I have seen this addressed before on the DND-L (D&D list) and we have been on a lengthy discussion...
I started to use the idea of a listen check with -10 DC, reducing the penalty by 2 every round the noise continues... I think I would keep my rule, call of ctuhlu works for paranoid ambient, not for D&D stressed characters after a battle, maybe use the -5 for a dungeon or other very dangerous area, but the time without proper sleep or how much strenuous action was taken would modify...
No take tens, must roll, not consciously attent, and also would make it a full round, always did, you are awake, next round you act...