No C 83/20 Official  Journal  of the European  Communities 2. 4. 80 
tions,  but  the  total  amount  of mercury  in the  surface  water  would  remain  the  same.  The  regu-
lar daily  measurement  of the  discharged  effluent  would  detect  immediately  any  sudden  rise  in 
the mercury  concentration  so that  appropriate  measures  could  be taken  at once.' 
Reason 
This  amendment  is self-explanatory. 
Voting 
For:  37;  against:  46;  abstentions:  3. 
Opinion  on 
— the proposal  for a Council  Directive  on the limit  values  for discharges  of aldrin,  diel-
drin and  endrin  into  the aquatic  environment 
— the proposal  for a Council  Directive  on the quality  objectives  required  for the aquatic 
environment  into  which  aldrin,  dieldrin  and  endrin  are discharged 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the Euro-
pean  Communities  No  C 146  of 12 June  1979,  page  5 to 9. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 29 May  1979  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 
174th  plenary  session  held  in Brussels  on 12 and 13 December  1979. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  Treaty  establishing  the  Euro-
pean  Economic  Community,  and  in particular  Arti-
cle 198  thereof, 
Having  regard  to the request  made  by the  Council 
of the European  Committee  on 29 May  1979  for an 
opinion, 
Having  regard  to the decision  taken  by the Bureau 
on 21 May  1979,  instructing  the Section  for Protec-
tion of the  Environment,  Public  Health  and  Con-
sumer  Affairs  to draw  up an opinion  on the matter, Having  regard  to the  oral  report  submitted  by the 
rapporteur,  Mr van  Campen, 
Having  regard  to the opinion  issued  by the Section 
for Protection  of the  Environment,  Public  Health 
and Consumer  Affairs  on 27 November  1979, 
Having  regard  to the discussions  at its 174th  plenary 
session  held  on 12 and  13 December  1979  (meeting 
of 12 December  1979), 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
unanimously: 
2. 4. 80 Official  Journal  of the  European  Communities No C 83/21 
PROPOSAL  FOR  A COUNCIL  DIRECTIVE  ON THE 
LIMIT  VALUES  FOR  DISCHARGES  OF ALDRIN, 
DIELDRIN  AND  ENDRIN  INTO  THE  AQUATIC 
ENVIRONMENT 
1. Introduction 
Aldrin,  dieldrin  and  endrin  are  the  first  compounds 
to be placed  in the  organohalogen  category  in list  I 
of Directive  76/464/EEC.  The  reason  why  high 
priority  has  been  given  to including  them  in list  I is 
that these  are highly  persistent,  toxic  chemicals  with 
the ability  to  accumulate  in  living  organisms. 
Because  of these  properties,  the use  of 'drins'  is with 
a few  exceptions  banned  in the Member  States.  Pro-
perties  that  are  detrimental  to the  environment  are, 
however,  necessary  for  certain  applications.  In par-
ticular,  the  high  persistence  of aldrin,  dieldrin  and 
endrin  makes  them  suitable  in places  where  other 
pesticides  are unsatisfactory.  As an example  we can 
mention  the  impregnation  of cables  and  wood  for 
underground  applications  which  require  termite-res-
istance  over  a long  period.  Furthermore,  the hazards 
of possible  substitutes  have  not  been  sufficiently 
investigated  in many  cases,  particularly  in the  case 
of the woollen  industry. 
11. General  comments 
1. The  Committee  would  like  to express  its appre-
ciation  of the  fact  that  it has  been  afforded  an 
opportunity  to comment  on  the  'drins'  Directive, 
although  consultation  is not strictly  required.  On the 
basis  of the  outline  Directive  it also  expresses  the 
hope  that  this  policy  will  be continued  in the future. 
2. The  Committee  would  have  preferred  the  Com-
mission  to have  submitted  one  Directive  dealing 
with  both  the  discharge  and  the  quality  standards. 
The procedure  which  has  been  adopted,  namely  the 
submission  of two  parallel  Directives,  may  easily 
cause  confusion.  In the  Explanatory  Memorandum 
it is stated  that:  'the  Member  States  are  obliged  to 
apply  the  limit  values  pertaining  to the  emission 
standards  for  effluent,  except  in cases  where  a 
Member  State  can  prove  that  the  quality  objectives 
established  are  being  met  throughout  the  area  which 
might  be affected  by the discharges'. 
3. The  Committee  understands  that  eight  Member 
States  have  already  opted  for  the use  of limit  values 
whilst  the  remaining  Member  State  has  come  out  in 
favour  of quality  objectives.  Although  the  introduc-
tion of parallel  Directives  offers  a compromise  solu-
tion,  the  Committee  considers  that  in future  every 
effort  must  be made  to introduce  a single,  coherent 
Directive. 4. The  Committee  supports  the  standards  pro-
posed  by the  Commission  as a total  ban  on the  pro-
duction  and  use  of 'drins'  does  not  seem  to be possi-
ble at the  present  time.  There  are  two  reasons  for 
this,  namely  that  other  pesticides  are not  satisfactory 
for certain  applications  and  that  possible  substitutes 
have  not  yet  been  adequately  examined  as regards 
their  technical  properties.  Nonetheless,  the Commit-
tee considers  that  preparations  for a total  ban  on the 
production  and  use  of 'drins'  should  be made  as 
soon  as possible. 
5. In  the  meantime  rules  must  be introduced  gov-
erning  the  manufacture  and  use  of 'drins'  and  strict 
standards  must  be imposed  in this  field,  particularly 
because  of the  extremely  toxic  nature  of these  sub-
stances.  Endeavours  must  consequently  be made  to 
come  up with  less  dangerous  alternative  products 
without  delay.  In the  wool-processing  industries  the 
use of 'drins'  seems  to be declining  already  and 
investigations  into  the  toxic  characteristics  of alter-
native  products  for use  in these  and  other  industries 
(including  agriculture)  must  be  promoted  vigo-
rously.  In the  meantime  the  existing  firms  should 
make  use  of the  best  technical  means  to tackle  the 
problem  of discharges  of'drins\ 
6. An  important  point  to which  the  Committee 
would  also  like  to draw  attention  is dilution  in the 
receiving  water.  As  far  as the  'drins'  Directive  is 
concerned,  good  dilution  seems  assured,  at least  in 
the case  of the  production  plant  because  of the 
favourable  geographical  situation.  Since,  however, 
this Directive  specifies  the first  substances  for inclu-
sion  in list  I of the  outline  Directive  76/464/EEC 
and as such  might  serve  as a model  for  other  subst-
ances,  the Committee  would  point  out  that  the  level 
of dilution  may  differ  substantially  from  place  to 
place.  Moreover,  account  must  be taken  of a possi-
ble difference  in levels  of demand  between  winter 
and summer  seasons. 
III. Specific  comments 
I. A  number  of  radical  measures  have  been 
adopted  at the  production  plant  so as to be able  to 
meet  tighter  standards  regarding  the  discharge  of 
water  containing  aldrin,  dieldrin  and/or  endrin.  The 
guideline  here  was  20 micrograms/1.  For  a discharge 
of 25 000  m?  per  day  this  means  0 5 kg aldrin,  diel-
drin and/or  endrin  per  day  or 15 kg per month  or 180 
kg per year. 
It now  looks  as if the production  plant  will  be able 
to keep  below  180  kg per  year  by around  1982. 
No C 83/22 Official  Journal  of the European  Communities 2. 4. 80 
* In  the  Committee's  view  the  calculation  of concen-
trations  of 'drins'  on the  basis  of average  monthly 
figures  provides  an accurate  and  rapid  source  of 
information  on the  level  of pollution.  If the monthly 
average  of 20 micrograms/1  is exceeded  counter-
measures  may  be taken  forthwith.  Moreover,  this 
method  of calculation  makes  it impossible  for  the 
firms  concerned  to compensate  for  high  concentra-
tions  of discharges  in one  month  by low  concentra-
tions  in the  following  months.  The  quality  of the 
environment  is thus  best  safeguarded  by the  use  of 
average  monthly  limit  values. 
2. The  requirement  that  as from  1 January  1986 
waste  water  must  not  contain  more  than  four  micro-
grams/1  of the  pesticides  in question  cannot  be met 
given  the  current  state  of technical  progress  in this 
field.  It is therefore  to be expected  that  the producer 
will have  to invoke  the clause  allowing  an extension 
if he can  prove  at least  nine  months  beforehand  that 
this requirement  cannot  be  met.  It is generally 
impossible  to prove  that  something  cannot  be done, 
but the  Committee  interprets  this  clause  as meaning 
that the producer  should  draw  up a list of the availa-
ble techniques  indicating  the  limit  values  that  can 
be achieved  with  each  of them. 
3. The  Committee  considers  that  daily  measure-
ments  should  be made  of 'drins'  concentrations  in 
the waste  water  of wool-processing  plants  just  as in 
that of the  'drins'  production  plant.  The  annual 
amount  of 'drins'  discharged  into  the waste  water  by 
wool-processing  plants  is of the  same  order  of mag-
nitude  as that  discharged  by the production  plant. 
It is particularly  in the  wool-processing  plants  that 
strenuous  efforts  should  be made  to find  alternative 
pesticides.  This  is first  of all because  the use  of toxic 
'drins'  would  appear  to be less  necessary  in these plants  than  in the  others  (those  which  treat  electric 
cables  and  wood).  Secondly,  in contrast  to the situa-
tion with  regard  to these  latter  plants,  wool-process-
ing plants  discharge  a considerable  amount  of 
'drins'  into  water. 
4. In  principle,  the  Committee  considers  that 
requiring  new  plants  to have  a zero  discharge  of the 
substances  specified  in list I is unrealistic  as there  is 
always  some  degree  of discharge,  however  small,  in 
all production  processes.  Furthermore,  this  require-
ment  is a discrimination  against  new  plants  and  it 
even  renders  the establishment  of new  plants  impos-
sible.  The  Committee  is agreeable  to a zero  dis-
charge  requirement  in the  case  of 'drins'  because  the 
present  capacity  is evidently  adequate  and  because 
this requirement  can  prevent  new  production  plants 
for these  toxic  substances  from  being  set up in the 
Community.  The  Committee  trusts,  however,  that 
the zero  discharge  requirement  will  not  be included 
in subsequent  Directives. 
PROPOSAL  FOR  A COUNCIL  DIRECTIVE  ON THE 
QUALITY  OBJECTIVES  REQUIRED  FOR  THE 
AQUATIC  ENVIRONMENT  INTO  WHICH  ALDRIN, 
DIELDRIN  AND  ENDRIN  ARE  DISCHARGED 
General  comments 
1. The  Committee  would  draw  attention  to its 
comments  on the  Directive  on limit  values  in which 
it calls  for both  of the Directives  to be combined. 
2. Although  the  Directive  on limit  values  does  not 
deal  with  discharges  of 'drins'  as a result  of agricul-
tural  usage,  the Directive  on quality  objectives  must 
take  this  usage  properly  into  account. 
Done  at Brussels,  12 December  1979. 
The Chairman 
of the Economic  and  Social  Committee 
Raffaele  VANNI 
ANNEX 
to the opinion  of the Economic  and Social  Committee 
The following  amendment  was  rejected  during  discussions: 
III. Specific  comments 
Replace  the third  paragraph  of point  I by the following: 
In the course  of continuous  production  processes  there  are inevitably  fluctuations  in the con-
centration  of "drins"  in the waste  water.  These  may  be due  to technical  factors  (variations  in 
the volume  of production,  breakdowns  in the production  process,  cleaning  work)  but also  to 
factors  beyond  the manufacturer's  control  (rain  showers). 
2. 4. 80 Official  Journal  of the European  Communities No C 83/23 
Because  of these  fluctuations  the existing  plant  cannot  meet  the standard  of 20 micrograms/1 
on the  basis  of the  monthly  mean  discharge.  The  Section  urges  therefore  that  the  20 micro-
grams/1  standard  should  apply  to the annual  mean  discharge.  Incidental  peaks  would  then  be 
offset  against  low  concentrations,  while  the  total  pollution  of the  surface  water  by "drins" 
would  still  remain  the  same.  Furthermore,  through  the  continuous  daily  monitoring  of the 
waste  water  discharged,  any  sudden  rise  in the  pesticide  concentration  would  be detected 
immediately,  so that  appropriate  action  could  be taken  at once/ 
Reason 
The reasons  for this  amendment  are contained  in the text  itself. 
Voting 
For:  20; against:  33; abstentions:  12. 
Opinion  on the proposal  for a Council  Directive  amending  Directive  77/93/EEC  on pro-
tective  measures  against  the introduction  into  the Member  States  of harmful  organisms 
of plants  or plant  products 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the Euro-
pean  Communities  No  C 209  of 21 August  1979,  page  8. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 13 November  1979  the Council  referred  the abovementioned  proposal  to the Eco-
nomic  and  Social  Committee  in accordance  with  Articles  43 and  100  of the  Treaty 
establishing  the European  Community. 
B. OPINION  OF THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  prepared  its opinion  on the above  matter  at its 
174th  plenary  session  held  in Brussels  on 12 and  13 December  1979. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  Treaty  establishing  the  Euro-
pean  Economic  Community,  and  in particular  Arti-
cles 43 and  100  thereof, 
Having  regard  to the  request  made  by the  Council 
of the  European  Communities  on 13  November 
1979  for an opinion, Having  regard  to the  decision  taken  by its Bureau 
on 20 November  1979  instructing  the  Section  for 
Agriculture  to prepare  the work  on this  matter, 
Having  regard  to the  oral  report  submitted  by the 
rapporteur,  Mr Clavel, 
Having  regard  to the opinion  issued  by the Section 
of Agriculture  at its 210th  meeting,  held  on 29 Nov-
ember  1979,