how disruptive it is to activity; if I am doing effects of noise does increase my range of future options the dishes or working in a noisy kitchen or even watching for autonomous choice by educating me about a harm a loud film, someone turning on a lawnmower two gar- that I was not aware of, even if I am not currently able to dens away will hardly register, whereas if I was having exercise my autonomy in any way that can prevent that lunch in the garden enjoying birds singing, the effect harm from affecting me. However, I can then act in such would be quite different. as way as to limit my own noisemaking activity to pre- Another important contextual feature is the reason for vent others from these newly recognized (and other) making noise, and whether that reason is reasonable. harms. Having set the scientific scene, we can now Voice suggests four requirements for his ‘Test of move on to a closer consideration of the ethics of noise. Reasonable Noise’: The noisy practice is connected with a reasonable comprehensive doctrine. The Ethics of Noise The practice is part of the history and traditions of Noise clearly causes vast amounts of harm to millions if that doctrine. not billions of people. Often the term ‘noise pollution’ is The practice is essential to the activity (as judged used to reflect the harm that it causes (paradoxical as any from within the perspective of that doctrine). noise is by definition pollution; a more accurate term might be sonic pollution). Yet sometimes noise is neces- The reasonableness of the practitioners is evident sary. Even Schopenhauer, who detested noise, acknowl- in attempts to meet the concerns of other citizens. (Voice, 2009) edged that a case can be made for justifiable noise: Hammering, the barking of dogs, and the scream- Thus, someone might have a good reason for playing ing of children are abominable; but it is only the music outdoors as part of a music festival, but not for cracking of a whip that is the true murderer of listening to loud music without earphones in the quiet thought. Its object is to destroy every favourable carriage of a train. Music festivals have a long tradition, moment that one now and then may have for re- and the noise is to some degree necessary; in contrast, flection. If there were no other means of urging on listening to music on a speaker instead of earphones in a an animal than by making this most disgraceful of all noises, one would forgive its existence. But it is place that is meant to be quiet is unnecessary and hence quite the contrary: this cursed cracking of whips is unreasonable. not only unnecessary but even useless. However, the aforementioned non-conscious nature (Schopenhauer, 1851) of some harms caused by noise raises some problems for this account. Voice (2009) states that ‘Obviously, no Schopenhauer might have been happier in Ancient sound is noise without someone hearing it as noise’ Rome, where a law was once implemented that prohib- but as stated above, the evidence shows that unperceived ited coppersmiths on any streets where professors lived. sound can harm in a way that is unwanted, and as such Fortunately, whips are only rarely heard nowadays, but constitutes noise. Thus, even if people are not woken by we have plenty of newer alternative sources of noise, cars, church bells being rung late at night, their sleep can still planes and mobile phones among them. In this section, I be disturbed, with harmful physiological effects. This consider several different sources of noise and their jus- also applies to people who are awake; they might not tifiability in order to assess their ethical status. be annoyed by background noise that nonetheless has The start of our first lockdown was made easier by the a negative effect on their well-being. Non-conscious fantastic spring weather, but it was difficult to enjoy the garden because someone always seemed to be mowing effects could and should be factored into any test of rea- sonable noise, tipping the balance more towards noise their lawn. In considering different examples of noise and their associated effects on persons’ autonomy and being unreasonable because of probable yet generally well-being, we should of course be mindful of context. unquantifiable health effects. One person generating lots of noise on a silent hillside is Another issue affecting Voice’s test is that it is not worse than dozens driving on the motorway, partially obvious why history and tradition should be considered because each person on the motorway is simply doing relevant countervailing factors to be weighed against 292 SHAW public health harms. The fact that a noisy activity has a Droning on: Two Noisy Cases long history is irrelevant if it causes harm to people’s Now let us turn to some cases to consider noisy auton- health and well-being now. Furthermore, a practice omy in practice. Given the importance of context to our could be essential to an activity without being noisy. assessment of the justifiability of noise, it is not surpris- Any evident reasonableness on the part of the practi- ing that a great deal of annoyance can result when new tioners would include attempting to find non-noisy sources of noise are introduced into a novel context. Two ways of achieving the goal achieved by the noisy practice. similar examples are the introduction of jetskis and If they refuse to attempt to do so, they are not being rea- speedboats to a countryside loch, and the use of drones sonable. So if Voice’s test is actually unreasonable, par- up a mountain. Loch Lomond is Scotland’s largest loch ticularly given the medical evidence of harm from by surface area and has been a haven for those seeking auditory, non-auditory and non-conscious noise, what nature and beauty for over a hundred years. It also lies should the criteria be for reasonable noise? In other words, only half an hour’s drive from Glasgow, and the south- what constraints should there be upon our noisy west shores have been subject to a degree of commercial- autonomy? ization. In the early 2000s, there was intense debate Respecting other people’s noisy autonomy—which around the use of the loch by water-skiers, jet-skiers includes not only the freedom to make noise but the free- and motorboats. One correspondent to the Glasgow dom to be free of it if one so wishes—cannot consist sim- Herald wrote that ‘The emphasis seems to have slipped ply in avoiding making noise that one would find towards simply banning jet skis, which, while desirable, annoying. There are several reasons for this. As already only addresses part of the speed problems. Water skiing mentioned, perceptions of noise are subjective, and what is just as noisy, just as damaging to the enjoyment of might not seem like noise to you might be very noisy to every other person either using the loch or its surround- me. This could be because you have a high noise threshold ings and just as dangerous to the health of both wildlife and I have a low one. Complicating the picture further is and humans .. . The noise is incredible’ (Morrisson, the fact that you might have a good reason for making the 2004). However, those who use powered transport on the loch derive great enjoyment from doing so; so could noise, but I do not know what that reason is, potentially the generation of this noise be considered as reasonable? resulting in a situation where you are making sound that The use of engines on the surface of a loch that is the you do not regard as a noise, for a good reason, but to me centrepoint of a national park is perhaps the classic ex- it seems like loud noise for no good reason. We also know ample of conflict between people exercising their noisy that noise can harm without being perceived by any autonomy in particular ways that may be mutually in- involved party as noise, but that is difficult to consider compatible. The walkers, yachters, climbers and picnick- in such deliberations; perhaps, we simply have an add- ers would prefer to have peace, quiet and tranquillity; the itional weak obligation to avoid making noise because of powerboaters and jet-skiers want to do as their names the non-auditory unperceived harms it can do to others. suggest. Is it fair to them to ban such activity because it Noisy autonomy can also be illuminated by consider- disturbs the majority of visitors to Loch Lomond? The ing the scale of the potential harm that can be generated nature of noise puts noisy loch users at a substantial very easily; indeed, it is all too easy to make noise and disadvantage in terms of reasonableness. It only takes very difficult to avoid it. One person can engage in ac- one speedboat with one person on it going up the loch tivity that causes noise to be heard by hundreds, or even at 50 miles an hour to shatter the peace and quiet for thousands (e.g., a loud car driven at speed at night). miles in each direction, violating the negative liberty of Some people will not notice the noise at all, but could those using the loch for quieter pursuits. In terms of still be affected by it if it causes physiological damage. relational autonomy, this could also be seen as dominat- Others will notice the noise, but not mind it, even if it ing ‘quiet’ loch users by denying them the ability to ex- causing such damage, making it sound rather than noise ercise their noisy autonomy; one can only exercise one’s according to the old definition. Others will be annoyed freedom in this sense if one is not dominated by others by the noise and label it as noise in the classic sense. (Of (Wenner, 2020). The disutility of even one boat being course, noise is also relevant during the current Covid- used this way in terms of the annoyance and potential 19 pandemic; some countries have banned music in pubs stress to other loch(side) users is out of all proportion to because the noisier the environment (BBC, 2020), the any potential enjoyment of those on the boat. For some more likely it is that people will raise their voices and walkers and other people around the loch, this noise increase the risk and range of viral spread.) might merely be offensive; but for others, it could NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 293 actually do harm. The aforementioned point about an- the Isle of Skye, my family and I climbed up to the Old noyance stemming not only from the noise itself but Man of Storr, a famous natural pinnacle about 500 from distress at the disruption of another activity is par- metres above sea level that sits below even bigger cliffs. ticularly relevant here. The medical evidence also shows At one point, I heard a loud buzzing sound and warned that time spent in natural settings is beneficial for health the kids to look out for wasps, before realizing that the and well-being. If that time is disrupted by man-made sound was coming from high above our heads: it was a noise, not only is stress and annoyance caused because of drone. On realizing this, the sound was instantly trans- that noise; the opportunity to exercise freedom in attain- formed into a noise. Note that this was not because it was ing that benefit is also compromised. Thus noise can not hugely loud; rather, we had been enjoying the spectacu- only spoil fun and harm health; it can also prevent health lar views and the peace and quiet; now, the tranquillity benefits being achieved. (One might term this noise’s was disturbed by the drone and we also had to keep an double effect; it harms health and also prevents health eye on it to make sure it was not going to fall on us (if it being improved through relaxation.) In such circum- had been a wasp, I would not have categorized it as noise stances, the term ‘offensive’ is insufficient; harm can re- as we could easily have moved out of range of the sound sult both from irritation at the sound itself and from the and the sting; a drone is different). Its user was not ob- prevention of peaceful activity in the vicinity of the loch. viously in sight, although we could see several few people Ironically, however, if there are 10 boats, the increase quite far away (as the Storr is a popular site). Had I seen in disutility for ‘quiet’ loch users compared with one the operator, I would have asked him to turn the drone boat is so marginal that it becomes easier to make a off. Would that have been proportionate? The drone case for power-boating as a permissible practice. The may have been being used to film or take photographs difference between (near-) silence and one boat is mas- rather than ‘just for fun’, but the sound would have been sive; the difference between one and 10 is almost insig- audible to dozens of other people, many of whom were nificant by comparison. And of course, the competing presumably annoyed as well. The noisy whirr of the utility of boat users is substantially increased for each drones’ rotors entirely changed the environment of the extra boat on the water. Recognizing that a complete Storr, and preventing us from exercising our autonomy ban on vessels with engines on the loch would be dispro- as we wished to. portionate, the National Park introduced byelaws to Again, this might be deemed offensive rather than regulate noise and other disturbance; all such vessels harmful, but the drone was certainly creating noise pol- ‘shall be fitted with a silencer expansion chamber or lution that harmed the environment and our experience other contrivance suitable and sufficient to prevent the of it; the operator may have been unaware of this, but occurrence of noise amounting to a Nuisance caused by that in turn suggests something of a lack of consider- the escape of the exhaust gases from the engine’ ation, or that he was operating it from too great a dis- (LLTNPA, 2013). Furthermore, though the maximum tance. I return to the issue of the threshold for harmful speed in the centre of the loch is 90 kilometres per hour, noise in the next section. in all areas within the designated zones on the west, south In fact, as I found out once I was back in the office, this and east of the parts of the loch most frequented by drone operator was not following best practice and also walkers and other nature lovers (including swimmers) breaking the law as reflected in the Civil Aviation the limit is 11 kilometres per hour—i.e., much quieter. Authority’s ‘Drone Code’ (UKCAA, 2019). The drone While many lovers of tranquillity would prefer an out- was directly over our heads for several minutes despite right ban on vessels with engines, this solution seems the law stating that drones should be at least 50 metres proportionate and ensures that different groups of citi- away (horizontally) from any people other than the op- zens can access the loch in a reasonable way, while erator. Note, however, that while these legal stipulations respecting one another’s autonomy. (While this example mean that the drone should not have been flown over might not seem relevant in terms of non-conscious our heads or up at the Storr, they do not say anything noise, it is entirely possible that residents living around about the level of noise emitted by a drone. Had the Loch Lomond do not mind the sound of powerboats, yet drone kept away from us, the law would have been sat- are subconsciously harmed by it, or even if it annoys isfied, but we would not have been, as we would still have them while they are awake do not realize that it is dis- heard the drone at almost the same volume. The Code rupting their sleep and thus harming them.) A more recent development is the introduction of stipulates that all drone operators must pass a test and drones into natural settings. On holiday recently on register as users, but says nothing whatsoever about 294 SHAW noise. In contrast, a best practice guide for drone users in unannoying, but remains annoying sound according to the traditional definition of noise.) Scotland states the following: The question of whether noise annoyance is offensive Drones are noisy bits of kit and the last thing or actually harmful is highly context-dependent. As people want when out enjoying the tranquil Passchier-Vermeer and Passchier (2000) put it: ‘Noise sounds of Scotland’s nature is a drone buzzing annoyance is a feeling of resentment, displeasure, dis- around their heads. Have respect for other users of the countryside, don’t just throw your drone comfort, dissatisfaction, or offense when noise interferes up next to a group of walkers, it’s disrespectful with someone’s thoughts, feelings or actual activities. It and inconsiderate. If you are desperate to catch is not yet possible to predict noise annoyance on an in- that shot and there are people around, it is good dividual basis because of the large variety of (partly un- practice to ask any other users, walkers, climbers, known) endogenous and exogenous characteristics that bikers, etc. for permission. (Houston, 2020) affect annoyance’. Further complicating these factors are (Note the assumption that the drone is being used for a three others; annoyance also relates to a given person’s anxiety, any fear of the noise source, and whether the specific purpose.) This respectful guidance puts the rea- noise was perceived as avoidable. The same authors sonableness test in the hands of those affected by the found that taking air, road and rail noise at a level of drone’s noise: the choice is left to those affected by the 70 decibels, around 15 per cent found the rail noise noise. In effect, it is up to them to decide whether it is annoying, 25 per cent found the road noise annoying noise, and whether that noise is reasonable. However, in and over 40 per cent found the plane noise annoying many parts of Scotland people could be affected by the (Passchier-Vermeer and Passchier, 2000). In other noise of a drone without being seen by the operator, words, and unsurprisingly, whether a noise is annoying which raises issues not only around noise but also depends not only on the person experiencing it but also around safety; the law states that operators must always on its source. Nonetheless, if noise causes discomfort or keep the drone in sight, but not that they must ensure distress, then it is probably reasonable to categorize it as they can see anyone who could be within 50 metres range harmful. In the case of the Drone, I was indeed distressed of it—a paradox given the requirement to ensure a drone because I had sought a quiet retreat from technology, should be kept within 50 metres range. In terms of and the noise did cause discomfort; the fact that the noise respecting others’ noisy autonomy, those generating was certainly avoidable also played a role. In the case of noise have a responsibility to ensure that they are at least the loch, where mitigations and noise restrictions are in close enough to accurately gauge the potential for caus- place, it seems more likely that noise will merely cause ing annoyance to others. offence. But ultimately, in any scenario where noise causes annoyance or offence, it can cause stress, and stress can harm in a variety of ways: ‘psychologic (feel- Noisy Autonomy, Harm and Justice ings of fear, depression, sorrow), behavioral (social iso- The drone and loch examples both feature noise in rec- lation, aggression, excessive use of alcohol, tobacco, reational scenarios, and for a more detailed exploration food, drugs), and somatic (cardiovascular, gastrointes- of how noisy autonomy relates to harm and justice, tinal, respiratory illnesses)’ (Passchier-Vermeer and returning to urban examples of noise will be helpful. Passchier, 2000). Before proceeding, however, we should return to the There are clearly borderline cases where the margin issue of whether and when noise is harmful as opposed between offence and harm is slim but as explained in the to merely offensive. Harms of Noise section and associated table, noise can In the UK, noise is defined as anti-social if it causes clearly harm people in four ways: it can cause hearing loss ‘nuisance and annoyance’ (CAB, 2018). Nuisance and an- (auditory effect); it can cause stress via annoyance (see noyance suggest that noise is offensive rather than harm- previous paragraph); and it can cause non-conscious ful, but at the same time ‘anti-social’ suggests a certain physiological harm via conscious stress that harms the degree of harm. Of course, anti-social noise regulations body and via direct non-conscious effects on the body. and laws normally concern disputes between neighbours, Many people are exposed to these harms because they but they can also be applied more widely. (This definition live close to major sources of noise such as railway lines, of anti-social noise is interesting in light of the traditional major roads and motorways. If they regard this noise as definition of noise as any annoying sound. In effect, the annoying, they risk some serious health harms, includ- UK definition creates a category of annoying sounds that ing stroke and heart attack, according to Basner et al. (see are not annoying; noise that is not anti-social is deemed Introduction section). But of course, they might find this NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 295 noise annoying at first, but become used to it over time. Policy and Personal Implications of As already explained, however, the fact that they no lon- Noisy Autonomy ger find the noise annoying does not mean that it is not harming them; as Basner et al. state, even noise experienced The drone example illustrates both how noise is often when asleep,suchasloudtraffic,can impair mood,increase neglected by legislation on new technology, and how this sleepiness and reduce cognitive performance. fact requires the adoption of good practice by operators All of these harms are associated with noise pollution, of that technology. In this case, the autonomy of other and laws exist to regulate industrial and domestic pro- people is respected by reliance on reasonableness and a duction of noise. But in terms of noisy autonomy, if respectful approach being adopted by potential noise- individuals are to exercise self-determination with re- makers. But how should regulators and society as a gard to how noise affects them and others—in other whole approach the challenging issue of dealing with words, in order to exercise relational autonomy mean- non-conscious noise, which can harm people without ingfully—it is imperative that people know that unper- them being aware of it? ceived noise can be harmful. Ideally, legislators would take much greater account of Yet the nature of this harmful yet not annoying noise the harms caused by non-auditory noise. As suggested has another problematic feature; if we seek to maximize above, any discussion about the proportionality and rea- citizens’ noisy autonomy by telling them that the noise sonableness of noise generation should consider not that they now no longer regard as annoying is nonethe- only the potential for annoyance and distress but also less harming them, we risk increasing the overall harm to the physiological non-auditory and non-conscious which they are exposed by increasing the risk that they harms. For example, if science shows that drone use at will worry about the noise, and also run the risk of mak- night disrupts people’s sleep patterns (even without ing that noise annoying again for that very reason. Yet them knowing it), that would be evidence in favour of even without considering the importance of information a prohibition on such use—though not necessarily con- for self-determination, if we regard harms such as the clusive evidence. Similarly, it seems plausible that peo- potentially avoidable cognitive impairment of children ple’s enjoyment of outdoor spaces might be at least as important, such risks of increasing harm must be marginally compromised by background noise that deemed reasonable and necessary. I return to this issue remains subconscious; I might notice a drone when in the following section, but another issue that compli- someone else doesn’t, but it could still be affecting cates this already-complex aural landscape is that even if them regardless. told about these harms, some people might be unable to Legislators should also take our noisy autonomy ser- relocate to somewhere quieter due to economic con- iously. Generally, if there is a known threat to public straints; most noise burden is borne by those who live health, the public are informed about it, and there is in noisy city centres, not those in quiet leafy suburbs. In no obvious reason why that should not be the case addition, lower-paid workers are more likely to have jobs here. Indeed, the very idea that noise can be harmful that put their hearing at risk, and over 1 million people in without being perceived is one that the public should the UK are exposed to levels of noise that put their hear- be informed about, as it would increase their autonomy ing at risk at work (in addition to the increased risk of to have this information; different life choices might be harm from other causes due to high noise levels, such as made if people knew about all these additional potential not hearing warnings) (IOSH, 2021). This phenom- harms of noise. Furthermore, if people should indeed be enon—which I term ‘sonoeconomic inequality’— informed about the potential negative effects of non- means in turn that the noisy autonomy of those living conscious noise upon their health, they should probably in noisier areas is subject to greater constraints than also be told about the non-auditory effects on their car- those living elsewhere—another challenge for health diovascular system of getting annoyed about noise— justice. The effects of noise on children living in urban paradoxically, even if this will increase their risk of areas are even more of a pressing concern for two rea- such harm, because they will be both more likely to get sons: they are a vulnerable population subject to greater annoyed by noise, and more likely to get stressed protections, and some of the harms of urban noise affect through worry about those effects. Finally, the serious children more than adults in terms of years of life with health justice issues raised by noisy autonomy also war- reduced quality of life (Passchier-Vermeer and rant careful consideration by public health bodies and Passchier, 2000). legislators. 296 SHAW Enhancing citizen’s autonomy by informing them noise reduces the incidence of noise, it will also tend to about all the potential ill effects of noise could also reduce the infringement of others’ autonomy through have the effect of reducing the amount of noise. If people bothersome generation of unnecessary noise. are aware of and even worried about the effects of noise Noise is important for our autonomy, and autonomy on health, they are likely to be more considerate in terms is important for noise. We have rights and responsibil- of generating sound—hopefully reducing the frequency ities regarding noise, and thus we must consider noise (no pun intended) with which sound crosses the thresh- not only in terms of individual autonomy but also rela- old into noise. Thus, maximizing noisy autonomy by tional autonomy. The phenomenon of unperceived yet informing everyone about the auditory, non-auditory harmful noise further complicates the picture. I hope to and non-conscious effects of noise is likely to increase have convinced the reader of three key claims. First, those effects in the short term (by making people more while we all have a certain degree of autonomy in making aware of noise and hence at least temporarily more sound, generating noise can infringe autonomy in many harmed via stress response and distress), while also being ways. Second, the traditional definition is wrong: (non- likely to lessen the incidence of noise in the medium to conscious) noise can be noise without being noticed, or longer term through increased noise conscientiousness. even without being heard, because people would regard Of course, maximizing the public health benefit by it as troublesome if they knew of the harm that such reducing noise is not the only advantage; in addition, sounds can do. And finally, governments and public it is good to maximize people’s capacity for exercising health authorities have a duty to maximize people’s au- their autonomy in ways that also do not infringe the tonomy by not only attempting to reduce both non- autonomy of others. In other words, by informing peo- conscious and other non-auditory noise (as well as noise ple about the complex nature of noisy autonomy—or at that could damage hearing) but also by educating them least making them aware of the potential for causing about the potential harms of noise and sounds that do perceived and unperceived harm in this regard—they not yet pass their personal noise threshold. This is the will be able both to act more autonomously and to re- case even if, in so doing, we turn sounds that were not spect others’ autonomy to a greater extent. (Again, given heard into silent yet recognized noise, and thus increase our obligations regarding noise and the harms it can the harms that we were initially warning about. While cause others, a relational rather than individualistic ac- this might seem counter-productive, doing so both max- count of autonomy is appropriate when considering the imizes our noisy autonomy and will also hopefully re- public health ethics of noise.) One constraint on their duce all sorts of noisemaking in society. ability to act more autonomously, of course, is the issue of sonoeconomic inequality mentioned above; some citizens are more able than others to act against or Conflict of Interest move away from noisy neighbourhoods. None declared. Conclusion References In some apartments in Switzerland, men are forbidden Basner, M., Babisch, W., Davis, A., Brink, M., Clark, C., to urinate while standing during the night. This might Janssen, S., and Stansfeld, S. (2014). Auditory and seem like a bizarre rule that infringes men’s autonomy in Non-Auditory Effects of Noise on Health. Lancet, an unacceptable way. However, this gets things precisely 383, 1325–1332. the wrong way around. It is not banned because of wor- Baylis, F., Kenny, N. P., and Sherwin, S. (2008). A ries that they would do so in the dark and miss the bowl, Relational Account of Public Health Ethics. Public but because of the potential for noise generation and Health Ethics, 1, 196–209. sleep disturbance posed by loud peeing in the wee small British Broadcasting Corporation (BBC) (2020). Covid in hours (pun intended). Why should people bear the harm Scotland: Pub Ban on Background Music to Be Lifted. of conscious or non-conscious sleep disturbance, against BBCNewswebsite,available from:https://www.bbc.co.uk/ their will, because a man prefers not to sit down while urinating? They should be able to exercise their auton- news/uk-scotland-55260312 [accessed 4 March 2021]. Citizens’ Advice Bureau (CAB) (2018). Complaining omy in enjoying uninterrupted sleep. (Despite generally about Your Neighbour, available from: https://www. high standards of construction, walls can be thin in Switzerland.) If educating people about the harms of citizensadvice.org.uk/housing/problems-where-you-live/ NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 297 complaining-about-your-neighbour/ [accessed 20 July Agency, and the Social Self. New York, NY: Oxford 2021]. University Press. Donchin, A. (2001). Understanding Autonomy Merriam-Webster (2020). Noise, available from: https:// Relationally: Toward a Reconfiguration of Bioethical www.merriam-webster.com/dictionary/noise Principles. Journal of Medicine and Philosophy, 26, [accessed 4 March 2021]. 365–386. Morrisson, J. W. (2004). Jet Skis Are only a Part of Loch Fritschi, L., Brown, A. L., Kim, R., Schwela, D. H., and Lomond Problem. The Herald (Glasgow),13 Kephalopoulos, S. (eds) (2011). Burden of Disease December, available from: https://www.heraldscot from Environmental Noise. Bonn: World Health land.com/news/12410591.jet-skis-are-only-a-part-of- Organization. loch-lomond-problem/ [accessed 4 March 2021]. Houston, C. J. (2020). Drone Photography in Scotland: The Owens, J. and Cribb, A. (2013). Beyond Choice Complete Guide, available from: https://hiddenscot and Individualism: Understanding Autonomy land.co/guide-to-drone-photography-in-scotland/ for Public Health Ethics.PublicHealthEthics,6,262–271. [accessed 4 March 2021]. Passchier-Vermeer, W. and Passchier, W. F. (2000). Institute of Occupational Safety and Health (IOSH) Noise Exposure and Public Health. Environ Health (2021). Noise, available from: https://iosh.com/resour Perspect, 108 (Suppl 1), 123–131. ces-and-research/our-resources/occupational- Schopenhauer, A. (1851). On Noise, available from: health-toolkit/noise/ [accessed 20 July 2021]. https://biblioklept.org/2013/06/06/on-noise-arthur- Jennings, B. (2016). Reconceptualizing Autonomy: A schopenhauer/ [accessed 4 March 2021]. Relational Turn in Bioethics. Hastings Center Report, UK Civil Aviation Authority (UKCAA) (2019). The 46, 11–16. Drone Code, available from: https://dronesafe.uk/ Loch Lomond & The Trossachs National Park Authority wp-content/uploads/2019/11/Drone-Code_October2019. Loch Lomond Byelaws (LLTNPA). (2013). Available pdf [accessed 4 March 2021]. from: https://www.lochlomond-trossachs.org/wp-con Voice, P. (2009). Unjust Noise. Etikk I Praksis. Nordic tent/uploads/2016/07/Loch-Lomond-Byelwas-2013.pdf Journal of Applied Ethics, 3, 85–100. [accessed 4 March 2021]. Wenner, D. (2020). Nondomination and the Limits of Mackenzie C. and Stoljar N. (eds) (2000). Relational Relational Autonomy. IJFAB: International Journal of Autonomy: Feminist Perspectives on Automony, Feminist Approaches to Bioethics, 13, 28–48. http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png Public Health Ethics Oxford University Press

Noisy Autonomy: The Ethics of Audible and Silent Noise

Shaw, David
Public Health Ethics , Volume 14 (3): 10 – Oct 29, 2021
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PUBLIC HEALTH ETHICS VOLUME 14 ISSUE 3 2021 288–297 288 • • • Noisy Autonomy: The Ethics of Audible and Silent Noise David Shaw *, Department of Health, Ethics & Society, Care and Public Health Research Institute, Faculty of Health, Medicine and Life Sciences, Maastricht University, The Netherlands and Institute for Biomedical Ethics, University of Basel, Switzerland *Corresponding author: David Shaw, Department of Health, Ethics & Society, Care and Public Health Research Institute, Faculty of Health, Medicine and Life Sciences, Maastricht University, Postbus 616 6200 MD Maastricht, The Netherlands. Email: d.shaw@maastrichtuniversity.nl In this paper, I summarize the medical evidence regarding the auditory and non-auditory effects of noise and analyse the ethics of noise and personal autonomy in the social environment using a variety of case studies. Key to this discussion is the fact that, contrary to the traditional definition of noise, sound can be noise without being annoying, as the evidence shows that some sounds can harm without being perceived. Ultimately, I develop a theory of ‘noisy autonomy’ with which to guide us in discussing the public health ethics of noise and other sounds. ‘Certainly there are people, nay, very many, who will Introduction smile at this, because they are not sensitive to noise; it Our house is oddly quiet now that lockdown is over and is precisely these people, however, who are not sensitive the children are back in school. This has given me some to argument, thought, poetry or art, in short, to any kind time to think about noise. By its very nature, noise is of intellectual impression: a fact to be assigned to the annoying; unwanted sound that disturbs and causes dis- coarse quality and strong texture of their brain tissues’ tress. But noise is not only annoying; it can also have (Schopenhauer, 1851). However, it does not follow from serious health effects. Some noise is necessary, but much the fact that determining whether a sound constitutes noise in modern life is unnecessary, and people who noise is a subjective process, that the issue of noise can be create noise risk harming the physical and mental health reduced to sonic relativism. In fact, the opposite is true; of others, whether or not that noise is necessary. As such, the very fact that it is up to each of us to determine what noise is clearly a bioethical issue. we regard as a noise means that the ethical status of the Let’s start with some definitions. Noise is all around sound and who or whatever is generating it is dependent us, but noise is not simply sound. Generally, noise is on the listener’s verdict, not the producer’s. If neither the defined as ‘unwanteD’ or ‘undesireD’ sound (e.g., ‘any producer nor the listener regarded it as noise, there sound that is undesired or interferes with one’s hearing would not be an issue (at least in terms of how noise of somethinG’(Merriam-Webster, 2020)), which makes has traditionally been conceived); if both regarded it as the determination of whether a given sound is noise noise, it would also presumably not be an issue as steps sound rather subjective as it is a matter of personal would be taken to reduce the noise. The ethical issues choice, to some extent. However, one cannot choose around noise arise from the fact that someone does not not to be annoyed by a sound, much as one would like want it, while someone else does (or at least regards it as to be able to do so; that is precisely why noise can be so justified, even if potentially unwanted). annoying and why exercising one’s autonomy with re- Noise can be annoying in two main ways: it can be gard to sound can lead to conflict: one man free to shout annoying in its own right, and it can be annoying because is another’s terrorist. it prevents or diminishes enjoyment or completion of To the extent that it is a personal matter which sounds what one was doing. It is not just that the noise is annoy- are wanted and unwanted, it is true that noise is subject- ing; it is that it stops you enjoying what you would be ive; indeed, some people are not really that bothered by doing if it were not for the noise. As such, noise is a noise. Schopenhauer judged such people rather harshly: spoiler. Roughly speaking, whether noise is ethically doi:10.1093/phe/phab026 Advance Access publication on 29 October 2021 V C The Author(s) 2021. Published by Oxford University Press. This is an Open Access article distributed under the terms of the Creative Commons Attribution-NonCommercial License (https://creativecommons.org/ licenses/by-nc/4.0/), which permits non-commercial re-use, distribution, and reproduction in any medium, provided the original work is properly cited. For commercial re-use, please contact journals.permissions@oup.com NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 289 acceptable depends on whether it is necessary and thus The Harms of Noise justifiable, but before exploring the ethics in detail, we Noise is not only annoying; it costs lives. In Western should attempt to quantify the potential harms arising Europe alone, the World Health Organisation estimates from noise; as we shall see, even if a sound is not cate- that noise causes the loss of 1 million healthy years of life gorized as noise, it can cause physical harm. This raises every year (Fritschi et al., 2011). Medically, the effects of the curious point that noise can also be noise not because noise are categorized as either auditory or non-auditory. its sound is unwanted but because the medical harms The former category is rather narrow; auditory harms associated with it are not wanted. While some of the are essentially those that produce hearing loss, whether medical effects will not be encountered unless one is occupational or social in cause. In contrast, non- annoyed by the noise, others will occur regardless of auditory harms comprise a broad category that encom- whether it is regarded as noise or mere sound (this issue passes annoyance, cognitive impairment, sleep disturb- is explored more in the next section). ance and cardiovascular health. In this paper, I focus on Before proceeding, it will be useful to define what I non-auditory harms, but the term ‘non-auditory’ can be mean by ‘noisy autonomy’. Noisy autonomy is best confusing because annoyance is a conscious non- understood as our capacity for self-determination in re- auditory effect that is nonetheless directly related to lation to how noise (both audible and silent) affects our what is heard, while those affected by sleep disturbance lives; as such it is an important component of our per- may not be aware of any ill effects, making such harm sonal autonomy. In practical terms, it concerns both our non-auditory but also non-conscious. A Lancet review rights in terms of making noise and our obligations in states that: terms of considering the effects of that noise on others. Annoyance is the most prevalent community re- The subjective nature of noise as annoyance means that sponse in a population exposed to environmental there is ample room for disagreement about precisely noise. Noise annoyance can result from noise where those rights and responsibilities lie. This balance interfering with daily activities, feelings, thoughts, between rights and responsibilities is further compli- sleep, or rest, and might be accompanied by nega- tive responses, such as anger, displeasure, exhaus- cated by the fact that imperceptible or unperceived noise tion, and by stress-related symptoms. In severe can also be harmful, and we also have both a right to forms, it could be thought to affect wellbeing know this and an obligation to take it into account; and health, and because of the high number of knowledge about the effects of noise on oneself and people affected, annoyance substantially contrib- others is highly significant for noisy autonomy. utes to the burden of disease from environmental As will become clear, noisy autonomy reflects a relational noise. (Basner et al., 2014) understanding of autonomy (Mackenzie and Stoljar, 2000; Annoyance is not merely an emotional state; it also has Donchin, 2001); it concerns not only the traditional bio- physiological consequences: ‘noise exposure increases ethical conception of respect for individual autonomy but systolic and diastolic blood pressure, changes heart also acknowledges that ‘persons are inherently social and rate, and causes the release of stress hormones’ (Basner politically and economically situated beings, raised in social et al., 2014). While annoyance might seem a rather ob- settings, who learn to develop their interests and values in vious direct reaction to noise, medically speaking the conversation with other social and politically and econom- emotional stress reaction is referred to as indirect, while ically situated beings’ (Baylis et al., 2008). Indeed, noise is physiological disruption due to noise (other than hear- the perfect instantiation of our social embeddedness, as we ing loss) is referred to as a direct pathway: cannot live without making or hearing it, and noise can Potential mechanisms are emotional stress reac- harm others without even being perceived. Given the (anti- tions due to perceived discomfort (indirect path- )social nature of noise, considering it from the perspective way), and non-conscious physiological stress of relational autonomy is more appropriate than more from interactions between the central auditory traditional individualistic conceptions of autonomy. system and other regions of the CNS (direct path- way). The direct pathway might be the predom- (Such relational accounts of autonomy are increasingly inant mechanism in sleeping individuals, even at common in bioethics (Jennings, 2016) and are particularly low noise levels. (Basner et al., 2014) suited to public health ethics (Owens and Cribb, 2013).) Finally, as we shall see, noise also raises important issues Noise also affects cognitive performance and develop- regarding justice because of its differential presence in dif- ment in children (Passchier-Vermeer and Passchier, ferent environments. 2000). 290 SHAW As mentioned in the introduction, it is important to The non-conscious harms attributable to noise raise note that noise disrupts autonomy in not one, but two two interesting and interrelated issues regarding the def- inition of noise and the nature of noisy autonomy. ways. One not only does not want to hear the noise; one If noise is unwanted sound, and I hear an unwelcome wants to carry on one’s activities without them being sound, then I can accurately and reliably label that sound disrupted by the noise. For many people, it is not just as noise. Yet the scientific evidence illustrates that sound the noise itself that is annoying—it is the way in which can harm even if it is not actually annoying for an indi- noise prevents or interrupts the enjoyment of some other vidual—indeed, the medical literature refers to such ongoing activity, as already mentioned. As such, noise is sound as noise even if it is not unwanted. As such, the both intrinsically and extrinsically annoying. medical literature labels sound as noise if it causes harm, Furthermore, both the intrinsic and the extrinsic annoy- rather than simply if it causes annoyance (though this ance will increase in inverse proportion to the perceived particular point does not seem to be acknowledged any- necessity of the noise. Ultimately, ‘chronic exposure can where in the literature), changing the definition from .. .. increase the risk of hypertension, arteriosclerosis, being subjective to having some degree of objectivity. and .. . severe events, such as myocardial infarction The person who has a high noise threshold might even and stroke .. . [with] higher prevalence and incidence be hearing noise at very harmful levels without being of cardiovascular diseases and mortality in highly noise- bothered or annoyed by it; such a person is thus more exposed groups’ (Basner et al., 2014). likely to be unaware that noise he or she is generating— In addition, while noise can disturb sleep by waking whether high or relatively levels—might be annoying for people up, it can also cause disturbance without the per- others. son being aware of it: ‘Human beings perceive, evaluate, The idea that sound can be noise without being and react to environmental sounds, even while asleep .. . annoying has obvious implications for noisy autonomy. Short-term effects of noise-induced sleep disturbance What if a person is aware of sound that does not pass her include impaired mood, subjectively and objectively threshold of auditory disturbance, and she thus does not increased daytime sleepiness, and impaired cognitive regard as noise, while also unaware that those sounds are performance’ (Basner et al., 2014). Thus noise can actu- harming her? According to this person, this is not noise, ally harm people in four distinct ways: (i) it can cause but according to the medical literature, it is—at least in hearing loss (the auditory effect); (ii) it can cause stress the non-auditory sense of sound that causes harm. As and distress via annoyance; and (iii) it causes non- such, it is simultaneously a non-annoying noise (or ra- conscious physiological harm through (e.g.) heart dam- ther, sound, by the old definition), and a non-auditory age caused both by the (conscious) stress and (iv) via noise—so it is noise despite not being noise in at least direct non-conscious physiological effects on the body. two senses. Note that there can be overlap between these categories; Of course, if someone were to tell me about the non- some people may not be annoyed by a particular loud auditory harms to which I am exposed, I might well re- sound (and might not class it as noise in the traditional gard them (the sounds, not the person) as annoying, sense) but might nonetheless be physiologically harmed which could in turn lower my threshold for annoyance by it. Thus noise can be noise without being perceived at at hearing the auditory signals associated with the non- all, but also while being perceived but without being auditory harms. Ironically, of course, learning about the perceived as annoying. Table 1 summarizes these cate- potential harms could in turn increase my stress levels in gories of noise and their harmful effects. two ways; by making me worry about the non-auditory Table 1. Categories of noise and their harmful effects Nature of noise Effect of noise Perceived as noise Noise (perceived yet Non-perceived Hearing about harms of (annoying) not annoying) noise non-perceived noise Hearing loss (auditory) If sufficiently loud Possible (e.g., No No loud music) Stress and distress (indirect) Yes No No Yes Physiological harm (direct) Yes Yes Yes Yes (via stress) NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 291 effects of noise and by increasing (or creating) the stress what everyone else is doing there, and because that is associated with the sounds in question when I experience what motorways are designed for. Generally speaking, them; before, they did not annoy me, and now they may. hillsides are designated as natural spaces, which imply a However, while it might increase rather than decrease certain degree of peace and quiet. The context of noise harms done to me, telling me about the non-auditory also relates to how disruptive it is to activity; if I am doing effects of noise does increase my range of future options the dishes or working in a noisy kitchen or even watching for autonomous choice by educating me about a harm a loud film, someone turning on a lawnmower two gar- that I was not aware of, even if I am not currently able to dens away will hardly register, whereas if I was having exercise my autonomy in any way that can prevent that lunch in the garden enjoying birds singing, the effect harm from affecting me. However, I can then act in such would be quite different. as way as to limit my own noisemaking activity to pre- Another important contextual feature is the reason for vent others from these newly recognized (and other) making noise, and whether that reason is reasonable. harms. Having set the scientific scene, we can now Voice suggests four requirements for his ‘Test of move on to a closer consideration of the ethics of noise. Reasonable Noise’: The noisy practice is connected with a reasonable comprehensive doctrine. The Ethics of Noise The practice is part of the history and traditions of Noise clearly causes vast amounts of harm to millions if that doctrine. not billions of people. Often the term ‘noise pollution’ is The practice is essential to the activity (as judged used to reflect the harm that it causes (paradoxical as any from within the perspective of that doctrine). noise is by definition pollution; a more accurate term might be sonic pollution). Yet sometimes noise is neces- The reasonableness of the practitioners is evident sary. Even Schopenhauer, who detested noise, acknowl- in attempts to meet the concerns of other citizens. (Voice, 2009) edged that a case can be made for justifiable noise: Hammering, the barking of dogs, and the scream- Thus, someone might have a good reason for playing ing of children are abominable; but it is only the music outdoors as part of a music festival, but not for cracking of a whip that is the true murderer of listening to loud music without earphones in the quiet thought. Its object is to destroy every favourable carriage of a train. Music festivals have a long tradition, moment that one now and then may have for re- and the noise is to some degree necessary; in contrast, flection. If there were no other means of urging on listening to music on a speaker instead of earphones in a an animal than by making this most disgraceful of all noises, one would forgive its existence. But it is place that is meant to be quiet is unnecessary and hence quite the contrary: this cursed cracking of whips is unreasonable. not only unnecessary but even useless. However, the aforementioned non-conscious nature (Schopenhauer, 1851) of some harms caused by noise raises some problems for this account. Voice (2009) states that ‘Obviously, no Schopenhauer might have been happier in Ancient sound is noise without someone hearing it as noise’ Rome, where a law was once implemented that prohib- but as stated above, the evidence shows that unperceived ited coppersmiths on any streets where professors lived. sound can harm in a way that is unwanted, and as such Fortunately, whips are only rarely heard nowadays, but constitutes noise. Thus, even if people are not woken by we have plenty of newer alternative sources of noise, cars, church bells being rung late at night, their sleep can still planes and mobile phones among them. In this section, I be disturbed, with harmful physiological effects. This consider several different sources of noise and their jus- also applies to people who are awake; they might not tifiability in order to assess their ethical status. be annoyed by background noise that nonetheless has The start of our first lockdown was made easier by the a negative effect on their well-being. Non-conscious fantastic spring weather, but it was difficult to enjoy the garden because someone always seemed to be mowing effects could and should be factored into any test of rea- sonable noise, tipping the balance more towards noise their lawn. In considering different examples of noise and their associated effects on persons’ autonomy and being unreasonable because of probable yet generally well-being, we should of course be mindful of context. unquantifiable health effects. One person generating lots of noise on a silent hillside is Another issue affecting Voice’s test is that it is not worse than dozens driving on the motorway, partially obvious why history and tradition should be considered because each person on the motorway is simply doing relevant countervailing factors to be weighed against 292 SHAW public health harms. The fact that a noisy activity has a Droning on: Two Noisy Cases long history is irrelevant if it causes harm to people’s Now let us turn to some cases to consider noisy auton- health and well-being now. Furthermore, a practice omy in practice. Given the importance of context to our could be essential to an activity without being noisy. assessment of the justifiability of noise, it is not surpris- Any evident reasonableness on the part of the practi- ing that a great deal of annoyance can result when new tioners would include attempting to find non-noisy sources of noise are introduced into a novel context. Two ways of achieving the goal achieved by the noisy practice. similar examples are the introduction of jetskis and If they refuse to attempt to do so, they are not being rea- speedboats to a countryside loch, and the use of drones sonable. So if Voice’s test is actually unreasonable, par- up a mountain. Loch Lomond is Scotland’s largest loch ticularly given the medical evidence of harm from by surface area and has been a haven for those seeking auditory, non-auditory and non-conscious noise, what nature and beauty for over a hundred years. It also lies should the criteria be for reasonable noise? In other words, only half an hour’s drive from Glasgow, and the south- what constraints should there be upon our noisy west shores have been subject to a degree of commercial- autonomy? ization. In the early 2000s, there was intense debate Respecting other people’s noisy autonomy—which around the use of the loch by water-skiers, jet-skiers includes not only the freedom to make noise but the free- and motorboats. One correspondent to the Glasgow dom to be free of it if one so wishes—cannot consist sim- Herald wrote that ‘The emphasis seems to have slipped ply in avoiding making noise that one would find towards simply banning jet skis, which, while desirable, annoying. There are several reasons for this. As already only addresses part of the speed problems. Water skiing mentioned, perceptions of noise are subjective, and what is just as noisy, just as damaging to the enjoyment of might not seem like noise to you might be very noisy to every other person either using the loch or its surround- me. This could be because you have a high noise threshold ings and just as dangerous to the health of both wildlife and I have a low one. Complicating the picture further is and humans .. . The noise is incredible’ (Morrisson, the fact that you might have a good reason for making the 2004). However, those who use powered transport on the loch derive great enjoyment from doing so; so could noise, but I do not know what that reason is, potentially the generation of this noise be considered as reasonable? resulting in a situation where you are making sound that The use of engines on the surface of a loch that is the you do not regard as a noise, for a good reason, but to me centrepoint of a national park is perhaps the classic ex- it seems like loud noise for no good reason. We also know ample of conflict between people exercising their noisy that noise can harm without being perceived by any autonomy in particular ways that may be mutually in- involved party as noise, but that is difficult to consider compatible. The walkers, yachters, climbers and picnick- in such deliberations; perhaps, we simply have an add- ers would prefer to have peace, quiet and tranquillity; the itional weak obligation to avoid making noise because of powerboaters and jet-skiers want to do as their names the non-auditory unperceived harms it can do to others. suggest. Is it fair to them to ban such activity because it Noisy autonomy can also be illuminated by consider- disturbs the majority of visitors to Loch Lomond? The ing the scale of the potential harm that can be generated nature of noise puts noisy loch users at a substantial very easily; indeed, it is all too easy to make noise and disadvantage in terms of reasonableness. It only takes very difficult to avoid it. One person can engage in ac- one speedboat with one person on it going up the loch tivity that causes noise to be heard by hundreds, or even at 50 miles an hour to shatter the peace and quiet for thousands (e.g., a loud car driven at speed at night). miles in each direction, violating the negative liberty of Some people will not notice the noise at all, but could those using the loch for quieter pursuits. In terms of still be affected by it if it causes physiological damage. relational autonomy, this could also be seen as dominat- Others will notice the noise, but not mind it, even if it ing ‘quiet’ loch users by denying them the ability to ex- causing such damage, making it sound rather than noise ercise their noisy autonomy; one can only exercise one’s according to the old definition. Others will be annoyed freedom in this sense if one is not dominated by others by the noise and label it as noise in the classic sense. (Of (Wenner, 2020). The disutility of even one boat being course, noise is also relevant during the current Covid- used this way in terms of the annoyance and potential 19 pandemic; some countries have banned music in pubs stress to other loch(side) users is out of all proportion to because the noisier the environment (BBC, 2020), the any potential enjoyment of those on the boat. For some more likely it is that people will raise their voices and walkers and other people around the loch, this noise increase the risk and range of viral spread.) might merely be offensive; but for others, it could NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 293 actually do harm. The aforementioned point about an- the Isle of Skye, my family and I climbed up to the Old noyance stemming not only from the noise itself but Man of Storr, a famous natural pinnacle about 500 from distress at the disruption of another activity is par- metres above sea level that sits below even bigger cliffs. ticularly relevant here. The medical evidence also shows At one point, I heard a loud buzzing sound and warned that time spent in natural settings is beneficial for health the kids to look out for wasps, before realizing that the and well-being. If that time is disrupted by man-made sound was coming from high above our heads: it was a noise, not only is stress and annoyance caused because of drone. On realizing this, the sound was instantly trans- that noise; the opportunity to exercise freedom in attain- formed into a noise. Note that this was not because it was ing that benefit is also compromised. Thus noise can not hugely loud; rather, we had been enjoying the spectacu- only spoil fun and harm health; it can also prevent health lar views and the peace and quiet; now, the tranquillity benefits being achieved. (One might term this noise’s was disturbed by the drone and we also had to keep an double effect; it harms health and also prevents health eye on it to make sure it was not going to fall on us (if it being improved through relaxation.) In such circum- had been a wasp, I would not have categorized it as noise stances, the term ‘offensive’ is insufficient; harm can re- as we could easily have moved out of range of the sound sult both from irritation at the sound itself and from the and the sting; a drone is different). Its user was not ob- prevention of peaceful activity in the vicinity of the loch. viously in sight, although we could see several few people Ironically, however, if there are 10 boats, the increase quite far away (as the Storr is a popular site). Had I seen in disutility for ‘quiet’ loch users compared with one the operator, I would have asked him to turn the drone boat is so marginal that it becomes easier to make a off. Would that have been proportionate? The drone case for power-boating as a permissible practice. The may have been being used to film or take photographs difference between (near-) silence and one boat is mas- rather than ‘just for fun’, but the sound would have been sive; the difference between one and 10 is almost insig- audible to dozens of other people, many of whom were nificant by comparison. And of course, the competing presumably annoyed as well. The noisy whirr of the utility of boat users is substantially increased for each drones’ rotors entirely changed the environment of the extra boat on the water. Recognizing that a complete Storr, and preventing us from exercising our autonomy ban on vessels with engines on the loch would be dispro- as we wished to. portionate, the National Park introduced byelaws to Again, this might be deemed offensive rather than regulate noise and other disturbance; all such vessels harmful, but the drone was certainly creating noise pol- ‘shall be fitted with a silencer expansion chamber or lution that harmed the environment and our experience other contrivance suitable and sufficient to prevent the of it; the operator may have been unaware of this, but occurrence of noise amounting to a Nuisance caused by that in turn suggests something of a lack of consider- the escape of the exhaust gases from the engine’ ation, or that he was operating it from too great a dis- (LLTNPA, 2013). Furthermore, though the maximum tance. I return to the issue of the threshold for harmful speed in the centre of the loch is 90 kilometres per hour, noise in the next section. in all areas within the designated zones on the west, south In fact, as I found out once I was back in the office, this and east of the parts of the loch most frequented by drone operator was not following best practice and also walkers and other nature lovers (including swimmers) breaking the law as reflected in the Civil Aviation the limit is 11 kilometres per hour—i.e., much quieter. Authority’s ‘Drone Code’ (UKCAA, 2019). The drone While many lovers of tranquillity would prefer an out- was directly over our heads for several minutes despite right ban on vessels with engines, this solution seems the law stating that drones should be at least 50 metres proportionate and ensures that different groups of citi- away (horizontally) from any people other than the op- zens can access the loch in a reasonable way, while erator. Note, however, that while these legal stipulations respecting one another’s autonomy. (While this example mean that the drone should not have been flown over might not seem relevant in terms of non-conscious our heads or up at the Storr, they do not say anything noise, it is entirely possible that residents living around about the level of noise emitted by a drone. Had the Loch Lomond do not mind the sound of powerboats, yet drone kept away from us, the law would have been sat- are subconsciously harmed by it, or even if it annoys isfied, but we would not have been, as we would still have them while they are awake do not realize that it is dis- heard the drone at almost the same volume. The Code rupting their sleep and thus harming them.) A more recent development is the introduction of stipulates that all drone operators must pass a test and drones into natural settings. On holiday recently on register as users, but says nothing whatsoever about 294 SHAW noise. In contrast, a best practice guide for drone users in unannoying, but remains annoying sound according to the traditional definition of noise.) Scotland states the following: The question of whether noise annoyance is offensive Drones are noisy bits of kit and the last thing or actually harmful is highly context-dependent. As people want when out enjoying the tranquil Passchier-Vermeer and Passchier (2000) put it: ‘Noise sounds of Scotland’s nature is a drone buzzing annoyance is a feeling of resentment, displeasure, dis- around their heads. Have respect for other users of the countryside, don’t just throw your drone comfort, dissatisfaction, or offense when noise interferes up next to a group of walkers, it’s disrespectful with someone’s thoughts, feelings or actual activities. It and inconsiderate. If you are desperate to catch is not yet possible to predict noise annoyance on an in- that shot and there are people around, it is good dividual basis because of the large variety of (partly un- practice to ask any other users, walkers, climbers, known) endogenous and exogenous characteristics that bikers, etc. for permission. (Houston, 2020) affect annoyance’. Further complicating these factors are (Note the assumption that the drone is being used for a three others; annoyance also relates to a given person’s anxiety, any fear of the noise source, and whether the specific purpose.) This respectful guidance puts the rea- noise was perceived as avoidable. The same authors sonableness test in the hands of those affected by the found that taking air, road and rail noise at a level of drone’s noise: the choice is left to those affected by the 70 decibels, around 15 per cent found the rail noise noise. In effect, it is up to them to decide whether it is annoying, 25 per cent found the road noise annoying noise, and whether that noise is reasonable. However, in and over 40 per cent found the plane noise annoying many parts of Scotland people could be affected by the (Passchier-Vermeer and Passchier, 2000). In other noise of a drone without being seen by the operator, words, and unsurprisingly, whether a noise is annoying which raises issues not only around noise but also depends not only on the person experiencing it but also around safety; the law states that operators must always on its source. Nonetheless, if noise causes discomfort or keep the drone in sight, but not that they must ensure distress, then it is probably reasonable to categorize it as they can see anyone who could be within 50 metres range harmful. In the case of the Drone, I was indeed distressed of it—a paradox given the requirement to ensure a drone because I had sought a quiet retreat from technology, should be kept within 50 metres range. In terms of and the noise did cause discomfort; the fact that the noise respecting others’ noisy autonomy, those generating was certainly avoidable also played a role. In the case of noise have a responsibility to ensure that they are at least the loch, where mitigations and noise restrictions are in close enough to accurately gauge the potential for caus- place, it seems more likely that noise will merely cause ing annoyance to others. offence. But ultimately, in any scenario where noise causes annoyance or offence, it can cause stress, and stress can harm in a variety of ways: ‘psychologic (feel- Noisy Autonomy, Harm and Justice ings of fear, depression, sorrow), behavioral (social iso- The drone and loch examples both feature noise in rec- lation, aggression, excessive use of alcohol, tobacco, reational scenarios, and for a more detailed exploration food, drugs), and somatic (cardiovascular, gastrointes- of how noisy autonomy relates to harm and justice, tinal, respiratory illnesses)’ (Passchier-Vermeer and returning to urban examples of noise will be helpful. Passchier, 2000). Before proceeding, however, we should return to the There are clearly borderline cases where the margin issue of whether and when noise is harmful as opposed between offence and harm is slim but as explained in the to merely offensive. Harms of Noise section and associated table, noise can In the UK, noise is defined as anti-social if it causes clearly harm people in four ways: it can cause hearing loss ‘nuisance and annoyance’ (CAB, 2018). Nuisance and an- (auditory effect); it can cause stress via annoyance (see noyance suggest that noise is offensive rather than harm- previous paragraph); and it can cause non-conscious ful, but at the same time ‘anti-social’ suggests a certain physiological harm via conscious stress that harms the degree of harm. Of course, anti-social noise regulations body and via direct non-conscious effects on the body. and laws normally concern disputes between neighbours, Many people are exposed to these harms because they but they can also be applied more widely. (This definition live close to major sources of noise such as railway lines, of anti-social noise is interesting in light of the traditional major roads and motorways. If they regard this noise as definition of noise as any annoying sound. In effect, the annoying, they risk some serious health harms, includ- UK definition creates a category of annoying sounds that ing stroke and heart attack, according to Basner et al. (see are not annoying; noise that is not anti-social is deemed Introduction section). But of course, they might find this NOISY AUTONOMY: THE ETHICS OF AUDIBLE AND SILENT NOISE 295 noise annoying at first, but become used to it over time. Policy and Personal Implications of As already explained, however, the fact that they no lon- Noisy Autonomy ger find the noise annoying does not mean that it is not harming them; as Basner et al. state, even noise experienced The drone example illustrates both how noise is often when asleep,suchasloudtraffic,can impair mood,increase neglected by legislation on new technology, and how this sleepiness and reduce cognitive performance. fact requires the adoption of good practice by operators All of these harms are associated with noise pollution, of that technology. In this case, the autonomy of other and laws exist to regulate industrial and domestic pro- people is respected by reliance on reasonableness and a duction of noise. But in terms of noisy autonomy, if respectful approach being adopted by potential noise- individuals are to exercise self-determination with re- makers. But how should regulators and society as a gard to how noise affects them and others—in other whole approach the challenging issue of dealing with words, in order to exercise relational autonomy mean- non-conscious noise, which can harm people without ingfully—it is imperative that people know that unper- them being aware of it? ceived noise can be harmful. Ideally, legislators would take much greater account of Yet the nature of this harmful yet not annoying noise the harms caused by non-auditory noise. As suggested has another problematic feature; if we seek to maximize above, any discussion about the proportionality and rea- citizens’ noisy autonomy by telling them that the noise sonableness of noise generation should consider not that they now no longer regard as annoying is nonethe- only the potential for annoyance and distress but also less harming them, we risk increasing the overall harm to the physiological non-auditory and non-conscious which they are exposed by increasing the risk that they harms. For example, if science shows that drone use at will worry about the noise, and also run the risk of mak- night disrupts people’s sleep patterns (even without ing that noise annoying again for that very reason. Yet them knowing it), that would be evidence in favour of even without considering the importance of information a prohibition on such use—though not necessarily con- for self-determination, if we regard harms such as the clusive evidence. Similarly, it seems plausible that peo- potentially avoidable cognitive impairment of children ple’s enjoyment of outdoor spaces might be at least as important, such risks of increasing harm must be marginally compromised by background noise that deemed reasonable and necessary. I return to this issue remains subconscious; I might notice a drone when in the following section, but another issue that compli- someone else doesn’t, but it could still be affecting cates this already-complex aural landscape is that even if them regardless. told about these harms, some people might be unable to Legislators should also take our noisy autonomy ser- relocate to somewhere quieter due to economic con- iously. Generally, if there is a known threat to public straints; most noise burden is borne by those who live health, the public are informed about it, and there is in noisy city centres, not those in quiet leafy suburbs. In no obvious reason why that should not be the case addition, lower-paid workers are more likely to have jobs here. Indeed, the very idea that noise can be harmful that put their hearing at risk, and over 1 million people in without being perceived is one that the public should the UK are exposed to levels of noise that put their hear- be informed about, as it would increase their autonomy ing at risk at work (in addition to the increased risk of to have this information; different life choices might be harm from other causes due to high noise levels, such as made if people knew about all these additional potential not hearing warnings) (IOSH, 2021). This phenom- harms of noise. Furthermore, if people should indeed be enon—which I term ‘sonoeconomic inequality’— informed about the potential negative effects of non- means in turn that the noisy autonomy of those living conscious noise upon their health, they should probably in noisier areas is subject to greater constraints than also be told about the non-auditory effects on their car- those living elsewhere—another challenge for health diovascular system of getting annoyed about noise— justice. The effects of noise on children living in urban paradoxically, even if this will increase their risk of areas are even more of a pressing concern for two rea- such harm, because they will be both more likely to get sons: they are a vulnerable population subject to greater annoyed by noise, and more likely to get stressed protections, and some of the harms of urban noise affect through worry about those effects. Finally, the serious children more than adults in terms of years of life with health justice issues raised by noisy autonomy also war- reduced quality of life (Passchier-Vermeer and rant careful consideration by public health bodies and Passchier, 2000). legislators. 296 SHAW Enhancing citizen’s autonomy by informing them noise reduces the incidence of noise, it will also tend to about all the potential ill effects of noise could also reduce the infringement of others’ autonomy through have the effect of reducing the amount of noise. If people bothersome generation of unnecessary noise. are aware of and even worried about the effects of noise Noise is important for our autonomy, and autonomy on health, they are likely to be more considerate in terms is important for noise. We have rights and responsibil- of generating sound—hopefully reducing the frequency ities regarding noise, and thus we must consider noise (no pun intended) with which sound crosses the thresh- not only in terms of individual autonomy but also rela- old into noise. Thus, maximizing noisy autonomy by tional autonomy. The phenomenon of unperceived yet informing everyone about the auditory, non-auditory harmful noise further complicates the picture. I hope to and non-conscious effects of noise is likely to increase have convinced the reader of three key claims. First, those effects in the short term (by making people more while we all have a certain degree of autonomy in making aware of noise and hence at least temporarily more sound, generating noise can infringe autonomy in many harmed via stress response and distress), while also being ways. Second, the traditional definition is wrong: (non- likely to lessen the incidence of noise in the medium to conscious) noise can be noise without being noticed, or longer term through increased noise conscientiousness. even without being heard, because people would regard Of course, maximizing the public health benefit by it as troublesome if they knew of the harm that such reducing noise is not the only advantage; in addition, sounds can do. And finally, governments and public it is good to maximize people’s capacity for exercising health authorities have a duty to maximize people’s au- their autonomy in ways that also do not infringe the tonomy by not only attempting to reduce both non- autonomy of others. In other words, by informing peo- conscious and other non-auditory noise (as well as noise ple about the complex nature of noisy autonomy—or at that could damage hearing) but also by educating them least making them aware of the potential for causing about the potential harms of noise and sounds that do perceived and unperceived harm in this regard—they not yet pass their personal noise threshold. This is the will be able both to act more autonomously and to re- case even if, in so doing, we turn sounds that were not spect others’ autonomy to a greater extent. (Again, given heard into silent yet recognized noise, and thus increase our obligations regarding noise and the harms it can the harms that we were initially warning about. While cause others, a relational rather than individualistic ac- this might seem counter-productive, doing so both max- count of autonomy is appropriate when considering the imizes our noisy autonomy and will also hopefully re- public health ethics of noise.) One constraint on their duce all sorts of noisemaking in society. ability to act more autonomously, of course, is the issue of sonoeconomic inequality mentioned above; some citizens are more able than others to act against or Conflict of Interest move away from noisy neighbourhoods. None declared. Conclusion References In some apartments in Switzerland, men are forbidden Basner, M., Babisch, W., Davis, A., Brink, M., Clark, C., to urinate while standing during the night. This might Janssen, S., and Stansfeld, S. (2014). Auditory and seem like a bizarre rule that infringes men’s autonomy in Non-Auditory Effects of Noise on Health. Lancet, an unacceptable way. However, this gets things precisely 383, 1325–1332. the wrong way around. It is not banned because of wor- Baylis, F., Kenny, N. P., and Sherwin, S. (2008). A ries that they would do so in the dark and miss the bowl, Relational Account of Public Health Ethics. 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Public Health Ethics – Oxford University Press

Published: Oct 29, 2021

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