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See id. (finding pollution leaves little trace on human bodies). 29. See D. Schwela et al., Confounding or Aggravating Factors in Noise-Induced Health Effects: Air Pollutants and Other Stressors, NOISE & HEALTH, July-Sept. 2005, at 41, 41-50 (discussing noise pollution and air pollution interaction which makes it difficult to assess only noise pollution effects). 30. See H.G. Leventhall, Low Frequency and Noise and Annoyance, NOISE & HEALTH, Apr.-June 2004, at 59, 59-60 (distinguishing those who have heightened sensory response from those who have low sensory responses to noise). 31. See id. (stating those with sensitivity to low-frequency sound can experience extreme distress from constant noise); see generally G. Belojevic et al., Noise and Mental Performance: Personality Attributes and Noise Sensitivity, NOISE & HEALTH, Oct.- Dec. 2003, at 77, 77-89 (explaining people with noise sensitivity struggle with mental performance). 32. See Leventhall, supra note 30, at 69 (expressing challenges detecting noise pollution). 33. See H. Ising et al., Low Frequency Noise and Stress: Bronchitis and Cortisol in Children Exposed Chronically to Traffic Noise and Exhaust Fumes, NOISE & HEALTH, Apr.-June 2004, at 21, 21-28 (noting high exposure to traffic noise at night can cause bronchitis in child). 2009] 5 Gillespie: The No Longer Silent Problem: Confronting Noise Pollution in the Published by Villanova University Charles Widger School of Law Digital Repository, 2009 186 VILLANOVA ENVIRONMENTAL LAW JouRNAL [Vol. XX: p. 181 Until recently, such difficulties resulted in a lack of international scientific agreement on the methodologies for estimating the forms of noise pollution and its impacts (for example, whether annoyance is actually a health issue). 34 Accordingly, pivotal international players, such as the World Health Organization (WHO), have recently begun to harmonize the research methodologies for noise pollution. 35 Current attempts to synchronize and solidify the research into international databases are highly desirable because they will lead to an easier and more effective method of forecasting the possible impact of policies and preventative actions on noise pollution.3 6 Yet, because substantive scientific debate remains in a number of areas, international, national and regional legislators should adopt a precautionary approach until a greater scientific consensus is reached regarding noise pollution. 

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