No C 232/2 Official Journal of the European Communities 31. 8. 87 
2.3. The Committee suggests setting up a central list of 
the various approved laboratories on EEC territory; such a 
list should be easily accessible to the public, should indicate 
each laboratory's fields of activity and could be run by the 
'Committee' referred to in Article 6 of the present 
proposal. 
2.4. The Committee also considers that, in line with 
previous Commission statements, laboratories should not be 
allowed to refuse inspection, although their legitimate rights 
should be preserved, especially their right of appeal. The 
proposed Directive should therefore include: 
Done at Brussels, 1 July 1987. 
1. General comments 
1.1. The Committee is pleased to see that parts I and II of 
Directive 76/464/EEC are to be merged into a single 
Directive, which will make for a more systematic 
approach. 
1.2. In the Committee's view, however, the text is too 
long-winded (and even confused in parts) — there are so 
many recitals that they outnumber the actual articles. It is not 
necessary to reproduce all the articles and Annex I of the (a) the right of appropriate bodies to have access to 
inspection reports and related documents; 
(b) the right to appeal when such inspections may lead to a 
laboratory being struck off the GLP list; and 
(c) the appointment of an appeal authority (possibly the 
'committee' referred to in Article 6 of the proposal). 
2.5. The Committee therefore welcomes and endorses the 
present proposal, and feels that it is essential if GLP is to be 
guaranteed. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
original proposal. It would have been better to make the text 
simpler. 
1.3. The Committee feels that the proposal is too limited 
in its scope. Not all uses of the drins are covered and the 
Committee points out that environmental problems could 
arise from these other uses, e.g. leather and wood 
protection. 
The Committee also emphasizes the need for preventive 
measures by avoiding the introduction into the Community 
of commodities which can give rise to releases of the drins 
into the aquatic environment of the Community. Opinion of the Economic and Social Committee on the modified proposal for Council Directives 
concerning limit values for discharges of aldrin, dieldrin and endrin in the aquatic environment and 
quality objectives for aldrin, dieldrin and endrin in the aquatic environment 
(87/C 232/02) 
On 23 April 1987 the Council decided to consult the Economic and Social Committee, under Article 
198 of the Treaty establishing the European Economic Community, on the abovementioned 
proposal. 
The Section for Protection of the Environment, Public Health and Consumer Affairs, which was 
responsible for preparing the Committee's work on the subject, adopted its opinion on 1 June 1987 in 
the light of the report by Mr Rolao Concalves. 
At its 247th plenary session (meeting of 1 July 1987) the Economic and Social Committee 
unanimously adopted the following Opinion: 
The Committee endorses the proposal and has the following comments to make: 
31. 8. 87 Official Journal of the European Communities No C 232/3 
The Committee was disappointed, particularly after so many 
years have elapsed since the first proposal, that the 
Commission has not been able to deal with these broader 
issues. 
1.4. Whist realizing that this Directive does not address 
itself to the marketing of the drins but only the pollution they 
may cause, the Committee would nonetheless wish to know 
in which Member States of the Community the use of these 
products is still allowed and which two countries still have 
problems resulting from the import of commodities treated 
with these pesticides. 
1.5. The Committee urges the Commission to propose a 
Directive which would ban products treated with the 
substances in question, considering also that scientific 
progress would allow us to expect their replacement by less 
harzardous ones. 
1.6. The Committee welcomes the idea that where 
neighbouring Member States have an interest in common 
waters they could cooperate in monitoring the application of 
the Directive and in harmonizing the measures outlined in 
this proposal (Articles 3 (6) and 4). The Committee would 
call for even closer cooperation and joint solutions to internal 
Community problems, the aim being the continued 
consolidation of the internal market in coherence with the 
conclusions of the inaugural EYE Conference in 
Luxembourg. 
1.7. The Committee does not agree with the omission of 
isodrin from the main text of the Directive and its Annexes. 
The Commission merely refers to isodrin in footnotes, 
though by doing this it seeks to extend limit values for aldrin, 
dieldrin and endrin to cover isodrin as well. Isodrin should be 
defined as a chemical substance and included.in the limit 
values given in the Annexes, along with the other pesticides 
covered by the Directive, instead of being relegated to the 
footnotes. 
2. Detailed comments 
2.1. Recital 6 
This is an unnecessary repetition of recital 5. Moreover, it 
could be taken to mean that consumer protection is of 
secondary importance compared to pollution of the aquatic 
environment, which would be inconsistent with the aim of 
building a 'People's Europe'. The recital is unfortunately 
worded and superfluous, and should therefore be deleted. 
2.2. Article 2 (e) (original proposal) 
The definition of 'discharge' (Article 2 (e) of the original 
proposal) should be retained and reworded as follows to fit in 
with the new layout in the amended proposal: 
'the introduction into the waters referred to in Article 1 (2)'. 
Otherwise, references further on in the proposal to discharges (Article 3 (1) and the Annexes) are not 
explained. 
2.3. Article 3 (3) 
Authorizations should be reviewed 'every five years', or 
'every five years after an initial period of four years', in order 
to fall in line with the time scales laid down in Article 6 (2) 
and 5 (3) of Directive 86/280/EEC. 
2.4. Article 7 (1) 
The proposed deadline of 1 January 1988, the date by which 
all Member States are to bring into force the necessary 
measures comply with the Directive, is unrealistic. This 
approach has been used in the past and has created 
discrepancies amongst the Member State which are 
unacceptable as they could give rise to distortions in 
competition. 
2.5. Annex I — General provisons 
Isodrin should be included at this stage in the list of pesticides 
covered by these provisions. 
2.6. Annex II — Specific provisions 
Isodrin should be added to the three substances already 
listed. The rest of the Annex, including the tables, should be 
amended accordingly and references to isodrin should be 
deleted from the footnotes. 
2.7. Tables in Annex II — Headings A and B 
1.1 A. Once again, the deadlines for the introduction of 
limit values (1 January 1988 in both cases) are unrealistic and 
should be revised. 
2.7.2. The Committee would like to have further 
information from the Commission about the technical basis 
for both the limit values and quality objectives. 
2.7.3. The Council advises the Commission to take into 
account scientific knowledge in the establishment of these 
values. 
2.8. Annex II — Heading A 
The Committee feels that the discharges of the drins from 
other processes using the material should be subject to similar 
No C 232/4 Official Journal of the European Communities 31. 8. 87 
controls to those for proofing of wool and wool products and 
that these limits should be specified in the table. 
2.9. Standstill clause 
The Committee assumes that the standstill clause set out in 
Committee 3 Annex 2, heading B, will also apply to heading 
A, although the text does not so specify. The Committee 
thinks that the sediment analysis, and particularly sampling 
methods, is not sufficiently developed and concretely defined 
(e.g. the place, time, distance of the source, type of sediment 
etc.). Leaving the measurements of the concentration of the 
Done at Brussels, 1 July 1987. 
1. General comments 
1.1. On 28 June 1984 the Council, acting on a 
Commission proposal, adopted Regulation (EEC) No 
1872/84 (2) on action by the Community relating to the 
environment. 
1.2. This Regulation opened the door for the Community 
to grant financial support in three priority areas: 
— demonstration projects for developing new cleaner 
technologies, 
— demonstration projects for developing new techniques 
and methods for measuring and monitoring the quality of 
the natural environment, and 
(») OJNoC 18,24. 1. 1987, p. 5. 
(2) OJ No L 176/1 et seq of 3 July 1984. drins in the aquatic environment, sediments, molluscs, 
shellfish and fish to interpretation by Member States could 
lead to discrepancies in the application of the Directive. 
2.10. Reference method of measurement 
The limits of determination for each substance in sediments 
and organisms should be defined on a separate basis and not 
applied jointly. Limits should not vary according to the 
number of other substances present. 
The Chairman 
the Economic and Social Committee 
Alfons MARGOT 
— projects providing an incentive and designed to 
contribute towards the maintenance or restoration of 
seriously threatened habitats of endangered species of 
particular importance to the Community, under 
Directive 79/409/EEC. 
1.3. The Commission reports points to a keen demand 
and initial assessments indicate that those projects which 
have been implemented will have a positive impact. 
Applications for aid have exceeded the funds available 
several times over. 
1.4. The Committee is pleased that the Commission has 
submitted a new proposal in the light of this experience. The 
proposal is designed to secure continuity and to promote and 
fund additional projects in the following new key areas: Opinion of the Economic and Social Committee on the proposal for a Council Regulation on action by 
the Community relating to the environment (!) 
(87/C 232/03) 
On 15 January 1987 the Council, acting under Article 198 of the Treaty establishing the European 
Economic Community, asked the Economic and Social Committee for an opinion on the 
abovementioned proposal. 
The Committee instructed its Section for Protection of the Environment, Public Health and Consumer 
Affairs to prepare the opinion. The Section adopted its opinion, based on the report by Mr Schmitz on 
1 June 1987. 
The Committee unanimously adopted the following opinion at its 247th plenary session (meeting of 1 
July 1987).