27. 11. 78 Official Journal of the European Communities No C 283/19 
labour and the public authorities in the Community, in which a new social policy can be con­
structed on the basis of solidarity and planning, with binding force for all concerned.' 
Voting 
It was decided by 38 votes to five, with eight abstentions, to delete the phrase 'with binding force for all 
concerned'. 
Opinion on the draft Council resolution on a Community action programme on safety and 
health at work 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 9 of 11 January 1978, page 2. 
A. LEGAL BASIS FOR THE OPINION 
On 4 January 1978 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 160th 
plenary session held in Brussels on 20 and 21 June 1978. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, HAS ADOPTED THE FOLLOWING OPINION 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Article 198 
thereof, 
Having regard to the request made by the Council of 
the European Communities on 5 January 1978 for an 
opinion, 
Having regard to the decision taken by its chairman on 
18 January 1978, instructing the Section for Social 
Questions to prepare an opinion and a report on the 
subject, 
Having regard to the opinion issued by the Section for 
Social Questions on 8 June 1978, 
Having regard to the report submitted by Mr Eboli, the 
rapporteur, 
Having regard to the discussions at its 160th plenary 
session held on 20 and 21 June 1978 (meeting of 21 
June 1978), unanimously: 
1. Introduction 
1.1. The Community action programme on safety and 
health at work deserves careful consideration in view of 
the importance of the issues it raises and the validity of 
its proposed objectives. 
1.2. The Commission document is based on the follow­
ing premises: 
— the number of industrial accidents and diseases 
remains high 'despite the efforts made in the 
Member States of the Community'; 
— modern technological advances are responsible for a 
growing number of occupational risks. It is thus 
No C 283/20 Official Journal of the European Communities 27. 11. 78 
essential to identify and neutralize potential hazards 
and develop 'a comprehensive preventive policy 
with regard to all occupational risks'. 
The Commission is therefore convinced that the key to 
effective accident prevention is a comprehensive ap­
proach on the technological work-environment and 
educational fronts. In other words, the prevention of 
industrial accidents must be a synthesis of many differ­
ent measures. 
1.3. The Commission believes this comprehensive 
approach must be mulit-disciplinary and involve use of 
the full armoury of techniques that are available to 
study the work environment, equipment, methods and 
organization, as well as the human element, in order to 
identify and then eliminate occupational risks. 
1.4. Although the approach was touched upon in the 
Committee's 1975 study, a clarification of certain con­
cepts is necessary before going on to the technical dis­
cussion of the proposal. 
1.5. This is done at length in the report, but a brief 
outline of the concepts is also given below. 
1.6. The concepts of 'safety at work' and 'prevention 
of occupational accidents and diseases' are closely re­
lated and sometimes even used as synonyms. But they 
nevertheless have distinct and clearly circumscribed 
meanings. 
1.7. Very roughly we may say that 'safety' exists where 
the likelihood of materialization of risks has been re­
duced to the limits of probability. 'Primary prevention' 
consists in measures to keep workers from encountering 
known hazards. 'Secondary prevention' means 
minimizing the effects of such damage when it occurs 
and taking steps to remove the hazard. 'Tertiary preven­
tion' means preventing further impairment of workers' 
psychological and physical faculties after accidents. 
1.8. Official type approval or some other testing pro­
cedure for especially dangerous equipment and machin­
ery is of central importance in ensuring safety. This type 
approval must be based on constantly updated inform­ation provided by ergonomics — information which is 
anyway vital in its own right for any strategy of safety 
and accident prevention. 
1.9. A knowledge of the phenomenon is a prerequisite 
for any strategy to combat occupational accidents and 
diseases. Up until now, this knowledge has been ob­
tained almost exclusively by traditional statistical 
methods recording the frequency and gravity of acci­
dents and diseases. 
1.10. However, these methods (see report) are of 
limited use in measuring the effective risks. Hence the 
need to introduce more sophisticated statistical tech­
niques relating to the particular work environment 
under study which, rather than recording accidents that 
have already occurred, assess the probability of acci­
dents irrespective of whether or not they produce injury 
or disease. 
1.11. It must be added that the concepts of safety and 
prevention need to be more widely applied in industry 
than has been the case in the past. An autonomous 
practical safety policy for industry, with its own charac­
teristic and specific structure, is essential in order to 
bring out the specific features of this sector. 
1.12. The ideas of the Commission's action pro­
gramme should be put into effect by instruments which 
meet the concrete requirements of safety at work. These 
instruments must build on existing knowledge and 
experience, and provide yardsticks and a flow of infor­
mation making it possible to take action on declarations 
of intent (which are sometimes little more than lip-
service) and ensure that human suffering and tragedy is 
no longer a part of 'labour costs'. Above all, it must be 
emphasized that the prime objective is to uphold the 
human dignity of the workers, vis-a-vis the machinery 
and mechanisms of production and their effects on 
society. 
2. General remarks on the document 
2.1. As noted, the Commission document bases the 
case for Community action on the fact that despite 
27. 11. 78 Official Journal of the European Communities No C 283/21 
some improvement in work safety, occupational ac­
cident and disease rates are still alarmingly high. 
2.2. A dynamic, effective and coordinated Community 
programme could facilitate the continuous exchange of 
practical experience, objective appraisal of the success 
of individual programmes and development of a com­
mon strategy for reaching common practical ends with 
appropriate legal backing. 
2.3. The new approach of a comprehensive, interdisci­
plinary policy of accident prevention may, in the Sec­
tion's opinion, be the answer to the unsatisfactory prog­
ress made in accident prevention in spite of the 
measures which have been in force in the Member 
States for a considerable time. 
2.4. Despite the success claimed for previous accident 
prevention measures on the basis of a temporary decline 
in accident rate, serious structural problems nevertheless 
remain in accident prevention which give no room for 
complacency. These require constant and broad-based 
action, with no single technology or sector being given 
priority, and with constant collaboration between plan­
ners, government, law-makers, scientists and the two 
sides of industry. 
2.5. The Community programme should complement 
rather than replace the national programmes and should 
be implemented to the extent allowed by funds and 
machinery. It is considered to have three general objec­
tives ((a) improvement of the working environment 
from the accident-prevention, health, psychological and 
social points of view, (b) full knowledge of the causes of 
accidents at work, and (c) analysis of human behaviour) 
and cover six practical lines of research. It will have to 
seek practical solutions to a large number of complex 
problems on the basis of the approach outlined in the 
report. 
2.6. In particular, the programme must be closely 
oriented (and if necessary promptly adjusted as it is 
being implemented to keep it on course) to the under­
lying philosophy and strategy, which centres on 
thorough, empirical knowledge of the causes of indus-
trical accidents and disease. 2.7. Particular importance attaches in this context to 
obtaining comparable statistics and to investigation of 
the practicality of constructing models for measuring 
degrees of hazard in particular undertakings and indus­
tries. 
2.8. Some further features in the programme require 
emphasizing: 
— constant collaboration with the ad hoc advisory 
committee, 
— the crucial role and participation of the two sides on 
industry, 
— the special responsibility of employers for applying 
safety regulations. The workers should be involved 
in drawing up the standards and should monitor 
their implementation, 
— the education campaign which needs to be mounted 
in liaison with the trade unions, 
— the attitude of employers to health and safety, 
which may be influenced by the cost of safety 
measures, 
— the binding nature of the legal instruments enacted 
under the Community programme for the Member 
States and the definition of political monitoring 
procedures and possible penalties, 
— the specific prevention problems of particular indus­
tries and undertakings, with special reference to 
hazards resulting from the use of a number of new 
technologies and substances whose safety has not 
been sufficiently tested, 
the value and relevance of the concept of 'permiss­
ible exposure levels', in view of the advances in 
scientific knowledge and the recent study made of 
the subject by the International Labour Office, 
the need for cooperation between the International 
Labour Office and the European Foundation for the 
Improvement of the Environment and Living and 
Working Conditions, which ought to assign due 
importance to safety and accident prevention in its 
work, the need to step up the exchange of infor­
mation on these topics, with particular reference to 
possible ways of testing the effectiveness of preven­
tion measures, 
No C 283/22 Official Journal of the European Communities 27. 11. 78 
— investigation of the social, economic, human and 
psychological consequences of accidents at work 
and industrial disease, 
— investigation of the problem of rehabilitation. 
2.9. The achievement of the programme's goals will 
depend on the way in which the problems indicated 
above are tackled as well, of course, as on the capability 
and will to apply fully the all-round prevention prin­
ciples on which it is based. 
2.10. The Section's opinion of the objectives of the 
proposed programme and of the proposed six inter­
disciplinary project areas in particular is broadly 
favourable. However, it is felt that the planned projects 
should not be given differing degrees of priority on the 
basis of the relative importance attached to specific 
technical aspects or, in more general terms, to particular 
aspects of working conditions. In view of the all-round 
approach to prevention, a project's order in the list 
should be regarded as irrelevant, although it may be 
taken as a functional indication for the purposes of the 
allocation of the funds at the Commission's disposal. 
2.11. Finally, we would draw attention to the need for 
a prompt response to the Community programmes on 
the part of the Member States, so that there is later not 
a wide gap between Community measures and Direc­
tives and actual practice. 
3. Specific comments on the points of the Community 
programme on safety and health at work 
3.1, point 1 
Incorporation on safety aspects into the various stages 
of design, production and operation 
3.1.1. We have no fundamental observations to make 
on the section describing the aims of this point of the 
programme, as it mainly consists of discussion of issues 
relating to the contents of this point. In general safety 
must be given priority in this incorporation model. 
3.1.2. More explicit reference should perhaps be made, 
however, to the idea of safety approval/testing of plant 
and machinery as a key item in the integrated safety 
strategy. This safety approval/testing would be the 
application of ergonomic research. 
3.1.3. When introducing safety approval/testing sec­
toral priorities must be set up according to the degree of danger in the particular industry and the feasibility of 
such a procedure. 
3.1.4. The need for ergonomic research on technologi­
cal innovations is to be stressed. However, the same 
amount of prominence should be given to 'remedial' 
ergonomics in relation to plant and machinery which 
has passed the planning stage, or has already been in­
stalled, without full regard to the need to adapt plant 
and machinery to man. 
3.1.5. With regard to the 'contents' of point 1, it 
would be wise to select the priorities not only on the 
basis of 'the wishes expressed or guidance given by re­
levant bodies, who should above all bear in mind prac­
tical considerations', but also on the basis of a classifi­
cation of subjects according to their importance as 
causes of industrial accidents and disease. 
3.1.6. The priorities the Commission has selected 
appear to the Section to be a reasonable choice, though 
of course, .bearing in mind what we have said above, 
they do not cover everything and therefore must be seen 
as a pragmatic starting point. 
3.2, point 2 
Determination of exposure limits for workers with 
regard to pollutants and harmful substances present or 
likely to be present at the workplace 
3.2.1. We endorse what is said in the 'aims' of point 2 
of the programme. However, we would like to make a 
point about the term 'exposure limit', since the Com­
mission's main aim here is to align the concepts and 
terminology used. At its 63rd session (1977) the Inter­
national Labour Conference adopted Convention No 
148 and recommendation No 156 on the working en­
vironments for which the general expression 'exposure 
limits' was to be used. 
3.2.2. This term replaces the old terms 'maximum 
allowable concentration', 'acceptable exposure limits', 
etc., without going into detail about 'ceilings' or 'weigh­
ted' values. There were specific reasons for dropping the 
epithets 'allowable' and 'acceptable'. The former ap­
pears to imply some administrative or legal sanction, 
which is not always the case, and the latter appears to 
refer to an established biological tolerance level which, 
however, cannot be generalized for all workers. These 
reasons are set out in ILQ docuifient MELE/1977/V. 
3.2.3. The Commission document, after using the 
correct term 'exposure limits' in the heading of this 
point, unfortunately reverts to using the adjective 'ac­
ceptable' with it in the text of the 'aims' section. 
27. 11. 78 Official Journal of the European Communities No C 283/23 
3.2.4. With regard to the 'contents' of point 2, we 
would reiterate our view that the chosen priorities con­
stitute a tentative list; the point about use of words like 
'allowable' in relation to exposure limits also applies. 
3.2.5. In view of the fact that individual Directives 
cannot be issued on all dangerous substances and all 
physical agents potentially presenting a hazard, the 
criteria for the selection of subjects for such Directives 
must take account of the intrinsic danger of the sub­
stances and their form and frequency of use. 
3.3, Point 3 
More extensive monitoring of workers' safety and 
health 
3.3.1. The section on the aims of point 3 lists the 
various operations which go to make up an effective 
system of monitoring of workers' health and safety. 
3.3.2. The list gives a sufficiently analytical, and also 
comprehensive account of the complex subject of 
monitoring, although it should be emphasized that each 
operation needs to be seen as an integral part of the 
overall scheme, since the information obtained from 
each operation links up with that from others. 
Harmonization of monitoring should of course not be 
confused with standardization of the methods used in 
the various operations. These form part of the contents 
of points 1 and 2 of the programme. 
3.3.3. Point 3 raises the difficult issue of the role of the 
staff carrying out monitoring work. 
3.3.4. Some ideas for this could perhaps be taken from 
the Community-wide system for monitoring radiation 
hazards, though without affecting the responsibility of 
employers and the need for participation of the workers 
according to specified forms and procedures. The radia­
tion monitoring standards should also lay down a cer­
tain legal structure for the staff. 
3.3.5. With regard to the 'contents' of point 3, we 
would stress the importance of biological indicators for 
monitoring and hope that the Commission will propose 
more and more of these. 3.3.6. The key figure in the monitoring of occu­
pational health is the industrial medical officer. We 
would stress the importance of correct training of these 
staff, who could of course work in units serving several 
firms. Specialists in industrial medicine should be used. 
However they should operate as an integral part of their 
country's health service (while maintaining their pro­
fessional independence), in order to ensure proper coor­
dination of all public health services. The training pro­
grammes for industrial medical officers therefore need to 
be expanded and incentives introduced to encourage 
new recruits into the profession. 
3.3.7. Only the approach to inspection needs to be a 
uniform Community one. Within this common 
framework different practical arrangements can be 
permitted in the various Member States. However, it is 
essential that the work should be done by a fully com­
petent public agency adequately staffed in relation both 
to the workload and the type of inspections carried out. 
3.3.8. On 'special monitoring', we would point out 
that the greatest possible amount of facilities and per­
sonnel should be assigned to this work. 
3.4, point 4 
Accident and disease aetiology and assessment of risks 
connected with work 
3.4.1. Statistics like those generally collected for indus­
trial accidents and disease clearly cannot, because of 
their intrinsic limitations, solve the problem of the 
aetiology of industrial accidents and disease or the 
assessment of the risks presented by particular jobs. 
3.4.2. Nevertheless, it is essential to standardize the 
criteria used in the collection and compilation of data 
on industrial accidents, by agreeing a precise definition 
of accident and precise rules on the cases to be con­
sidered, the subsets of data which are to be aggregated, 
the numerical expression of the degree of exposure to a 
hazard, and procedures for constructing the various 
indices. 
3.4.3. Industrial disease poses a special problem owing 
to the considerable difficulty of establishing the 
aqtiological-pathogenetic relationship between exposure 
to the hazard and development of the disease. However, 
No C 283/24 Official Journal of the European Communities 27. 11. 78 
this is no excuse for not pressing on with alignment of 
the criteria on which statistics for industrial disease are 
compiled and, eventually, the cataloguing of those 
criteria. 
3.4.4. Conventional accident and disease statistics can, 
if correctly compiled, provide hard information on a 
'macrosystem'. For 'microsystems', more sophisticated 
statistical techniques have to be used which enable the 
information derived from the incidence of accidents and 
disease to be related to the concept of probability and, 
hence, of measurement of risk. 
3.5, point 5 
Coordination and promotion of research on occu­
pational safety and health 
3.5.1. The justification of point 5 of the programme is 
obvious. Any advance in prevention and safety must 
have a rigorous scientific basis in research which is 
often too complex to be undertaken by single 
laboratories or even single Member States. 
3.5.2. The aims and contents of this point, therefore, 
must be supported. It is to be hoped that this work will 
help to bridge the gaps in technology, organization, 
knowledge and application which are often responsible 
for poor records of accidents and industrial disease. 
3.5.3. Although ranging over various fields, the re­
search must relate to a general framework of reference, 
so that the results converge on the primary goal of the 
programme. 
3.5.4. The Committee recalls its previous comments on 
the coordination and promotion of research (para-
Done at Brussels, 21 June 1978. graph 1.2. of the opinion on vinyl chloride monomer of 
29 September 1977). In this opinion, the Committee 
proposed that consideration be given to establishing: (a) 
a European agency which would investigate dangers 
associated with industrial materials, prior to their use in 
industry; (b) data designed to record the effects of 
dangerous materials. 
3.6, point 6 
Development of safety and health consciousness by 
means of education and training 
3.6.1. Point 6 of the programme is a particularly in­
teresting one as it has been called the logical premise of 
the other points. 
3.6.2. What the Commission does here clearly cannot 
take the place of work currently being carried out or to 
be undertaken at the later stage by the Member States. 
However, the programme which is to get under way 
later this year will undoubtedly provide a stimulus for 
work on this important aspect of overall prevention. 
3.6.3. In this connection the Dublin-based European 
Foundation for the Improvement of Living and Work­
ing Conditions must play an important role as must the 
Berlin-based Vocational Training Centre in certain 
cases. To this end the requisite funds should be pro­
vided for education and training. 
3.6.4. Finally, we would stress that education and 
training in safety needs the active support of all sections 
of the population and must involve all sides of industry, 
from management downwards, and that it must be first 
introduced into the curriculum of the first years at 
school, and gradually be extended throughout the edu­
cation system including at post-university level. 
The Chairman 
of the Economic and Social Committee 
Basil de FERRANTI 
27. 11. 78 Official Journal of the European Communities No C 283/25 
ANNEX 
to the opinion of the Economic and Social Committee 
The following parts of the Section's opinion were altered as a result of the adoption of amendments at 
the plenary session. 
Page 3, paragraph 1.8 
'Official type-approval of equipment and machinery is of central importance in ensuring safety. This 
type-approval must be based on constantly updated information provided by ergonomics — infor­
mation which is anyway vital in its own right for any strategy of safety and accident prevention.' 
Voting 
For: 18, against: 16, abstentions : 6. 
Page 6, the third indent of paragraph 2.8 
'— the responsibility of the employer and the worker in applying safety regulations.' 
Voting 
For: 44, against: 2, abstentions : 7. 
Page 13, paragraph 3.6.3 
'A specific allocation of money for this work, administered in liaison with the European Foundation 
in Dublin, might be a useful measure.' 
Voting 
Unanimous. 
Opinion on the draft Council recommendation of 8 December 1977 to the Member States 
regarding methods of evaluating the cost of pollution control to industry 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 10 of 12 January 1978, page 6. 
A. LEGAL BASIS FOR THE OPINION 
On 5 January 1978 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.