No C 180/26 Official Journal of the European Communities 8. 7. 87 
3. On seeing such a list, and if the circumstances 
warrant it, the Commission, together with the appropri­
ate national authorities in the Member States, shall 
coordinate such measures. The Commission shall make 
any recommendations in this respect to the Member 
States. 
Article 12 
Each Member State shall provide the Commission with 
all information concerning the application of this Regu­
lation, in particular cases of non-compliance with the 
maximum permitted levels. 
The Commission shall communicate such information 
to the other Member States and shall regularly inform 
the Economic and Social Committee. 
1. General comments 
1.1. The Committee welcomes the fourth environ­
mental action programme and the draft Council resol­
ution on the continuation and implementation of the 
environment policy, bearing in mind: 
— the importance of protective and preventive 
environmental measures from the point of view of 
safeguarding the fundamental prerequisites of life 
and the quality of life of all of the Community's 
inhabitants, 
— the fact that environmental protection concerns all 
areas of life, specialist interests and responsibility 
and the fact that everyone both influences and ben­
efits from the environment. 
(!) OJ No C 70, 18. 3. 1987, p. 3. Article 13 
The arrangements for applying this Regulation and any 
amendments to be made to the list of minor foodstuffs 
contained in Annex II shall be adopted in accordance 
with the procedure provided for in Articles 5 and 6. 
Article 14 
This Regulation shall enter into force on the day follow­
ing its publication in the Official Journal of the Euro­
pean Communities. 
This Regulation shall be binding in its entirety and 
directly applicable in all Member States. 
In future the Community should determine standards 
for a progressive environmental policy; the Member 
States should be called upon to play their part in achiev­
ing this aim. 
1.2. The Committee supports the political objectives 
of the programme, in particular the intention to use the 
facilities and powers made available under the Single 
European Act and to take account, from 1992, of the 
common internal market in the formulation of environ­
mental policy. 
The Committee does, however, regret the failure of 
the programme to include a clear appraisal of the 
implementation of the earlier action programmes on 
the environment, in particular the third Community 
action programme. 
1.3. The projected further development and upward 
alignment of substantive European environmental law 
is welcomed. The Committee sees this as a step towards 
strengthening the principle of taking preventive action, 
a principle which : Opinion on the Council resolution on the continuation and implementation of a European 
Community policy and action programme on the environment (1987 to 1992) (*) 
(87/C 180/11) 
On 28 October 1986 the Council, acting under Article 198 of the EEC Treaty, asked the 
Economic and Social Committee for an Opinion on the following abovementioned draft 
document. 
The Committee instructed its Section for Protection of the Environment, Public Health and 
Consumer Affairs to prepare its work on the matter. The rapporteur was Mr. Boisseree. The 
Section adopted its Opinion on 23 April 1987. 
The Committee notes that the Council of Ministers at its meeting of 19/20 March 1987 
expressed its intention to take a further decision on the individual proposals contained in 
the fourth action programme on the environment once it has received the Opinions of the 
European Parliament and the Committee and the Commission's proposals. In view of this 
decision the Committee expects the following Opinion to have an impact on the Council of 
Ministers' discussion. 
The Committee adopted the following Opinion at its 246th plenary session (meeting of 
13 May 1987) by 81 votes to 42, with 17 abstentions: 
8. 7. 87 Official Journal of the European Communities No C 180/27 
— starts with measures to tackle the source of pol­
lution or damage, 
— brings existing older plants and products within the 
scope of the protective measures, 
— requires resources to be used sparingly and damage 
to the environment to be avoided, 
— also makes economic sense as preventive measures 
are generally less expensive than subsequent action 
to remedy environmental damage. 
In line with the principle of taking preventive action, 
environmental protection measures should be put into 
effect at an early stage, even though all scientific doubts 
have not yet been fully cleared up. 
1.4. The Committee supports the decision taken by 
the Council of Ministers on 24 November 1986 and calls 
for the action programme to concentrate on priority 
measures which can be implemented within the pro­
posed time scale and which because of their European-
wide dimension, can only satisfactorily be resolved at 
Community level. 
The Commission should therefore draw up a concen­
trated plan of action for the period 1987 to 1992 based 
on the comprehensive presentation contained in the 
fourth environmental action programme. The plan of 
action should include the following: 
— an accurate description of the current situation, 
referring to the provisions and Directives laid down 
by the Community and describing how they have 
been applied in the individual Member States; a list 
of the authorities and bodies responsible for the 
various aspects of environmental protection in the 
Member States; a summary of regional and local 
experience in particular problem areas, 
— a list and appraisal of the results of the earlier 
action programmes, in particular, the third action 
programme, 
— a survey of environmental problems which — 
especially because of their trans-frontier nature — 
are best tackled at Community level and of prob­
lems which it is thought should be dealt with at 
Member State level, 
— a timetable for the individual Community measures, 
an explanation of the criteria used in determining 
the order of priority for these measures and an 
assessment of their overall impact (including their 
impact on the financial contribution and staff ser­
vices to be provided by the Community). 
Without wishing to anticipate the decisions to be taken 
by the Commission, the Committee regards it as impor­
tant for the list of priority measures to include the 
following: 
— the monitoring and assessment of the already exist­
ing environmental protection provisions and the 
adjustment of these provisions to technical progress, 
taking account of the economic, social and employ­
ment impact, — the inclusion of the environmental protection factor 
in all relevant policy areas and Community financial 
instruments, 
— precautionary measures, involving non-Community 
countries, to protect the Community against large-
scale, international environmental pollution, e.g. the 
spread of sulphur and nitrogen compounds as a 
consequence of atmospheric pollution, 
— environmental protection measures in frontier 
regions (eg. in cases of discharges of heat or pol­
lutants into rivers running through several 
countries), brought about by promoting increased 
cooperation and participation on the part of those 
involved, 
— workers should be informed about environmental 
problems affecting businesses in order to enable 
them to participate in solving the problems. 
1.5. Bearing in mind the relevance of this environ­
mental programme to economic, social and employ­
ment policy, the Committee urges the Commission, in 
connection with the implementation of the programme, 
to involve employers' and workers' organizations and 
representative consumer and environmental group. The 
groundwork should be done at Community level for 
collaboration at national, regional and local level. 
2. Specific comments 
2.1. General policy orientations 
2.1.1. Amendments to the Treaty of Rome 
2.1.1.1. The Committee wants extensive use to be 
made of the powers set out in the Single European Act, 
in order to supplement Community environmental law. 
In order to make more rapid progress in the environ­
mental sector the Committee calls upon the Council of 
Ministers to make use of majority voting wherever 
possible (Article 100a and 130s of the EEC Treaty). 
2.1.1.2. The Committee welcomes the proposed 
measures for improving environmental reporting at 
Community level. It is important to concentrate on 
essentials. The quality of national and Community 
environmental provisions and the success of their 
implementation can most effectively be judged in terms 
of the effective progress of the environmental situation. 
Data on this matter should therefore be compiled on 
ah ongoing basis for publication in a 'Community state 
of the environment report' and the data should be 
regularly assessed. 
2.1.1.3. This would require an adequate number of 
permanently operating measuring stations recording the 
most significant damage to the environment at relevant 
places. To enable their findings to be assessed at Com­
munity level, it will be necessary to standardize the 
measuring procedures, assessment criteria and staff 
training. 
No C 180/28 Official Journal of the European Communities 8. 7. 87 
2.1.1.4. The Committee also supports the Com­
mission's intention to change the agreement on the 
provision of information into a binding Community 
instrument in order to improve its procedures for 
obtaining information about environmental measures 
planned by the Member States. The new powers pro­
vided for in the Single European Act impose a strict 
obligation to provide such information. 
2.1.1.5. In order to prevent Community standards 
from impeding the introduction of more advanced sol­
utions in individual Member States it may be necessary 
for particular reasons to lay down expressly that these 
standards are to be regarded as 'minimum standards' 
(Article 130t of the EEC Treaty, added under the Single 
European Act). 
2.1.2. Implementation of Community Direc­
tives 
2.1.2.1. The programme rightly draws attention to 
the incorporation of Community environmental law, 
particularly Community Directives, into the laws of the 
Member States. The Committee deplores the fact that 
a large number of the environmental Directives have 
not been incorporated at all or only partially incorpor­
ated. The Committee calls for a comprehensive stock­
taking of the situation (to include a survey of the 
infringement procedures instituted in this matter under 
Article 169 of the EEC Treaty) which should be made 
available to the public. In order to eliminate difficulties 
with regard to incorporation and subsequent implemen­
tation, more importance should be attached by the 
Commission (from the time it drafts proposals) and by 
the Council of Ministers (when adopting Directives) to 
the readiness with which provisions can be incorporated 
into national law and implemented by the Member 
States. 
2.1.2.2. The Committee agrees with the Commission 
that the effective implementation of the environmental 
legislation will be particularly important in the future. 
The Committee supports the Commission's proposals 
(a) for improving the flow of information between the 
Community and the Member States and between the 
Member States themselves and (b) for improving the 
publicity given to protection of the environment. 
2.1.2.3. The Commission's idea of introducing 
'Community environment inspectors', could be impor­
tant from the point of view of providing the Member 
States with information and advice and helping them 
to exchange information on their experiences. In this 
connection it should however be borne in mind that 
the implementation of environmental legislation — 
whether European, national or regional — is a matter 
for regional or national authorities and must remain 
so. Steps should be taken to prevent duplication of the 
work of the Community Inspectors and the national 
authorities. The Commission should consider dropping 
the term 'environment inspector' and replacing it with, 
say, 'environment observer'. 
2.1.2.4. Special attention should be paid in this 
respect to company environmental protection officers 
(in-house specialists). Their role should to some extent 
be standardized under Community law. The rules 
regarding the use of company environmental protection 
officers and their qualifications should differ according to the size of the company in question. The status of 
these specialists should be enhanced. 
The 'environmental careers' to which environmental 
protection tasks — including those undertaken by com­
pany environmental protection officers — give rise 
require their own courses of study, eg. in the fields 
of geography, medicine, biology, technology, ecology, 
geology, chemistry and physics. Particular importance 
should be attached to integrated environmental science 
courses. The Commission should draw up training cri­
teria in order to create freedom of movement with 
regard to these professions within the Community. 
2.1.3. Integration of environmental policy 
with other Community policies 
2.1.3.1. The Committee supports the programme for 
integrating environmental protection with other Com­
munity policies. In general the main principles of the 
Community 'environmental impact assessment'^) 
should be applied to all relevant Community measures 
and policy areas. For instance, the explanatory memor­
anda to draft legal instruments should define the 
environmental impact of the proposed measures (the 
indication of the probable budgetary consequences of 
legal instruments set out in draft texts). 
2.1.3.2. This applies in particular to the Com­
munity's common agricultural policy which must seek 
to ensure that agriculture and forestry are compatible 
with the environment, that the countryside is preserved 
as an area where people can live and as a setting for 
economic activity, and that the public is provided with 
high quality agricultural products. The European Struc­
tural Fund designed to assist agricultural measures 
should also be used more than has hitherto been the 
case. For preserving farming activities compatible with 
environment protection considerations. It is assumed 
here that agricultural and forestry undertakings are 
subject to the general laws on the environment and 
planning. 
2.1.3.3. Environmental protection should also 
receive more attention in transport policy and there 
should be a greater emphasis on promoting public 
transport, including transfrontier local transport. Com­
munity safety provisions with regard to the transport 
of dangerous materials or other materials of significance 
to the environment should bear in mind, more than has 
hitherto been the case, environmental hazards as a 
result of accidents. 
2.1.3.4. The programme rightly places special 
emphasis on the coordination of environmental policy 
and regional policy. The Committee would draw atten­
tion in particular to the potential environmental con­
flicts arising from the planned Community-funded 
infrastructure projects of European interest (see 
COM(86) 722 final and working document CES 42/87) 
in the event of a failure to coordinate the measures at 
the right time. 
C1) Council Directive 85/337/EEC (OJ No L 175, 5. 7. 1985, 
p. 40). 
8. 7. 87 Official Journal of the European Communities No C 180/29 
The Committee supports the use of the Regional Fund 
to finance the environmental rehabilitation of inner city 
areas and old industrial areas. 
2.1.3.5. With regard to the coordination of environ­
mental policy and energy policy, the Committee high­
lights the urgency of the measures to improve the 
efficiency of energy conversion and energy use. 
Improved efficiency is essential here if environmental 
protection and resource-conservation are to be compat­
ible with maintenance of living standards. Measures 
to secure an economically sound and environmentally 
acceptable combination of heat and power production 
in electricity generation should be promoted. 
Concessionary tariffs for increased consumption of 
power, heat, water, etc., should be discontinued. The 
Commission should draw up draft models for a tariff 
structure geared to the environmental requirements of 
the Community. This does not of course mean that the 
Committee wants to see tariffs for major consumers 
abolished. 
2.1.3.6. The Committee attaches particular import­
ance to the linking of the protection of the environment 
and protection of the consumer. The Commission 
should devise policies for promoting the marketing 
and use of products which are not harmful to the 
environment. What is particularly necessary is the intro­
duction of a system of marking products to show that 
they are not harmful to the environment. Such a system 
already exists in some States. It is likewise necessary to 
make it obligatory for products' instructions to indicate 
how the products may be used and disposed of without 
damage to the environment. The contribution which 
the individual may make to the effective protection of 
the environment is very inadequately recognized. The 
press, radio and other media should be called upon to 
give greater publicity to products which are not harmful 
to the environment and to the use (and disposal) of 
products in a way which is not environmentally damag­
ing. They should also be urged to pay more attention 
to warning against the use of products which are harm­
ful to the environment. This educational work by the 
media must also cover people's leisure activities. 
The Commission and the Council of Minister should 
work closely together with consumer associations and 
environmental associations at all relevant levels. 
2.1.3.7. The Committee draws attention to the inter­
relation between environmental protection and indus­
trial safety. Every effort must be made to ensure that 
the working environment is not adversely affected by 
measures to prevent pollution of the external environ­
ment, and vice versa. 
The same applies to housing. In this connection atten­
tion is drawn to the damage to the environment, health 
and safety caused by building and industrial materials, 
and by household appliances; appropriate instructions 
and warnings should be provided. Building materials 
recognized as health hazards must be prohibited. Simi­
larly, there should be a ban on construction on danger­
ous sites. 2.1.4. Economic and employment aspects of 
environmental policies and actions 
2.1.4.1. The Committee fundamentally supports the 
Commission's views on economic and employment 
aspects of environmental protection. The Committee 
supports in particular medium and long-term measures 
designed to ensure continuous progress. Businesses can 
calculate the impact of such environmental protection 
policies in advance and they are therefore more likely to 
have a beneficial effect on employment than precipitous 
changes in environmental laws. Experience has also 
shown that the failure to implement environmental 
measures or their late implementation places jobs in 
jeopardy. 
The Commission is requested to compile and publish 
details of experiences and other data concerning the 
impact of environmental protection on economic 
growth and employment in the Community and else­
where. 
The Committee would draw attention to the following 
examples of ways in which environmental protection 
can create jobs: 
— the reconversion of old industrial plants, 
— insulation, rehabilitation and restoration of build­
ings, 
— building and maintenance of sewage treatment 
plants and water treatment plants, 
— research and development, 
— establishment of leisure facilities in rural areas. 
2.1.4.2. As studies carried out by the Committee in 
various regions of the Community have demonstrated, 
the enhancement of the landscape and living conditions 
as a result of improvements in environmental protection 
will have a beneficial effect on tourism, thereby con­
tributing to economic strength of these regions. Care 
should, however, be taken to ensure that tourism does 
not develop on lines harmful to the environment. 
2.1.4.3. The five-year Community programme of 
demonstration project (*) envisaged by the Commission 
provides an opportunity to promote Community 
environmental policy — particularly for the benefit of 
more disadvantaged regions of the Community. The 
Committee therefore supports the proposed pro­
gramme. 
2.1.4.4 The Committee would refer to the Commit­
tee's comments on cost-benefit assessments of environ­
mental policy measures as set out in its Opinion on the 
second action programme for the environment (2). The 
assessment criteria will however be controversial, as 
account is taken of the great variety of legitimate points 
of view. 
0) COM(OO) of 2. 3. 1987. The ESC will publish on Opinion on 
this paper in the course of 1987. 
(2) OJ No C 281, 27. 11. 1976, p. 23. 
No C 180/30 Official Journal of the European Communities 8. 7. 87 
2.1.5. Economic instruments of environment 
policy 
2.1.5.1. The Committee welcomes the intention to 
make greater use of economic instruments in the 
environmental policy. This will make it possible to 
promote environmental protection measures taken by 
those concerned on their own initiative, without pre­
judice to the legal instruments. The sale of environmen­
tal utilization permits is frequently mentioned in this 
context. The Committee has fundamental reservations 
over this type of measure which has so far not proved 
to be practicable anywhere. 
When assessing the economic impact of environmental 
protection measures it should be borne in mind that, 
in the final analysis, it is the consumer who has to meet 
all or part of the costs. 
2.1.5.2. In the section dealing with economic instru­
ments the Commission proposes greater use of the 
Regional Fund in reducing environmental pollution. 
The Committee endorses the proposal, provided that 
such aid goes primarily to those who take environmen­
tal protection measures extending beyond what is pre­
scribed. In cases where the Regional Fund is used for 
environmental protection schemes particular attention 
should be paid to involving regional and local authori­
ties, associations and initiatives. 
2.1.5.3. The Committee is pleased that the Com­
mission is contemplating extending the 1975 Com­
munity framework provisions on Member States' aid 
for environmental protection measures. Consideration 
should, however, be given to making such extension 
conditional upon aid being restricted to measures which 
(a) go beyond the minimum requirements laid down by 
law or set out in European standards, or (b) incorporate 
state-of-the-art developments or enable these develop­
ments to be put into practice before the statutory dead­
line. 
2.1.5.4. The Committee notes with interest the Com­
mission's views on the legal provisions governing liab­
ility and compensation in respect of damage to the 
environment. It draws attention to the problems 
involved in compensation for trans-frontier damage and 
to the need to make insurance cover mandatory, should 
liability regardless of fault (absolute liability), be intro­
duced. Attention is also drawn in this context to the 
importance of implementing Directive 85/374/EEC(1) 
on liability for defective products. 
In cases where it is not possible to attribute individual 
responsibility for damage to the environment to individ­
ual agents — as, for example, with regard to contamin­
ated sites (old-established dumps), damage to forests 
and water pollution — the State is not to be called 
upon to meet the cost of rehabilitation work from the 
outset. Consideration should also be given to whether 
and to what extent the cost of redressing such damage 
can be met by regional or sectoral funds. A further 
idea for consideration is the formation of associations 
(*) Council Directive of 25 July 1985 on the approximation of 
Member States' legal and administrative provisions on liab­
ility for defective products (OJ No L 210, 7. 8. 1985, p. 29). bringing together the agents of pollution and product 
users in joint financing ventures. Where possible such 
solutions should be organized on a transfrontier basis. 
2.1.5.5. The pollution charges referred to in the pro­
gramme merit consideration. These charges should be 
high enough to avoid an incentive for those concerned 
to take their own measures to avoid environmental 
pollution. The Committee proposes the organization of 
a comprehensive exchange of experience — involving 
both Community and non-Community countries — 
on the impact of such charges upon environmental 
protection and on difficulties involved in collecting 
them. 
In the case of environmental pollution which endangers 
public health there can be no question of charges replac­
ing environmental protection measures. 
2.1.6. Information and education 
2.1.6.1. The Committee attaches considerable 
importance to environmental education, the provision 
of information on the environment and the training of 
teachers. 
2.1.6.2. The Committee proposes that, in particular 
in the European Year of the Environment, the pilot 
schools project should not be brought to an end but 
continued and extended to higher education (2). An 
appraisal of the measures carried out to date should be 
undertaken and published. The Committee is particu­
larly interested in seeing information on the environ­
ment incorporated into school curricula. The Com­
mission should look into the feasibility of providing 
environmental teaching material for use in the Member 
States. The Committee draws attention to the practice 
in some Member States whereby schools and adult 
education organizers work together with outside organ­
izations specializing in environmental protection and 
environmental education. 
2.1.6.3. It is also a part of the environmental edu­
cation to provide young people undergoing vocational 
training with all the necessary information on environ­
mental protection (eg. manufacturing processes and 
environmental protection techniques; the selection of 
environmentally-compatible materials; and a know­
ledge of environmental protection provisions). Further 
vocational training courses should also keep students 
abreast of the latest developments and provisions in the 
field of environmental protection and make them aware 
of the current desiderata of environmental policy. The 
Commission is urged to draw up models for this kind 
of job-related environmental information. 
(2) See also the Comett project (proposal for a Council Decision 
on an action programme of the Community in education and 
training for technology (1986 to 1993)) — (ESC Opinion of 
27 November 1985 (OJ No C 344, 31. 12. 1985, p. 4)) and 
the Erasmus project (proposal for a Council Decision on 
the European Community action scheme for the mobility 
of university students) (ESC Opinion of 23 April 1986 (OJ 
No C 189, 28. 7. 1986, p. 8)). 
8. 7. 87 Official Journal of the European Communities No C 180/31 
2.1.6.4. The Committee advocates an open debate 
on the environment and a high level of public partici­
pation in the environmental decision-making process. 
In the case of projects which have repercussions in other 
countries, special attention should be paid to ensuring 
that the local communities in those countries are 
involved at an early stage and on an equal footing in 
decision-making. 
2.1.6.5. The Committee supports the Commission's 
proposals for the provision of more information on 
the environment and for improved cooperation with 
environmental associations, non-governmental organiz­
ations and other bodies involved. With this aim in 
view it is important to give the members of the public 
concerned an insight into the preparatory work on 
environmental protection undertaken by the Com­
mission and into the results of the monitoring at Euro­
pean level of environmental protection measures. 
2.1.6.6. The following points should also be borne 
in mind with regard to the provision of environmental 
information by both the Community and the Member 
States: 
— As the impulse for maintaining and improving the 
Community's environment must, in the final analy­
sis, be borne by its inhabitants, the importance of 
improving environmental awareness by informing 
and educating people cannot be over-estimated. 
— Citizens of the Community as beneficiaries of 
environmental policy should be aware that all the 
measures have financial consequences and should 
recognize that both private and public finances are 
limited. Environmental information should there­
fore be provided which enables people to recognize 
the priorities of the various areas of policy and to 
help in implementing them. 
2.2. Measures to prevent and control environmental-
pollution 
2.2.1. In line with the political objectives of the 
action programme, the 'general principles for the pre­
vention and control of pollution' have, in the Commit­
tee's view, the following implications: 
— the various approaches to environmental protection 
should not be regarded as alternatives but, depend­
ing on the problem concerned, should be brought 
into play cumulatively; in this context the setting of 
quality objectives for the individual sectors of the 
environment must not jeopardize the validity of 
emission limits, 
— consistent application of the principle of taking 
preventive action entails giving priority to measures 
to tackle the source of pollution, 
— the responsibility for implementing these measures 
must lie with the polluter; where several polluters 
are involved, there is a case for specifying the joint 
responsibility of all concerned. Parties suffering 
damage or loss as a result of environmental pol­
lution must not be placed at a disadvantage in cases 
where more than one polluter is involved; therefore 
a 'reversal of the burden of proof. 
When these principles are being implemented account 
should be taken of the fact that environmental problems are not infrequently triggered by work on local develop­
ment projects. In such cases the responsibility of local 
and regional authorities should be particularly stressed. 
2.2.2. The Committee welcomes the emphasis placed 
by the Commission on 'state of the art' methods in 
determining emission limits. The Committee would, 
however, draw attention to the following points: 
— This term should be taken to imply the use of 
advanced processes, equipment and operating 
methods which seem well suited to promoting 
environmental protection; account should be taken 
in this respect of experience outside the Community. 
— The 'state of the art' is constantly progressing; such 
progress can be speeded up by setting deadlines for 
the objectives to be met under Community environ­
mental protection standards; 
2.3. Action in specific sectors 
2.3.1. Atmospheric pollution 
2.3.1.1. The Committee shares the Commission's 
view that the prevention of atmospheric pollution must 
be one of the main goals of Community environmental 
policy, especially in the light of trans-frontier air pol­
lution. The Community should therefore aim, by intro­
ducing higher emission standards in respect of the major 
pollutants and industries, to launch a clean air policy 
which would also cover existing plants. The Directive 
on large combustion plants is a first step in the right 
direction. The Committee urges the Council of Minis­
ters to adopt this draft Directive taking account of the 
Committee's Opinion, without further delay. 
2.3.1.2. High priority should, of course, also be given 
to measures to further reduce motor vehicle exhaust 
emissions. The technical progress which has been made 
in many areas enables stricter standards to be intro­
duced. 
2.3.1.3. The Community should play a constructive 
role in international policy to prevent air pollution. 
This applies in particular to the work in connection 
with agreements on long-range, transfrontier air pol­
lution and the supplementary protocol under which 
signatory countries undertake to reduce their sulphur 
dioxide emissions by at least 30% by 1993. 
2.3.1.4. There are grounds for suspecting that 
chlorofluocarbons are endangering the earth's ozone 
layer. The Committee considers that after years of 
largely fruitless debate it is now really imperative to 
take measures in the short term to bring about a sharp 
reduction in the use of chlorofluorocarbons and to set 
a timetable for achieving a complete ban on their use. 
The compromise reached following international con­
sultations does not go far enough to make an effective 
contribution to stopping further destruction of the 
ozone layer. Only harmless substances can be con­
sidered as replacements for chlorofluorocarbons. 
No C 180/32 Official Journal of the European Communities 8. 7. 87 
2.3.2. Fresh water and sea water 
2.3.2.1. In order to prevent pollution of inland water­
ways the Committee feels that emission standards and 
quality standards, which have hitherto been regarded 
as alternative or 'parallel' instruments should in future 
be applied cumulatively (point 4.2.3 of the action pro­
gramme). The fixing of emission ceilings for the various 
industries on the basis of the best available technology 
is regarded as feasible and as a matter of urgency. 
Particular importance should be paid in this context to 
the protection of ground water; such measures save the 
need for costly water. The Commission should give 
priority to the protection of rivers and waterways 
against pollution as a result of accidents. 
The Committee points out that there are cases of agri­
cultural pollution of waterways, e.g. from silo units, 
and that these should be avoided. 
2.3.2.2. High priority should also be attached to 
measures to prevent and reduce pollution of seas, coas­
tal waters and bathing waters. The seas surrounding 
the Community, in particular the Mediterranean and 
the North Sea, are sensitive ecosystems which the Com­
munity must make strenuous efforts to protect. The 
following areas in particular need to be looked at: 
— an Action Programme for the Mediterranean and 
for the North Sea on the basis of the first Conference 
on the Protection of the North Sea, 
— the reduction of land-based marine pollution con­
veyed via rivers and the atmosphere, 
— the reduction of the dumping of waste at sea and 
an end to waste incineration at sea, 
— the prevention of pollution caused by accidents; 
eg. measures should be taken to prevent largescale 
environmental damage as a result of shipping acci­
dents; this would involve setting up a round-the-
clock tug standby service at strategically located 
harbours and ensuring that damaged ships were 
swiftly towed to port, 
— legal measures to permit ships which are themselves 
not in a sufficiently safe state or have cargoes which 
are not in a sufficiently safe state to be detained in 
port if this is necessary in view of the weather 
situation. 
The Community should take steps to ensure that all 
international agreements on the prevention of marine 
pollution are swiftly ratified and enforced by the Mem­
ber States. 
2.3.3. Chemicals 
The Committee endorses the Commission's proposal, 
as part of the measures to provide protection against 
dangerous or harmful chemicals, to devise a new pro­
cedure for the risk assessment of existing chemicals. 
Using the EINECS list (European inventory of existing 
chemical substances), classification of dangerous sub­
stances should be undertaken. This classification, which would take the form of a list of priorities as regards 
timing and toxicological levels, should draw on existing 
test findings, such as those obtained in the US. 
In assessing the toxicity of chemicals, eg. those used in 
agriculture, account should be taken of the cumulative 
effects of repeated use and the interaction between 
substances used simultaneously. 
2.3.4. Biotechnology 
The Committee welcomes the interest shown by the 
Commission in tackling problems of biotechnology — 
as regards its effect on people and the environment — 
and in developing mandatory Community provisions 
in this field. As yet, none of the Member States has 
comprehensive legislation in this area. Community 
legislation could, therefore, serve as a model in this 
respect. The effectiveness of the proposed plan of action 
can only be assessed, however, after the Commission 
has put forward definite proposals. 
2.3.5. Noise 
2.3.5.1. The Committee shares the Commission's 
view that noise abatement is an important aspect of 
environmental protection, because of the number of 
people severely affected. 
2.3.5.2. Community anti-noise measures should con­
centrate on limiting noise at source and should cover 
appliances and vehicles which create noise. Controls 
should not simply apply to the noise emitted from a 
single source but should also take into account the 
combined noise level emitted by a number of appliances 
of the same or of different type. 
The Community 'quality objectives' for noise referred 
to in the Commission document should be the 
maximum levels in accordance with physiologial 
requirements, given that views differ in the various 
Member States as regards tolerable levels of noise. 
2.3.5.3. The possibility considered by the Com­
mission of using special charges to discourage noisy 
products is interesting as an example of an environmen­
tal policy instrument with an economic angle. The 
Committee has already set out its basic views on this 
matter in its Opinion on the protection of workers 
against the risks related to exposure to chemical, physi­
cal and biological agents at work: noise (*). 
(J) ESC Opinion of 23 November 1983 (OJ No C 23, 30. 1. 1984, 
p. 30); see also OJ No C 283, 27. 12. 1979, p. 19, and the 
Committee's Opinion of 20 October 1986 which will be 
published in the course of 1987. 
8. 7. 87 Official Journal of the European Communities No C 180/33 
2.3.6. Nuclear safety 
The Committee would refer to the Opinion o the Econ­
omic and Social Committee on Nuclear Safety (!) and to 
the Committee's Opinions currently in preparation (2). 
2.4. Management of environmental resources 
2.4.1. Conservation of nature and natural 
resources 
2.4.1.1. The Community should work towards a 
European nature conservation strategy, e.g. by adopting 
the 1980 World Conservation Strategy drawn up by 
the United Nations Environment Program (UNEP) in 
conjunction with other organizations. The Committee 
draws particular attention to the need to support Euro­
pean nature conservation areas. 
2.4.1.2. There is an inter-relation between nature 
conservation and other policies, in particular agricul­
tural policy. 
2.4.1.3. Conflict may arise between nature conser­
vation and agriculture — not least as a result of Com­
munity aid schemes — for the following reasons: 
— the Community's agricultural policy leads to the 
intensive use of available farmland; an effective 
nature conservation policy, on the other hand, often 
demands that ecologically important areas be left 
unfarmed, 
— preservation of wetlands is an important aspect of 
nature conservation. 
2.4.1.4. The Committee welcomes the animal wel­
fare and protection measures provided in the pro­
gramme and particularly wishes to see them 
implemented. 
2.4.2. Protection of the soil 
The inclusion of protection of the soil is welcomed. 
This subject deserves to be treated as an important 
aspect of Community environmental policy. Here, too, 
there is a close inter-relation with agriculture, in par­
ticular as regards: 
(*) ESC Opinion of 25 February 1987 on Community measures 
in pursuance of Chapter III of the Euratom Treaty, namely 
the establishment of a Community system of rapid exchange 
of information in cases of unusually high levels of radio­
activity or of a nuclear accident (OJ No C 105, 21. 4. 1987, 
p. 9). 
(2) ESC own-initiative Opinion on the consequences of the Cher­
nobyl nuclear accident and ESC Opinion on (a) the proposal 
for a Council Regulation (EEC) extending Regulation (EEC) 
No 1707/86 on the conditions governing imports of agricul­
tural products originating in third countries following the 
accident at the Chernobyl nuclear power station and (b) a 
permanent system for establishing limits for the radioactive 
contamination of drinking water and agricultural products in 
the case of a nuclear accident. These two ESC Opinions are 
expected to be adopted in mid-1987. — intensive husbandry (eg. problem of excessive use 
of liquid manure as a fertilizer), 
— the use of artificial fertilizers, 
— authorization and use of plant protection products, 
and defoliants, 
— measures to prevent erosion of farmland, and for­
estry land, including the risk of desertification, eg. 
of the kind which can be caused by widespread 
forest fires, 
— even if it is brought about by natural causes, deserti­
fication is a pressing problem in some regions and 
one which will require — in the short term — 
very considerable efforts to be made in all fields 
(research, finance, infrastructure work, etc.). 
Attention is drawn to the importance of area and town 
planning for protection of the soil ('sealing of the land­
scape' through the use of land for road and urban area 
construction). 
2.4.3. Waste management 
2.4.3.1. The Committee believes that waste manage­
ment (3) has become an increasingly important aspect 
of environmental policy. It calls for a 'waste strategy' 
with the following priorities: 
— waste avoidance, 
— waste processing and recycling of valuable 
materials, 
— waste disposal (less waste; dumping in ways which 
are not harmful to the environment and do not 
constitute a health hazard). 
As part of the strategy for avoiding waste, measures 
should be taken to promote the use of durable products 
and re-usable or recyclable packaging. 'Clean' technol­
ogies should also be developed and promoted. The 
inculcation of environmentally conscious attitudes has 
a particular role to play in reducing the generation of 
rubbish and resulting environmental pollution. 
2.4.3.2. The cleaning-up of contaminated sites 
(especially old dumps) is a particular waste manage­
ment problem. This is a very live issue in many Member 
States. The Committee welcomes the inclusion of these 
problems in the Council Regulation on Community 
action on the environment (4). Encouraging the Member 
(3) See ESC Opinion of 24 May 1984 on the Community action 
programme on the management of waste (avoidance, recyc­
ling, disposal) (OJ No C 206, 6. 8. 1984, p. 62), and the 
Section for Protection of the Environment, Public Health and 
Consumer Affairs' report on the matter. 
(4) Council Regulation (EEC) No 1872/84 (OJ No L 176, 
3. 7. 1984, p. 1) is to be amended accordingly, cf. the Com­
mission proposals set out in COM(00), of 19 December 1986 
and the ESC Opinion to be adopted in June 1987. 
No C 180/34 Official Journal of the European Communities 8. 7. 87 
States to exchange experiences would also be very use­
ful. The Committee also draws attention to the particu­
lar problem of poisonous waste. The transport and 
disposal of this waste requires transfrontier cooper­
ation, to include, inter alia, the registration of transport 
undertakings operating in this field. 
2.4.4. Urban areas, coastal and mountain 
zones 
The proposed measures to clean up derelict industrial 
areas and inner cities are of particular interest. Regional 
policy could have a role here. This also applies to areas 
having a single industrial structure and high pollution 
levels. Steps should be taken to ensure that society as 
a whole, and not just individuals, benefits from the 
financial advantages provided by rehabilitation work 
promoted by public funds. Funds should be derived 
from the increased value of the amenities for spending 
on the programme of further rehabilitation measures. 
The Committee draws the Commission's attention to 
the special environmental problems of islands. For geo­
graphical and hydrographic reasons these are at particu­
larly high risk. 
2.5. Research 
2.5.1. The Committee would refer to the Commit­
tee's Opinion adopted in November 1986 (l) on the 
Community framework programme in the field of Re­
search and Technological Development (1987 to 1991). 
Energy technology (R & D) is of particular interest for 
environmental policy; this should include promotion of 
the development of fuel cells and electrically powered 
vehicles. 
2.5.2. The coordination of environmental research 
in the Community is essential in order to prevent dupli­
cation of work, fill research gaps and make research 
results comparable. To this end, the Community should 
exploit the Member States' research capacity effectively, 
eg. by the award of EEC research contracts. 
2.6. International action 
2.6.1. Action taken in international organiz­
ations and with non-EEC countries 
The Committee is in favour of increased cooperation 
with international organizations and non-EEC 
countries. In so far as is possible, the Community should 
become a party to further international agreements. 
The Section underlines the need to avoid duplication 
of work, especially as regards research and development 
and the pooling of experience. Improved coordination 
is therefore needed between the various programmes. 
(*) ESC Opinion of 27 November 1986 (OJ No C 333, 
29. 12. 1986, p. 45). Joint action programmes should be worked out and 
promoted by the Community and international organiz­
ations (eg. the FAO). 
2.6.2. Cooperation with developing 
countries on environmental matters 
2.6.2.1. The Committee welcomes the fact that the 
Commission wishes the Community's development pol­
icy to take more account of environmental matters 
and wants the experiences and views of environmental 
organizations in developing countries to be taken into 
consideration. Every project for cooperation with the 
developing countries must be vetted from the point of 
view of its impact on the environment. 
2.6.2.2. One of the main aims of development aid 
should be to promote techniques suited to the circum­
stances of the developing countries, such as developing 
straightforward methods of providing supplies of fresh 
water. 
2.6.2.3. The Committee wishes to draw attention to 
the problem of the export to non-member countries of 
European products, the use of which is banned or 
restricted within the Community to protect health or 
the environment. 
The export of these products should in principle be 
prohibited. Where in exceptional cases the export of 
these products is not banned, however, steps should be 
taken at Community level to ensure that purchasers are 
informed of the known risks associated with them and 
that their attention is drawn to the legal restrictions. It 
must then be the responsibility of the importing country 
to take appropriate measures where necessary. 
2.7. European Year of the Environment 
2.7.1. The Committee has welcomed the European 
Year of the Environment. It regards EYE as an out­
standing opportunity to disseminate information on 
serious environmental problems and promote aware­
ness of the environment. This objective can be served 
by stepping up the dialogue between the various parties 
affected by environmental problems. 
2.7.2. The Committee has therefore considered the 
European Year of the Environment in its work pro­
gramme, laying stress on: 
— promoting awareness of the environment through 
information and training, 
— opening up new markets, by informing (a) firms 
and employees about progressive environmental 
protection techniques and (b) consumers about non-
polluting products, 
— job creation initiatives by the 'environmental indus­
try' and in the wake of the economi dynamism 
generated by the rehabilitation of areas suffering 
from environmental damage, 
8. 7. 87 Official Journal of the European Communities No C 180/35 
2.8. Cooperation on future environmental policy 
developments 
The Committee expects the present fourth environmen­
tal action programme to be followed by other environ­
mental action programmes. The Committee calls on 
the Commission, when it is drawing up these pro­
grammes and the related rules, to cooperate not only 
with government departments but also with employers' 
and workers' organizations and representative environ­
mental and consumer groups. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
ANNEX 1 
Rejected amendments 
The following amendments, tabled in accordance with the Rules of Procedure, and based on the Section 
Opinion, were rejected in the course of discussions: 
Point 2.1.2.1 
Delete the last three sentences (while retaining the first sentence). 
Reason 
Without effective supranational (i.e. Community) inspection, the Directives could not be applied in most 
regions or Member States. 
Voting 
For: 31, against: 84, abstentions: 8. 
Point 2.2.1 
(b) In the fourth line of the third indent, delete the words 'therefore a "reversal of the burden of proof". 
Reason 
The purpose of the second part of the amendment is to prevent uncritical acceptance of a principle (which in 
itself is uncontroversial) being applied in a way which puts it in serious conflict with the legal systems of the 
Member States. 
Votmg 
For: 50, against: 72, abstentions: 11. — measures to tackle regional environmental problems 
— including those of a transfrontier nature — 
involving cooperation between not merely state and 
local authorities but also both sides of industry, 
consumer associations and environmental associ­
ations. The press and the other media should also 
play a role in this respect. These measures should 
include exchanges of experience and information 
between such regions which, whilst geographically 
dispersed, suffer from similar problems. 
Done at Brussels, 13 May 1987. 
No C 180/36 Official Journal of the European Communities 8. 7. 87 
ANNEX 2 
The following members voted in favour of the Opinion: 
Mr AMATO 
Mr ASPINALL 
Mr ATAIDE 
Mr BENTO GONgALVES 
Mr BERETTA 
Mr BLESER 
Mr BOISSEREE 
Mr BOS 
Mr BRIGANTI 
Mr LOBO BRANDAO 
Mr CALVET CHAMBON 
Mr CARROLL 
Mr CAVAZZUTI 
Mr CEBALLO HERRERO 
Mr CHRISTIE 
Mr ALVES CONDE 
Mr CURLIS 
Mr van DAM 
Mr von der DECKEN 
Mr DELHOMENIE 
Mr DELLA CROCE 
Mr DOS SANTOS 
Mr DRAGO 
Mrs ELSTNER 
Mr EMO CAPODILISTA 
Mr ETTY 
Mr EULEN Mr FRANDI 
Mr GEUENICH 
Mr GLESENER 
Mr FORGAS 
Mr GOMEZ MARTINEZ 
Mr GORIS 
Mrs GREDAL 
Mr GREEN 
Mr van GREUNSVEN 
Mr HAAS 
Mr HAGEN 
Mr HAMMOND 
Mr HILKENS 
Mr HORSKEN 
Mr HOVGAARD JAKOBSEN 
Mr JASCHICK 
Mr JENKINS 
Mr KAARIS 
Mr LAKA MARTIN 
Mr LANDABURU 
Mr LOJEWSKI 
Miss MADDOCKS 
Mr MAINETTI 
Mr MEYER HORN 
Mr MORSELLI 
Mr MOURGUES 
Mr MUHR Mr MUNIZ GUARDADO 
Mr MURPHY 
Mr NIELSEN P. 
Mr NIEUWENHUIZE 
Mr ORSI 
Mr PROENCA 
Mr QUEVEDO ROJO 
Mr RAMAEKERS 
Mr ROSEINGRAVE 
Mr ROUZIER 
Mr SALOMONE 
Mr SANTILLAN CABEZA 
Mr SCHMITZ 
Mr SCHOEPGES 
Mr SILVA 
Mr SMITH A.R. 
Mr SMITH L.J. 
Mr SOLARI 
Mr STAEDELIN 
Mr STRAUSS 
Mrs TIEMANN 
Mr TUKKER 
Mr VANDEN BROUCKE 
Mr VIDAL 
Mr VELASCO MANCEBO 
Mr VERCELINO 
Mr ZUFIAUR NARVAIZA 
The following members voted against the opinion: 
Mr APARICIO BRAVO 
Mr ARENA 
Mr BAGLIANO 
Mr BELTRAMI 
Mr BROICHER 
Mr CASHMAN 
Mr CEYRAC 
Mr CLAVEL 
Mr COLLAS 
Mr COYLE 
Mrs DODD 
Mr DROULIN 
Mr GARDNER 
Mr GIACOMELLI Mr HANCOCK 
Mr KELLY 
Mr KENNA 
Mr LANCASTRE 
Mr LAUR 
Mr LOPEZ DE LA PUERTA 
Mr MACHADO v. TSCHUSI 
Mr MARGALEF MASIA 
Mr MARTIN ALMENDRO 
Mr MARTIN CASTELLA 
Mr MASPRONE 
Mr MORELAND 
Mr PEARSON 
Mr PELLETIER Mr PERRIN-PELLETIER 
Mr PETROPOULOS 
Mr PROUMENS 
Mr RIBIERE 
Mrs ROBINSON 
Mr ROLAO GONCALVES 
Mr ROMOLI 
Mr SAftJ 
Mr SCHNIEDERS 
Mr SPRINGBORG 
Mr TAMLIN 
Mr WAGNER 
Mr WHITWORTH 
Mr YVERNEAU 
The following members abstained: 
Mr ARETS 
Mr BLACK 
Mr CAMPBELL 
Mr CORELL AYORA 
Mr DUNET 
Mr FRESI Mr KROGER 
Mr LOW 
Mr NETO DA SILVA 
Mr NOORDWAL 
Mr de NORMANN 
Mr PARDON Mr POETON 
Mr RIERA MARSA 
Mr SPEIRS 
Mr TIXIER 
Mr WICK