29. 6. 81 Official Journal of the European Communities No C 159/1 
II 
(Preparatory Acts) 
ECONOMIC AND SOCIAL COMMITTEE 
Opinion on the proposal for a Council Directive laying down basic standards for the health 
protection of workers and the general public against the dangers of microwave 
radiation 
The text referred to the Committee has been published in Official Journal of the 
European Communities No C 249 of 26 September 1980, page 6. 
A. LEGAL BASIS FOR THE OPINION 
On 8 July 1980 the Council referred the abovementioned proposal to the Economic and 
Social Committee in accordance with Article 198 of the Treaty establishing the 
European Economic Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
186th plenary session held in Brussels on 25 and 26 March 1981. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the 
European Economic Community, and in particular 
Article 198 thereof, 
Having regard to the request made by the Council of 
the European Communities on 8 July 1980 for an 
opinion on the proposal for a Council Directive 
laying down basic standards for the health protection 
of workers and the general public against the dangers 
of microwave radiation, Having regard to the decision taken by its Bureau on 
2 July 1980 instructing the Section for Social 
Questions to draw up an opinion on this matter, 
Having regard to the opinion adopted by the 
abovementioned Section at its meeting on 
12 March, 
Having regard to the oral report made by the 
Rapporteur, Mr von der Decken, 
NoC 159/2 Official Journal of the European Communities 29. 6. 81 
Having regard to the discussions at its 186th plenary 
session on 25 and 26 March 1981 (meeting of 
25 March 1981), 
Whereas in several opinions already the Committee 
has called for the rules and standards for protection 
against ionizing radiation to be followed up by rules 
and standards for protection against non-ionizing 
radiation, 
Whereas the ever-increasing use of microwaves in 
many spheres of life makes it necessary to draw up 
appropriate rules and standards to ensure that people 
are protected, 
HAD ADOPTED THE FOLLOWING OPINION 
unanimously: 
General comments 
1. The Economic and Social Committee is very 
pleased to note that in submitting this draft Directive 
on the dangers of microwave radiation the 
Commission has acted on the various suggestions 
and requests made by, among others, the Committee 
itself and followed up its rules and standards for 
protection against ionizing radiation with proposals 
for non-ionizing radiation (l). 
2. The Committee is aware that microwaves 
represent only one form of non-ionizing radiation 
and expects the Commission to turn its attention 
soon to the other types, such as UV rays and laser 
beams. 
3. The use of microwaves, i.e. electromagnetic 
waves at specific frequencies, has become very 
important in many spheres and is constantly 
increasing. 
4. Microwaves can be harmful to the human body. 
The increasing use of such radiation makes it 
necessary to draw up appropriate rules and standards 
to ensure that people are protected. 
(') Opinion of the Economic and Social Committee on the 
proposal for a Council Directive (Euratom) laying down 
the basic safety standards for the protection of the health 
of workers and the general public against the dangers 
arising from ionizing radiation (CES 439/73 — 24 May 
1973, page 5: 'Furthermore, the Committee hopes that 
the good results on radiological protection recorded so 
far within the Community can be developed and applied 
in other areas of environmental protection.' 5. Furthermore, by introducing common rules and 
standards throughout the European Community 
barriers to trade can be avoided. 
6. The known and generally acknowledged harmful 
effect of microwaves on the human body stems from 
a possible rise in body temperature if the microwaves 
heat the body to such an extent that the body's own 
temperature regulation system can no longer 
maintain a constant temperature. 
7. Damage to the lens of the eye is also possible. 
The lens of the eye is not supplied with blood. Heat 
generated in the lens by microwaves is therefore 
dissipated extremely slowly, which may lead fairly 
rapidly to an overheating and subsequent clouding of 
the lens (cataract, grey cataract). The lens must be 
regarded as a vital organ. 
8. For both types of damage it is possible to set 
radiation limits below which there is no possibility of 
any harm being done. 
9. There is as yet no scientific proof of other 
harmful effects induced by substantially smaller 
doses of radiation and not deriving from the effect of 
heat. These non-thermal effects are, however, 
disputed. Eastern European countries in particular 
claim to have observed such effects, although these 
have not been definitely confirmed as yet. 
10. Three types of use must be distinguished: 
— closed systems, 
— open systems, and 
— medical applications. 
11. In the closed systems substances are subjected 
to heat treatment. Through the radiation these 
substances are dried, cooked, thawed, etc. In 
principle other sources of heat could be used, but 
microwaves are better, cheaper or quicker. The 
appliances used are generally completely enclosed. 
There is no danger to users as long as the appliance's 
safety arrangements remain intact. 
12. In the open systems microwaves are used, as 
with radar equipment, for communication, range-
finding, targeting, etc. The microwaves are therefore 
emitted outwards from the system. As fairly large 
areas are affected by this, the problem is to protect 
the general public as well as the operating 
personnel. 
29.6. 81 Official Journal of the European Communities No C 159/3 
13. The medical application of microwave 
radiation involves the warming of specific parts of 
the body for therapeutic purposes. This again raises 
the problem of protection at work, in this case for the 
doctor and medical technicians. It must also be 
ensured that the patient is protected from excessive 
doses of radiation. The Committee considers that the 
protection of patients as well as workers must be 
considered, either in this Directive or as soon as 
possible in a new Directive. 
Specific comments on the draft Directive 
Article 1 
14. The term 'controlled area' is specific to ionizing 
radiation and its definition not appropriate to the 
problem of microwaves. To avoid confusion another 
term should be used. 
15. The frequencies belong in the section on the 
Directive's scope (Article 2), not under the 
definitions. This is important because 
electromagnetic waves with frequencies below 300 
MHz (300 MHz = 300 million oscillations per 
second) are also microwaves but are not to be 
covered by this Directive. As microwaves with a 
frequency below 300 MHz may also have harmful 
effects, the Committee expects the Commission to 
submit soon a draft Directive on this frequency range 
too. 
16. The various language versions of the other 
terms require rechecking by experts. 
Article 2 
17. The Committee considers that the Directive 
should also deal with the exposure of patients. If, 
however, the Commission would prefer to deal with 
this question in a separate Directive, Article 2 must 
state explicitly that medical apparatus and the 
protection of occupationally exposed medical staff 
fall expressly within the ambit of this Directive. 
Article 3 
18. The Committee is of the opinion that all limits 
should be given in Article 3 and not, as in the draft, 
partly in an Annex. 
19. Regarding the actual limits, the Committee 
would ask the Commission to follow closely the 
relevant current research projects, e.g. those of the World Health Organization, and to examine in each 
case whether their findings would seem to require or 
justify a reduction in the EEC limits. 
20. As our knowledge in this field is extremely 
fragmentary and there are no national research 
projects in the Community, the Committee considers 
that the Commission should initiate a suitable 
research programme. Suitable funds should also be 
made available. In order to provide such a research 
programme with an information base, the Committee 
proposes that this Directive include an obligation to 
supply information on the effects of any exposure to 
microwave radiation which has damaged health. 
Articles 4, 5 and 8 
21. The Committee thinks that the Directive would 
be clearer if Articles 4, 5 (1) and 8 were condensed as 
follows: 
'Work involving exposure to microwave radiation 
shall be carried out under competent medical 
supervision or after medical authorization if it is 
planned to exceed the exposure limits laid down in 
Article 3, or if the work takes place under special 
environmental conditions which will subject the 
body to other stresses, e.g. high temperature, in 
addition to the microwave radiation. If necessary 
the limits laid down in Article 3 must be reduced 
accordingly.' 
22. Article 5.2 requires some rewording. The 
following revised and expanded version is 
proposed: 
'If work must be carried out in radiation fields 
consisting of continuous waves with energy 
fluence rates over 1 000 Wm~2 (100 mW/cm—2) or 
an equivalent pulse radiation, the exposure of the 
persons concerned must be reduced accordingly 
by protective clothing or other equipment and 
measures. The protective clothing, safety 
equipment and measures shall be tested 
periodically.' 
Article 6 
23. The control procedures must be defined more 
closely, since otherwise the text could be interpreted 
as meaning that the displaying of the appropriate 
warning sign referred to in Article 7 is regarded as 
sufficient. 
24. It should also be examined whether under this 
definition every room in a doctor's surgery which 
contains microwave therapy apparatus would not 
No C 159/4 Official Journal of the European Communities 29. 6. 81 
have to be declared a controlled area and what the 
consequences of this would be for doctors and 
patients. 
25. The last sentence in the third paragraph should 
therefore be reworded as follows: 
'The controlled area shall be demarcated by the 
operator responsible for safety.' 
Article 7 
26. If this Article is not to be incorporated into 
Article 6, which would be the best solution, then it 
must read as follows: 
'Appropriate warnings must be placed at the 
entrances to the danger areas.' 
The standardization of warning signs should be 
speeded up. 
Article 10 
27. The protection of the general public should not 
be dealt with under Title IV, 'operational protection', 
but, if the division into Titles is retained, under a 
separate Title. 
28. There are two types of problem involved in the 
protection of the general public: 
— possible exposure resulting from, in particular, 
the accumulation of radiation emitted by several 
open systems; 
— possible exposure of non-occupationally exposed 
persons to radiation emitted by closed 
apparatus. 
The first point is not dealt with at all in Article 10. 
The Committee urges that appropriate provisions be 
incorporated in the Directive. 
The second point can best be dealt with through 
design or type approval regulations (see comments 
on Article 11). 
Article 11 
29. The aim of this Article is basically to protect the 
non-professional, e.g. the housewife, who uses a 
Done at Brussels, 25 March 1981. microwave system. Therefore it concerns closed 
systems. The Committee feels that the most effective 
way of achieving this protection would be to ensure, 
by means of appropriate design or type approval 
tests (for which measurement rules should be issued 
on the lines of IEC publication 335—25), that 
emission values are low enough for the equipment to 
be used by the non-professional. These tests must 
include the safety arrangements intended to prevent 
accidental emissions. Such design or type approval 
tests must also apply to imported systems. 
30. Appropriate checks on the operation of safety 
arrangements can obviate the need for radiation 
measurement, even after a closed system has been in 
use for a relatively long time. 
Article 12 and 13 
31. The Committee considers that Articles 12 and 
13 should be combined in such a way that the general 
requirement comes first: 
'Member States shall take the measures necessary 
to comply with this Directive within one year of its 
notification.' 
This should be followed by the basic protection 
provisions in order of importance, for example: 
'In particular they shall take the measures 
necessary to ensure that the exposure limits are 
observed.' 
The text should end with: 
'Member States shall communicate to the 
Commission the provisions of national law which 
they adopt in the field governed by this 
Directive.' 
Concluding remark 
32. The Committee welcomes the fact that the 
Commission has decided to act against the dangers of 
microwaves. It considers that there are urgent 
practical grounds for implementing a suitable 
Directive as soon as possible. It is of the view, 
however, that the present Directive must be revised 
as quickly as possible, taking into account the 
comments made in this opinion. 
The Chairman 
of the Economic and Social Committee 
Tomas ROSEINGRAVE