13. 11. 78 Official  Journal  of the European  Communities No C 269/35 
for action  consistent  with  the objectives  specified  in the 
Community  Environmental  Action  Programme. 
2. The  Committee  also  welcomes  the  proposal  to 
involve  non-Member  States  in research.  Such  involvement 
will undoubtedly  shed  more  light  on the problems  to be 
resolved. 
3. The  Committee  stresses  the  importance  of 
disseminating  the  results  of research  and  therefore 
wonders  if it would  not  be appropriate  to tighten  up 
Article  5 of the draft  Decision.  As it stands,  Member  States 
need  not publish  results  in full.  This  would  completely 
undermine  the whole  idea  of disseminating  information, 
which,  as the  Advisory  Committee  on Programme 
Management  has stressed  in its opinion,  is the cornerstone 
of Community  action.  The Committee  takes  the view  that 
information  should  be disseminated  in accordance  with 
the arrangements  governing  research  on sulphur  dioxide in the atmosphere  (COST  Project  61 a). The  reports 
should  be published  periodically,  even  if they  are 
incomplete.  There  might,  at the outside,  be a case  for 
restricting  the dissemination  of data  on specific  areas,  but 
there  can  be no question  of this  becoming  standard 
practice. 
4. It  is proposed  that  the 'concerted  action'  should  run 
for four  years.  Given  the complexity  and  scale  of the 
programme,  four  years  may  not be long  enough.  The 
measures  taken  by  the  Member  States  and  the 
Commission  should,  if possible,  yield  concrete  results 
during  the  programme's  lifespan,  even  if these  are 
incomplete. 
5. The  Committee  is anxious  that  the concerted  action 
should  receive  adequate  funds  to allow  it to be pursued 
with success. 
Done  at Brussels,  31 May  1978. 
The Chairman 
of the Economic  and  Social  Committee 
Basil  de FERRANTI 
Opinion  on the proposal  for a Council  Directive  amending  Directive  73/173/EEC  on the 
approximation  of Member  States'  laws,  regulations  and administrative  provisions  relating  to 
the classification,  packaging  and  labelling  of dangerous  preparations  (solvents) 
The text  referred  to the Committee  has been  published  in Official  Journal  of the European 
Communities  No  C 25 of 31 January  1978,  page  4. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 23 January  1978,  the Council  referred  the abovementioned  proposal  to the Economic  and 
Social  Committee  in accordance  with  Article  100  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 159th 
plenary  session,  held  in Brussels  on 31 May  and  1 June  1978. 
The full text  of the opinion  is as follows: 
No C 269/36 Official  Journal  of the European  Communities 13. 11. 78 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the Treaty  establishing  the European 
Economic  Community,  and  in particular  Article  100 
thereof, 
Having  regard  to the request  made  by the Council  of the 
European  Communities  on 25 January  1978  for  an 
opinion, 
Having  regard  to the decision  taken  by the Committee's 
Bureau  on 31 January  1978,  instructing  the Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  to draw  up an opinion  and a report  on 
the matter, 
Having  regard  to the opinion  issued  by the Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  on 2 and  3 May  1978, 
Having  regard  to the report  submitted  by the rapporteur, 
Mr De Grave, 
Having  regard  to the discussions  at its 159th  plenary 
session  held  on 31 May  and  1 June  1978  (meeting  of 
31 May  1978), 
Whereas  it has  been  necessary  to make  this  initial 
amendment  to the  Directive  of 4 June  1973  on the 
classification,  packaging  and  labelling  of dangerous 
preparations  (solvents)  in order  to improve  the level  of 
protection  afforded  to the public  and,  in particular,  to 
persons  who  frequently  come  into  contact  with  these 
products  in their  work  or leisure  activities; 
Whereas  the aims  of the amendment  proposed  by the 
Commission  are:  to extend  the scope  of the Directive;  to 
cover  mixtures  of solvents  with  substances  which  are not 
dangerous;  to align  regulations  on labelling  and the use 
of symbols;  to oblige  manufacturers  to notify  the 
composition  of solvent  mixtures  to centres  providing 
information  on the treatment  of poison  victims  and  to 
oblige  Member  States  to provide  the other  Member  States 
and the Commission  with  a list of these  centres, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
with no votes  against  and two  abstentions: 
The Committee  approves  the proposal  for a Directive.  It 
wishes  to make  the following  comments  on the dangerous 
substances  Directive  adopted  by the Council. 
1. The  Committee  notes  that  the basic  Directive  on 
dangerous  substances  (67/548),  the  subsequent 
amendments  to the  Directive  (73/146,  75/409,  and 
76/907),  and the Directive  on solvents  (73/173)  have  been 
properly  incorporated  into  national  law  by only  three 
Member  States,  and in the case  of two  of these  Member 
States  this  has only  been  achieved  very  recently.  These 
Directives  should  have  come  into  force  on various  dates between  1 January  1972  and  1 May  1977.  The 
Committee  deplores  this  situation  and  urges  the 
Commission  to take  steps  to ensure  that  the Member 
States  do in fact  incorporate  the 1967  Directive  and the 
subsequent  Directives  into  national  law  and  really  do 
implement  them. 
2. In  the view  of the Committee  the proposed  Directive 
is likely  to improve  the protection  of consumers  against 
possible  accidents  and health  hazards  resulting  from  the 
use of solvents.  Consideration  should  also  be given, 
however,  to those  cases  where,  out  of carelessness, 
dangerous  substances  are poured  into  or prepared  in 
containers  intended  for the preservation  or preparation  of 
foodstuffs.  To protect  people  from  the risks  to health 
arising  from  such  careless  actions,  the Committee  has also 
discussed  the  question  of addifig  warning  dyes  (for 
example,  blue)  even  when  the products  in question  are no 
longer  in their  original  packaging. 
The Committee  is nevertheless  aware  that  adding  dyes  is 
not always  possible  on account  of the use to which  certain 
solvents  are  put.  The  Committee  therefore  asks  the 
Commission  to look  at the possibilities  of: 
— marking  certain  toxic  products  with  a dye, 
— or putting  a sticker  on products  that  have  to be 
prepared  and/or  kept  in a container  other  than  that  in 
which  they  were  put originally, 
— or finding  other  ways  of avoiding  such  cases  of 
confusion  as those  mentioned  above. 
3. Many  accidents  are caused  because  the public  is not 
sufficiently  informed.  The  Committee  therefore  asks  the 
Commission  to pay particular  attention  to this  matter  in 
its information  policy  and call upon  the Member  States  to 
do the same. 
4. The  Committee  also  notes  that,  after  it has been 
adopted  by the Council,  the Directive  under  discussion 
should  come  into  effect  at the same  time  as a Commission 
Directive  extending  the Annex  to the Directive  to include 
other  categories  of solvents.  The  Committee  is not 
consulted  on the proposal  for the latter  Directive  which  is 
drawn  up under  the procedure  for the adaptation  of the 
Directive  to technical  progress.  The  Committee  would 
like this  procedure  to be accompanied  by adequate 
consultation  of all the economic  and social  interest  groups 
involved:  industry,  trade,  farmers,  trade  unions 
representing  workers  coming  into  contact  with  solvents, 
and consumers.  At least,  one of these  groups  was  in fact 
not consulted  by the Commission  on the preliminary  draft 
of the  Directive.  In future  the  Commission  should 
endeavour  to seek  the views  of all parties  concerned  on the 
preliminary  draft  document,  in line  with  the practice 
followed  in other  fields  (agricultural  products,  foodstuffs, 
cosmetics,  customs  matters,  etc.). 
5. The  Committee  wonders  whether  it would  not be 
advisable  to permit  Member  States  to require  that first  aid 
13. 11.  78 Official  Journal  of the European  Communities No C 269/37 
instructions  be set out on the labels  of toxic  products.  In 
some  cases,  immediate  measures  have  to be taken  if a 
person  is to be saved.  There  is not always  a telephone  near 
at hand  to enable  the doctor  and  the poison  treatment information  centre  to be contacted.  Precious  minutes 
could  thus  be lost.  The  Committee  asks  the Commission 
to take  a fresh  look  at this  point  with  a view  to reducing 
the harmful  consequences  of accidents  as far as is possible. 
Done  at Brussels,  31 May  1978. 
The Chairman 
of the Economic  and  Social  Committee 
Basil  de FERRANTI 
ANNEX 
to the opinion  of the Economic  and Social  Committee 
1. Rejected  amendment  1 
The following  amendment  was  rejected  during  the discussion: 
Page  3, point  5 
Replace  the present  text  by the following: 
'The Section  has been  unable  to come  to a final  decision  on whether  it is advisable  to prohibit  Member 
States  from  requiring  that first-aid  instructions  be set outon  the labels  of solvents.  The label  should  at all 
events  state  that a doctor  needs  to be consulted  in the event  of accidental  intakes  of solvents.  Of course, 
there  are cases  when  emergency  measures  are recommended  and  when  a doctor  cannot  be called 
immediately.  In view  of such  cases,  the Section  asks  the Commission  to re-examine  the question  of 
first-aid  instructions.' 
Reasons 
The text as it stands  at present  gives  the impression  that  the Section  is in favour  of first-aid  instructions 
being  given  on solvent  containers.  Members  of the Section,  however,  have  widely  differing  views  on the 
matter  and these  divergences  come  out more  clearly  in the new  version. 
Result  of the voting 
For: 6, against:  26, abstentions:  9. 
2. The  following  text of the Section  opinion  was changed  as a result  of an amendment  accepted  during  the 
discussion: 
Page  2, point  2 
Many  fatal  accidents  are caused  by incautious  actions  that  cannot  be prevented  by the labelling  on 
dangerous  substances.  A case  in point  is when  a toxic  product  is prepared  (using  powders,  granules, 
etc.) or poured  into  an old food  container.  To avoid  fatal  cases  of confusion,  some  manufacturers  colour 
their  toxic  products  with  dyes  that are not found  in drinks.  Blue  dye is an example.  Even  if such  products 
are no longer  in their  original  packaging,  they  can still warn  people  that  are dangerous.  The  Section 
asks the Commission  to look  at the possibilities  of etc. 
Result  of the voting 
For: 35, abstention:  1.