Jurisdiction(s):
United Kingdom
Related legal acts
Key definition
Noise definition

What does Noise mean? In transactional, finance and insurance practice, noise describes uncertainty or variability in outcomes that is not driven by investment market movements. It is a descriptive expression rather than a defined legal term in the UK or Ireland. Examples include an insurer’s uncertainty over the frequency, timing and severity of future claims on its book, or short-term, immaterial fluctuations in working capital or earnings unrelated to market prices. Lawyers refer to noise when allocating non-market risk in contracts, for example in pricing mechanisms, earn-out or working capital true-ups, financial covenants, material adverse change clauses, warranties and indemnities, and in regulatory...

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Template pre-action letter of claim to employer for noise-induced hearing loss, Annex E compliant, with particulars of breach and disclosure requests, England and Wales

Precedents
imgtext

Address
Your Ref:
Our Ref:
Please ask for:
Date:
Telephone:
Email:

Dear [ insert organisation name ]

Noise-induced hearing loss (NIHL) Letter of Claim Part A

We act for [ insert Claimant’s name ] regarding a Noise Induced Hearing Loss claim against [ insert Defendant’s name ]. This correspondence is issued under Annex E of the Pre-Action Protocol for Disease and Illness Claims. To assist the Defendant(s) with a full investigation, we enclose the following (please tick to confirm enclosed):

  • ELTO search(es)
  • HMRC
  • Completed questionnaire
  • Completed Part B for each proposed Defendant
  • Audiogram
  • GP and hospital records
  • Anticipated valuation
  • Provisional Schedule of Special Damages with supporting evidence
  • Personnel/Occupational Health file or the Claimant’s signed authority to obtain a copy from the insured
  • Declaration of previous claims

1 Claimant’s details

1.1 Full name:
1.2 Address:
1.3 Date of birth:
1.4 National Insurance number:
1.5 Solicitor’s reference:

2 Employment history

2.1 The outline below records our client’s complete work history in both noisy and non-noisy settings:

  • Defendant
  • Employer
  • Employment dates
  • Exposure to noise? (Yes/No)
  • Hearing protection? (Yes/No)
  • Pursued? (Yes/No)
  • Lead insurer details
  • FSCS interest?...
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Simon Ellis
Simon Ellis

Simon is a Partner with Hugh James and specialises in industrial disease cases. Simon assists clients suffering with a wide range of industrial diseases, including asbestos related illnesses, hearing loss, HAVS and work related cancers. He has extensive experience in this field and represents clients in both unitary claims and large group actions. Due to his experience and reputation Simon is often approached to deal with more unusual types of industrial disease. He has been at the forefront of seeking justice for clients suffering with less common industrial diseases and has been involved in a number of cases considered by the Court of Appeal. He regularly contributes articles and participates in media interviews for the press regarding industrial disease issues. Recent testimonials from Simon's clients include the...

Web page updated on 22/05/2026

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