17. 11. 75 Official  Journal  of the European  Communities No C 263/37 
environment.  Achievement  of  the  proposal's 
objective  is vital  if progress  is to be made  towards 
implementing  practical  programmes  for safeguarding 
the environment. 
2. In  this  connection,  the Committee  asks  whether 
it would  not  be  worth  putting  stress  on 
environmental  problems  at  the  workplace.  In 
general,  as experience  has  shown,  these  problems 
have  certain  pollution  aspects  which  affect  the 
external  environment.  Emphasis  on this  aspect  would 
serve  the  dual  purpose  of  enabling  a large 
proportion  of external  pollution  to be eliminated 
more  easily  at source,  and  providing  data  on 
probable  trends  in this  type  of pollution. 
3. Furthermore,  the Committee  considers  that  the 
dates  should  be specified  on which  the Commission 
foresees  publishing  the  inventory,  which  is to be 
based  on information  received  from  the  Member 
States.  At all events  it is to be hoped  that  the time 
lag between  receipt  of data  and  publication  of the 
inventory  will  be as short  as possible,  in order  to guarantee  that  the  published  information  is of 
maximum  practical  benefit. 
4. 'Medicine'  and  'toxicology'  are  disciplines  of 
relevance  to  environmental  problems  and  are 
referred  to in the  explanatory  memorandum;  the 
Committee  would  suggest  that  they  be specifically 
mentioned  on  page  20  of the  Annex  (referral 
centres). 
5. Lastly,  the  Committee  points  out  that  the 
Member  States  will  probably  not  be able  to forward 
the first  questionnaire  to the  Commission  by the 
specified  date,  since  at best  the  Council  will  be 
unable  to enact  the Decision  until  late  in 1975. 
Done  at Brussels,  28 May  1975. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Directive  on the approximation  of the laws  of 
the Member  States  relating  to safety  belts  and  restraint  systems  of motor  vehicles 
The text  referred  to the Committee  was  published  in Official  Journal  of the European 
Communities  No  C 82 of 14 April  1975,  page  27. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 14 January  1975,  the Council  referred  the abovementioned  proposal  to the Economic 
and Social  Committee  under  Article  100  of the  Treaty  establishing  the  European 
Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 130th  plenary  session, 
held in Brussels  on 28 and  29 May  1975. 
The Opinion  is published  below. 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the referral  on 16 January  1975,  by 
the Council  of the  European  Communities,  of the 
proposal  for  a  Council  Directive  on  the 
approximation  of the  laws  of the  Member  States relating  to safety  belts  and  restraint  systems  of motor 
vehicles; 
Having  regard  to  Article  100  of  the  Treaty 
establishing  the European  Economic  Community; 
No C 263/38 Official  Journal  of the European  Communities 17.11.  75 
Having  regard  to the decision  taken  by its Bureau  on 
28 January  1975,  instructing  the Section  for Industry, 
Commerce,  Crafts  and  Services  to draw  up  an 
Opinion  and  report  on the matter; 
"Having  regard  to the  Opinion  adopted  by  the 
Section  for Industry,  Commerce,  Crafts  and  Services 
at its meeting  on 7 May  1975; 
Having  regard  to the  report  submitted  by  the 
Rapporteur,  Mr Masprone,  and  the  Co-Rapporteur, 
Mr De Grave; 
Having  regard  to the  discussions  at its meeting  on 
28 May  1975  (130th  plenary  session  of 28 and  29 
May  1975); 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a unanimous  vote: 
1. The  Economic  and  Social  Committee  approves 
the proposal,  subject  to the following  comments: 
2. Scope  of the draft  Directive 
2.1. The  draft  Directive  applies  to safety  belts  and 
restraint  systems  which  are designed  for installation 
in motor  vehicles  of category  Ml and  are  intended 
for separate  use by adult  occupants. 
2.2. The  Committee  deplores  the  fact  that  the 
Commissions  has  only  laid  down  rules  for  belts 
designed  for adults,  even  in the  case  of rear  safety 
belts,  which  are  very  often  used  by  children. 
Furthermore  some  Member  States  have  introduced, 
or are  about  to introduce,  regulations  to the  effect 
that children  travelling  in motor  vehicles  must 
occupy  the rear  seats. 
2.3. The  Committee  takes  note  of the Commission 
representative's  statement  that  it was  impossible  to 
devise  at short  notice  methods  applicable  to 
children's  safety  belts  and  to dual-purpose  safety 
belts.  Consequently  the  Committee  finds  that  the 
provisions  of this  Directive  are  not  sufficient  to 
eliminate  the technical  barriers  in the field  of safety 
belts  in general.  It also  considers  that  the  present 
Directive  must  at all events  not  entail  systematic 
fitting  to rear  seats  of safety  belts  designed  for 
adults,  even  if there  should  be  a delay  in 
harmonizing  other  restraint  systems. 
2.4. The  Committee  therefore  asks  the 
Commission  to supplement  its proposal  as swiftly  as 
possible  by  Directives  on  restraint  systems  for 
children  or by a Directive  on dual-purpose  systems. 3. Three-point  safety  belts  and  retractors 
3.1. The  Committee  welcomes  the  stipulation  of 
the draft  Directive  that  the side  front  seats  of motor 
vehicles  must  be fitted  with  three-point  safety  belts. 
Next  to harness  belts,  three-point  belts  give  the best 
distribution  over  the upper  body  of the deceleration 
force  produced  by an impact. 
3.2. The  Committee  considers  that  mandatory 
installation  of a three-point  safety  belt  or restraint 
system  for  the  centre  front  seat  is extremely 
questionable  from  the  point  of  view  of 
cost-effectiveness  since  this  seat  is only  used 
infrequently.  According  to  the  explanatory 
memorandum,  fewer  than  1 °/o of those  killed  or 
injured  were  occupying  centre  front  seats,  and  only  a 
very small  number  of vehicles  have  such  seats.  What 
is more  an expensive,  complex  device  would  be 
required  for  the  upper  anchorage  and  its 
development  would  take  considerable  time  and 
effort.  Other  difficulties  would  arise  in connection 
with  the driver's  visibility  to the side  and  rear,  since 
this can  be impaired  by any  structure  in the upper 
part of the vehicle,  or by the attachment  of the safety 
belt to its upper  anchorage. 
3.3. The  Committee  therefore  considers  that,  in 
view  of these  technical  difficulties,  the centre  front 
seat could  be fitted  with  a two-point  lap belt. 
3.4. The  proposal  makes  it obligatory  for  side 
front  seats  to be fitted  with  restraining  devices  which 
incorporate  retractors  and  are  so designed  that  the 
belt can  be put on and  buckled  and  unbuckled  with 
one hand.  The  Committee  would  point  out  that  this 
type of device  boosts  the wearing  of safety  belts  to a 
large  degree  in towns  and  on  the  open  road, 
resulting  in a considerable  reduction  in the  number 
of injuries  and  deaths.  This  is why  the Committee  is 
in favour  of the obligatory  fitting  of safety  belts  with 
automatic  emergency  locking  retractors,  even  though 
it is aware  that  a correctly-adjusted,  conventional 
three-point  belt  is more  efficient  than  a retractor 
belt. 
4. Rear  seat  safety  belts 
4.1. The  Committee  approves  the stipulation  that 
rear seats  of cars  must  be fitted  at least  with  lap 
belts. 
17.11.  75 Official  Journal  of the European  Communities No C 263/39 
5. Comments  on the annexes 
The Committee  draws  attention  to the observations 
in the report  of the Section  for Industry,  Commerce, 
Crafts  and  Services  concerning  certain  aspects  of the 
technical  specifications  included  in the  annexes  to 
the draft  Directive.  The  Committee  does  not  feel 
competent  to take  up positions  on these  technical 
matters,  but  it is concerned  to ensure  that  the 
standards  laid  down  in the Directive  are not such  as 
to require  major  re-design  and  re-tooling  without  any 
appreciable  improvement  in safety.  The  Committee therefore  suggests  that,  in consultation  with  users 
and producers,  the  Commission  should  re-examine 
the specifications  on which  observations  are made  in 
the abovementioned  report. 
Done  at Brussels,  28 May  1975. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the 
proposal  for  a Council  Directive  on the  approximation  of the  laws  of the  Member 
States  relating  to electro-medical  equipment 
proposal  for  a Council  Directive  on the  approximation  of the  laws  of the  Member 
States  relating  to medical  X-ray  equipment  operating  at 10 to 400  kV 
The text  referred  to the Committee  was  published  in Official  Journal  of the European 
Communities  No  C 33 of 12 February  1975,  page  5. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 15 January  1975,  the  Council  referred  the  abovementioned  proposals  to the 
Economic  and  Social  Committee  under  Article  100  of the  Treaty  establishing  the 
European  Economic  Community. 
B. OPINION  OF  THE  ECONOMIC  AND  SOCIAL  COMMITTEE 
The Economic  and  Social  Committee  drew  up its Opinion  at its 130th  plenary  session, 
held in Brussels  on 28 and  29 May  1975. 
The Opinion  is published  below. 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the referral  on 17 January  1975  by 
the Council  of the  European  Communities  of the 
proposal  for  a  Council  Directive  on  the 
approximation  of the  laws  of the  Member  States 
relating  to electro-medical  equipment,  and  the 
Proposal  for  a  Council  Directive  on  the 
approximation  of the  laws  of the  Member  States 
relating  to medical  X-ray  equipment  operating  at 10 
to 400  kV; 
Having  regard  to  Article  100  of  the  Treaty 
establishing  the European  Economic  Community; Having  regard  to the decision  taken  by its Bureau  on 
28 January  1975,  instructing  the Section  for Industry, 
Commerce,  Crafts  and  Services  to prepare  the 
Committee's  work  on the matter; 
Having  regard  to the  Opinion  adopted  by  the 
Section  for Industry,  Commerce,  Crafts  and  Services 
at its meeting  on 7 May  1975; 
Having  regard  to the  report  submitted  by  the 
Rapporteur,  Sir John  Peel;