Opinion of the Committee of the Regions on the 'Communication from the Commission accompanied by a proposal for a European Parliament and Council Decision adopting a programme of Community action 1999-2003 on pollution-related diseases in the context of the framework for action in the field of public health` (98/C 64/16)

THE COMMITTEE OF THE REGIONS,

having regard to the Communication from the Commission accompanied by a proposal for a European Parliament and Council decision adopting a programme of Community action 1999-2003 on pollution-related diseases in the context of the framework for action in the field of public health (COM(97) 266 final, COD 97/0153) ();

having regard to the decision taken by the Council on 27 June 1997, under Article 129 and 198c, first paragraph of the Treaty establishing the European Community, to consult the Committee of the Regions on the matter;

having regard to its decision of 8 March 1996 to direct Commission 8 - Economic and Social Cohesion, Social Policy and Public Health - to draw up the opinion;

having regard to the draft opinion (CdR 287/97 rev.) adopted by Commission 8 on 24 September 1997 (rapporteur: Mrs Bolger),

unanimously adopted the following opinion at its 20th plenary session on 19 and 20 November 1997 (meeting of 20 November).

1. Introduction

The Committee of the Regions (COR) welcomes this opportunity to comment on the Commission's proposed action programme on pollution-related diseases in the context of the framework for action in the field of public health.

It is most timely that the Commission, European Parliament and Council should focus their attention on the issue of environmental pollution, as the diseases associated with that pollution are escalating. The Committee of the Regions acknowledges the stringent efforts made by the Commission, European Parliament and Council in tackling the problems associated with environmental pollution.

When the environment is discussed it is usually in the context of environmental risks to public health. Threats to health, especially children's health have provoked an apparently strong reaction from potential victims. Given the increase in the proliferation of pollution-related diseases within the Union, it is only correct than an action programme should be devised and implemented with a view to minimizing the risk to the citizen and children in particular.

2. Pollution-related diseases

a) Definition of pollution-related diseases

For the purpose of this opinion, the term 'pollution-related diseases` shall be taken to mean, those diseases which are caused, provoked or aggravated by environmental pollution. In the context of public health, 'pollution` can be defined as an environmental imbalance or disturbance, man made or naturally occurring, which can have an adverse effect on human health. These pollutants range from water contamination and chemical emissions to the air and soil's physical corruption. Due to the broad nature of the field of environmental pollution, the Commission has correctly taken a somewhat focused approach when drawing up the Programme for Community Action 1999-2003 on pollution-related diseases. The Commission has chosen to concentrate its resources on health problems associated with air pollution. Air issues include toxic pollutants, acid rain, urban smog and smoke.

b) Proliferation of pollution-related diseases

Over the past number of decades, the increase in urbanization, industrialization and rapid population growth has led to an increase in the prevalence and concentration of pollutants. Communities have historically grown up around the workplace and in the recent past the workplace was often the source and cause of air pollution. While diseases arising from water pollution and poor hygiene have to a large extent been alleviated, their place has been taken by diseases which are caused by neglectful lifestyles and exposure to harmful air pollutants.

The gravity of the present situation is best illustrated by briefly looking at the extent of morbidity and mortality caused by pollutants which have attacked the respiratory system. It has been suggested that one-third of the world's health burden is inflicted by diseases that could be abated by focusing on the complex relationship between environmental and other factors, in particular the combating of unclean air.

A direct correlation exists between air pollution and the prevalence of respiratory diseases. One such respiratory disease is asthma. Asthma is an allergic disease of the human airways. Air passages are known to become inflamed in response to a number of environmental factors. Allergens, when combined with man-made air pollutants, are probably the most important of these and a close link between exposure and development of asthma has been demonstrated. Other environmental factors such as tobacco exposure, viruses and outdoor pollutants have all been demonstrated to aggravate individuals who have asthma.

The morbidity rate due to asthma increased by some 27 % between 1974 and 1984 in the European Community. The trend among children was even more worrying with the doubling of the prevalence of the disease in children over the same period. In Ireland, a relatively unpolluted country, 14 % of the population suffer from asthma and asthma accounts for more than one hundred deaths in Ireland each year. This figure, like that in many more Union Member States, is on the increase.

Chronic Obstructive Pulmonary Disease (COPD), of which the most common forms are bronchitis and emphysema, and allergies have spiralled over the last twenty years, thus causing a major health problem, especially in urban areas. Since the 1970s, the incidence of allergic rhinitis in both adults and children has doubled in a number of Community states. It is estimated that prevalence rates in the Community as a whole range from 2 % to 10 %.

3. Threats

a) Outdoor air pollution

The nature of outdoor air pollution has changed dramatically. Whereas once outdoor air pollution stemmed from the burning of fossil fuels, it is now clearly related to outdoor allergens and vehicle emissions.

Outdoor environmental allergens such as pollen and animal dander cause considerable discomfort to many over the course of the summer season. Pollen allergy, in particular, is rife contributing to allergic symptoms, like conjunctivitis and rhinitis. The level of pollen in the atmosphere has not increased over the years. It can be reasonably assumed therefore, that the rapid increase in allergies stems from a depletion or weakening of the body's defense system.

Vehicle emissions are rich in oxides of nitrogen, which under certain circumstances will produce ozone. However, while the public is well informed on the continual erosion of the ozone layer and the harmful effects associated with global warming, the more directly relevant causes of allergic and respiratory diseases are ignored to a considerable degree.

It may take a unified global response to circumvent the damage already inflicted on the ozone layer. In contrast, each citizen can affect and influence their indoor air-quality and lifestyle quite easily.

b) Indoor pollution

Indoor air pollution is considered to play a significant role in the proliferation of allergies. Indoor air quality is influenced by a wide range of elements. Radon concentrations, tobacco smoke, unvented kerosene heaters and dust particles are all contributing factors to the causation of indoor air pollution. Presently, there is the fear that individual air pollutants, although damaging, are not as worrying as a combinatory effect of air pollutants. While the human body may be able to fend off singular air pollutants, it cannot ward off a cocktail of pollutants.

One of the most harmful forms of air pollution is cigarette smoking and, while to smoke or not to smoke is a personal decision, it should certainly be public policy that nobody should smoke to pollute the air of their fellow citizens in public buildings or on public transport.

Society has started to take a mature approach to smoking. All Union States have introduced legislation prohibiting smoking in many public areas. A greater effort has been made at national and regional level to inform the public of the harmful effects associated with smoking. It is imperative that the progress made in this domain should be built on with continued research into the relationship between smoking and cancer and other respiratory diseases. Although smoking falls entirely under the aegis of the cancer programme, any relevant information obtained during the proposed related diseases action programme should be transferable.

4. The indoor environment

The nature of the indoor environment has changed in recent years. Much of Europe's population now lives in tightly sealed buildings with double glazing and no chimneys. Central heating is common, maintaining high temperatures and low humidity. New 'energy efficient` housing is designed to keep the weather out, and consequentially, to keep pollutants in. The house dust mite, in Greek 'dermatoghanid`, meaning 'skin-eating spider`, thrives in such conditions and reproduces at alarming speeds. Wall to wall carpeting, thick upholstery and bedding also help to harbour the mite.

In such an environment, young children tend to increasingly become hyper-sensitive. A child's immune system is not given time to develop as it faces a barrage of attacks from its earliest days in the homestead. Furthermore, parental care may have overstepped the limits of what is actually beneficial for the child. Often in attempting to protect the child from the elements, parents safeguard a child to an excessive degree, thus rendering the child's immune system useless. It is a question of balancing a child's exposure to the environment and protection from the elements.

A greater awareness of the hidden dangers, such as droppings of house dust mites, fungal spores and animal dander may go a long way towards circumventing many harmful allergies. As the European Commission correctly suggests, information campaigns should be embarked upon as a means of notifying the general public of the deleterious effects associated with indoor and outdoor air pollution.

In the workplace one of the most common forms of pollution emanates from asbestos materials. For some time, it has been recognized that asbestos can be harmful to human health. Exposure to high levels of asbestos particles in the atmosphere can cause asbestosis, pleural effects, bronchial carcinoma and mesothelioma. These diseases have been observed in workers exposed to asbestos by reason of their occupation.

The Commission, Parliament and Council are to be commended on their introduction of legislation in 1983 (83/447) protecting workers from exposure to asbestos. It is imperative, however, that the provisions made for the workplace are replicated in domestic housing. Many houses built in the 1950s and 1960s contain asbestos piping though which water flows. The potential for contamination is too great and the Committee of the Regions fully concurs with the Commission's view that all exposure to asbestos should be reduced as much as possible, using the best available technology without incurring excessive costs.

While the Commission's proposed action programme does not specifically refer to the eradication of diseases associated with asbestos, the Committee of the Regions calls on the Commission to examine this topic, in some detail, at a future date.

5. The prevention of pollution-related diseases

The decision to what extent we will control our air pollution and pay the necessary costs is a political one and includes the concept of 'acceptable risk`. The work carried out under the Fourth Action Programme (Research and Technological Development) in regard to the identification of atmospheric pollutants must be built on and brought to a new stage. It is only by fully understanding the causation of respiratory diseases that the problem can begin to be tackled.

The Commission, having taken on board the research supported by the Community and Community legislation in the environmental sector, has, in the proposal to combat pollution-related diseases, devised a three-pronged strategy. First, reducing the amount of pollutants by taking action at their source; second, acting to limit the amount of people's exposure to them; and third, mitigating the effects on individuals who are exposed to them.

While it may appear necessary to reduce the levels of all pollutants, it is neither feasible nor cost-effective. A more realistic approach to the task of reducing air pollutants is to focus a campaign on the individual. A citizen may prove willing and able to change their personal behaviour, thus complementing the legislative environmental framework already laid down in relation to industrial actors or car manufacturers. Changes to modes of transport, fuel users and vehicle emission control technology should be specifically targeted and promoted as a priority, in order to progress more rapidly in making widely beneficial improvements to public health.

6. The quest for information

As mentioned in the Commission's communication concerning the Community Action Programme on pollution-related diseases, a prerequisite for undertaking such preventive action is the collection of appropriate statistical information on the causation and the extent of the problems. Data exists concerning exposure to pollutants in many Member States. However, it has been difficult to determine the precise relationship between exposure to pollutants and the long-term health of the citizen.

In order to ascertain accurate data, an infant's exposure to pollutants must be monitored from its earliest days to a stage at which it can be considered to be developed and mature. This analysis can be carried out with the use of personal monitors, which are practically weightless. An analysis of personal exposure to pollutants depends on the air pollutant concentrations that are present in the locations the person moves through, as well as the time spent in each location. This necessitates the constant monitoring of exposure. A modelling of human exposure to air pollution cannot take place in the absence of comprehensive statistical analysis.

The establishment of the European Environmental Agency has facilitated the collection of some of the statistical data referred to above. It is imperative that this agency should continue to work closely with national and regional authorities in compiling information on air and water pollution. It is often at the national and regional level that the most relevant problems related to air pollution can be identified. Thus, it is expedient to bear in mind the principle of subsidiarity when drawing up an action plan to combat pollution-related diseases in the Union. As the Commission states, Community action shall only be taken in this field if by reason of its scale or effects the proposed action can be better achieved by the Community, compared to the action at national level. Furthermore, Community action must be proportional to the proposed objectives.

7. Community action against pollution-related diseases

As the prevention of respiratory diseases and allergies falls outside the ambit of other Community programmes, there is evidence that respiratory diseases and allergies present a health risk and result in morbidity and/or mortality, the Commission has wisely decided to focus its measures within the Commission's proposal on the curtailment of these diseases.

The Commission has outlined three broad objectives which are aimed at reducing the rapid proliferation of pollution-related diseases. The first of these objectives involves the improvement of information on pollution-related diseases. Once a comprehensive list of statistical data has been compiled, it may be possible to draw causal links between environmental pollutants and diseases.

The information gleaned from this statistical data will allow expert and citizen alike a clearer picture of the risks and the solutions to the problems associated with environmental pollution.

Secondly, the Commission contends that an increased level of understanding in relation to pollution-related diseases will enable both Community and national bodies to implement a coherent risk management strategy. The public perception of risks to public health are often misinformed and consequently lead to unnecessary public concern. While the public may preoccupy their thoughts with the associated dangers of electro-magnetic fields, salmonella or BSE, potentially more deadly pollutants lie hidden in the homestead. Daily low-level exposure to thousands of contaminants, in dosages too small to detect, take a dramatic toll on our immune system defences. Moreover, the public have continually underestimated smoking's contribution to the causation of respiratory and cardio-vascular diseases.

Information campaigns are required to inform citizens of the hidden dangers which lurk in domestic housing. Dust mites and bacteria thrive in the absence of ventilation. Winter temperatures necessitate insulation and heating. However, when the house or workplace is vacant, even for short periods of time, rooms should be well ventilated. Just as humans need to breathe, walls, ceilings and floors require an exchange of air. Information campaigns must encourage citizens to ventilate both houses and the workplace. Local and regional authorities' input into information campaigns is vital, as they have a key role to play in providing public information and changing public attitudes.

The third strand of the Commission's strategy in dealing with pollution-related diseases concerns activities which would directly reduce the prevalence and/or incidence of respiratory and allergic diseases. It is envisaged that actions would be devised to reinforce and link information campaigns. In addition, resources would be channelled into the promotion of best practices. In developing a European strategy, the Commission should be encouraged to examine best practice in each Member State and to channel resources into the promotion of best practices.

8. The budget

The Committee of the Regions, while understanding the current financial perspective, calls on the Commission to increase the proposed allocation of expenditure under the Commission's proposal on pollution-related diseases post 1999. The Commission's proposed programme on pollution-related diseases has been allocated ECU 1,3 million for the year 1999, in keeping with current financial perspectives. The Commission has recommended that the financial framework for the final four years of the programme (2000-2003) shall be determined in detail after the establishment of the future financial perspectives. It is the opinion of the Committee of the Regions that expenditure under this programme would increase by a sizeable amount post 1999. To make a telling contribution in the fight against pollution-related diseases, substantial funding is required. Information is invaluable and should not be circumscribed simply because of present financial constraints.

9. Concluding remarks

The Committee of the Regions would like to pay tribute to the Commission's innovative and encouraging work carried out to date in the realm of environmental pollution. This process has been complemented by Council and Parliament's interest and support.

The task of alleviating problems associated with environmental pollution is challenging but certainly not insurmountable. The clear priority of the Commission's proposed action on pollution-related diseases is to reduce the suffering inflicted on citizens generally, and children in particular, by environmental pollution. In addition, the socio-economic benefits accruing from a reduction in the prevalence of pollution-related diseases are not insignificant. Many days of work are lost each year throughout the Union as a result of pollution-related diseases. Moreover, the burden placed on a nation's health care system is considerable.

The Committee of the Regions lends its support to the Commission's proposed action programme on pollution-related diseases. It is imperative, however, that sufficient finance be set aside to enable regional, national and Community actors to play a significant role in the battle against pollution-related diseases.

Brussels, 20 November 1997.

The Chairman of the Committee of the Regions

Pasqual MARAGALL i MIRA

() OJ C 214, 16.7.1997, p. 7.