17. 6. 91 Official Journal of the European Communities No C 159/9 
Opinion on the proposal for a Council Directive concerning the minimum requirements for 
the provision of safety and/or health signs at work (!) 
(91/C 159/04) 
On 5 February 1991, the Council decided to consult the Economic and Social Committee 
under Article 118 A of the Treaty establishing the European Economic Community, on the 
abovementioned proposal. 
The Section for Social, Family, Education and Cultural Affairs, which was responsible for 
preparing the Committee's work on the subject, adopted its Opinion on 11 April 1991. The 
Rapporteur was Mr Carroll. 
At its 286th plenary session (meeting of 24 April 1991) the Economic and Social Committee 
unanimously adopted the following Opinion. 
1. General comments 
1.1. The proposal is based on Article 118a of the 
Treaty and is in the form of an individual Directive 
within the meaning of Article 16 of Council Directive 
89/391/EEC of 12 June 1989 on the introduction of 
measures to encourage improvements in the safety and 
health of workers at the workplace (2). 
1.2. The proposal is one of the new initiatives 
announced by the Commission in the Communication 
on its action programme relating for the implemen­
tation of the Community Charter of Basic Social Rights 
for Workers (3). The aim of the proposal is to extend 
the scope of Directive 77/576/EEC and to strengthen 
some of its provisions. 
1.3. The aim of the 1977 Directive was to ensure 
that a limited group of safety signboards and signs for 
obstacles and dangerous locations comply with certain 
principles. The current proposal is aiming to make the 
use of signs compulsory under certain conditions and 
it introduces new signboards and other types of signs, 
such as for the location and identification of containers 
and pipes and of fire-fighting equipment, markings 
for certain traffic routes, luminous and acoustic signs, 
adequate verbal communications and hand signals. 
1.4. The Economic and Social Committee has been 
supportive down the years of European Community 
policies for improving safety and health at the work­
place and has been constructive and innovative in sug­
gesting improvements and in highlighting particular 
problems arising from or associated with Commission 
proposals. The Committee is no less committed now in 
its consideration of the proposed updating and exten­
ts OJ No C 53, 28. 2. 1991, p. 46. 
(2) OJ No L 183 of 26. 6. 1989, p. 1. 
(3) COM(89) 568 final. sion of the 1977 Directive on safety signboards and 
signs for obstacles and dangerous locations. 
1.5. Therefore, the Committee gives a general wel­
come to the proposals but is concerned that there could 
be, albeit unwittingly, a consequential proliferation of 
signboards and signs with the attendant danger of a 
not 'seeing the wood for the trees' syndrome. 
1.6. Furthermore, the Committee must warn against 
the introduction of signs and/or signboards merely for 
the sake of attempting to provide for every possible 
type of contingency in the area of safety at the work­
place, bearing in mind that signs and signboards of 
themselves cannot be a substitute for a well-informed 
management and workforce with the requisite edu­
cation and training in the whole area of workplace 
hazards and accident control and prevention. 
1.7. This applies equally to small and medium-sized 
enterprises (SMEs) as well as to major establishments 
but SMEs may need special help and consideration 
to enable them to cope with the requirements of the 
proposed Directive. 
In this regard, national Governments have an obligation 
to ensure that the measures to be taken by them to give 
effect to the Directive include means whereby those 
charged with the overseeing responsibility for safety at 
the workplace have adequate educational possibilities, 
including leafleting, pamphlets, seminars, workshops 
and the generation of public-awareness programmes. 
1.8. In its Opinion on Directive 77/576/EEC issued 
on 30 September 1976, the Committee made a number 
of points which are valid in respect of the current 
proposal. The Committee then said, inter alia, 
'— a proliferation of safety signs should be avoid­
ed, as this would detract from their effective­
ness, 
— the symbols must be sufficiently expressive and 
eye-catching, especially for more vulnerable sec­
tions of the population such as children, elderly 
No C 159/10 Official Journal of the European Communities 17. 6. 91 
persons and migrant workers, and in the case 
of certain particularly dangerous types of work, 
— the technical requirements for these signs must 
take into account the psychological effect on 
persons who are not sufficiently well informed.' 
1.9. In addition, the Committee also submits that 
great care has to be taken in respect of workplace 
locations or job sites to which the public has access so 
as to ensure that the location and number of signs 
(visual and verbal) and signboards do not in themselves 
create a hazard to the workforce because of the techni­
cal nature or application of specific signs as opposed 
to an overall well presented and located general danger-
warning sign or signal. 
1.10. The Committee is aware that the Advisory 
Committee on Safety, Hygiene and Health Protecion 
at Work, set up by Council Decision 74/323/EEC of 
27 April 1974, was consulted and issued its Opinion 
which the Commission states was taken into account 
in the drafting of the proposal. 
2. Specific comments 
2.1. Article 7 
While noting that the exemptions permitted under this 
Article are confined to luminous signs and/or acoustic 
signs, the Committee is concerned that such exemptions 
might become too regular a feature even though there 
is a requirement that exemptions are dependent on 
alternative measures being taken which afford the same 
level of protection. 
The second paragraph of this Article also stipulates 
that exemptions are also dependent on prior consul­
tation witht he national employers and workers organ­
izations. 
2.2. Article 8 
Paragraph 1 of this Article does not stipulate when the 
workers and/or their representatives are to be informed 
of all the measures to be taken concerning the health 
and/or safety signs used at the workplace. The question 
is: should this be done sufficiently in advance to allow 
for familiarization and/or instruction and, who will so 
determine ? 
Paragraph 2 of the Article signals the requirement for 
suitable instruction concerning the signs used at work. 
The Committee would urge that there is an accepted understanding of what 'suitable' instruction means and 
that there is adequate monitoring of the standard of 
this instruction by the appropriate national authority. 
2.3. Annex 1 
2.3.1. Paragraph 2.5 of this Annex requires that lumi­
nous and acoustic signs and/or verbal communications 
should be used when required. The weakness of this is 
that the expression 'when required' is open to various 
interpretations as to whom makes the judgement and 
what criteria should be used when that judgement is 
being made. Even if there is an agreed and sustainable 
case to govern 'when required' (apart from a reference 
to common sense) it has to be borne in mind that a 
situation can arise or develop in the workplace not 
already provided for and, in the event of an accident, 
'when required' and how this was interpreted and 
applied could well feature prominently in any sub­
sequent proceedings. 
2.3.2. The same applies to the term 'if equally effec­
tive' used in paragraph 3.1 of this Annex. Who makes 
the judgement called for and with what responsibility 
and authority and against what criteria ? 
2.3.3. These points are made to emphasize the absol­
ute necessity for the utmost clarity and understanding 
of what is intended so as to avoid any confusion, 
misunderstanding or misplaced obligations. In para­
graph 5 of this Annex (Annex 1) there is a warning 
against the placing of too many signs too close together, 
and that two luminous signs which are likely to be 
confused should not be used at the same time. It also 
warns against using a luminous sign in the proximity 
of another indistinct sign. 
The Committee has no difficulty in accepting the object 
of these requirements but, again, has to draw attention 
to the difficulty of ensuring their implementation 
against the background of imprecise language and hav­
ing regard to particular practices in workplaces and the 
variations which may occur in assessing or defining the 
qualifying requirement. It is one thing for the Annex 
to say 'the effectiveness of a sign must not be adversely 
affected by ... etc.', but it is another thing to have a 
clear understanding (possibly for legal purposes) of 
what adversely affected really means, more especially 
if there has been an accident, and someone has been 
hurt. 
2.3.4. This is another argument in favour of maxim­
izing safety information, education and training and 
of ensuring that national or local safety authorities 
establish appropriate standards in the context of under­
standing and applying the terms of this Directive. 
17. 6. 91 Official Journal of the European Communities No C 159/11 
2.4. Annex 2 
2.4.1. The points made in respect of Annex 1 apply 
equally to paragraphe 1.3 of this Annexe and especially 
to the second paragraph, 2.1. The requirement is to use 
reflective materials or artificial lighting where the level 
of natural light is inadequate. Bearing in mind the basic 
requirements of the framework directive, there is still 
a need for clearer criteria for assessing such situations. 
This point is made not just to find fault but to emphas­
ize the necessity of ensuring maximum conformity to 
common standards bearing in mind the purpose of the 
entire exercice, to minimize and, indeed, to prevent 
accidents at the workplace. 
2.4.2. The Committee acknowledges the need for 
uniformity in all these signs and for that uniformity to 
coincide with accepted and understood safety sings. 
However, the Committee wonders if the number and 
variety of the signs indicated are not too many and is 
less than convinced that alle the signs proposed are 
necessary and will in any event be effective. It may well 
be that usage and growing familiarity will increase the 
effectiveness of all the signs set out in the Annex but 
some of them could be open to misinterpretation and 
might even add to or create confusion. This applies 
particularly to the following prohibitory signs: 
— Do not extinguish with water, 
— Not drinkable, 
— No access for unauthorized persons, 
— Do not touch, 
— Corrosive materials, 
— Laser beam, 
— Oxidant material, 
— Biological material, 
— Low temperature. 
Under Section 3.5, fire-fighting signs, the Committee 
would have to be convinced that the sign depicting 
'Fire-fighting Equipment, General' is appropriate. 
2.5. Annex 3 
While appreciating the value of a colour code for pipes, 
the requirement for the use of eight different colours 
raises the question of the need for a colour-code key to 
be readily available for persons who would not nor­
mally or regularly be in a workplace location with pipes 
and, hence, would have no familiarity with the contents 
of pipes or with their purpose. And the matter of colour-blindness must also be taken into account in 
assessing the worth of pipe colour coding. 
The Committee would also draw attention to the possi­
bility of problems arising: 
— due to existing variations in colour coding in Mem­
ber States, 
— as regards the effectiveness of colour coding in 
circumstances of poor lighting, 
— in situations where pipes and containers are subject 
to multi-purpose usage. 
2.6. Annexes 5, 6 and 7 
These Annexes require very special attention as to their 
implementation. It is very important to ensure that 
good levels of hearing and eyesight are not taken for 
granted and, therefore, all the more attention must be 
given to situations of casual attendance at the work­
place where hazards exist. 
2.7. Annex 8 
There is a possibility of much confusion in regard to 
verbal communications and it is imperative that in the 
educational programmes associated with these signals 
due regard is had to the use of the vernacular by 
workers in some situation so that casual visitors or 
workers at such workplace are not mislead or unwit­
tingly confused by verbal signals. 
The Committee would highlight the need for workers 
to have knowledge of the language necessary in order 
to protect their own health and safety. 
2.8. Annex 9 
The coded signals to be used need careful monitoring 
as to their effectiveness and, in particular, the 'move 
forward' and 'move backwards' arms signals are liable 
to lead to misunderstanding. It is suggested that the 
'move backward' signal should start at waist level, 
hands facing down, and proceed downwards and back 
to waist level. 
3. Conclusions 
3.1. The Committee repeats and emphasizes its 
ongoing support of the Commission and Council in the 
development of measures to improve workplace safety. 
It suggests, however, that the Commission should guard 
against an over-perfectionist approach to specific stan-
No C 159/12 Official Journal of the European Communities 17. 6. 91 
dards which may be extremely difficult to achieve and, 
some of which, may not really contribute much to the 
Done at Brussels, 24 april 1991. 
1. Introduction 
1.1. In recent years, the Committee has issued three 
Opinions on the situation of third country migrants: 
a) own-initiative Opinion of 25 October 1984 on 
migrant workers ('), 
b) opinion of 29 May 1985 on guidelines for a Com­
munity policy on migration (2). This Opinion largely 
reflects the earlier one, particularly in its comments 
on third countries, 
c) opinion of 12 July 1989 on the Mediterranean policy 
of the European Community (3). The Opinion sets 
out proposals for a policy for migrants from non-
EC Mediterranean countries. 
1.1.1. The Committee's assessment of the limits of 
EC policy in this field, and the recommendations and 
conclusions as to needs set out in the above Opinions, 
have not been taken up by the Council and remain 
largely valid. overall objective of protecting the worker's health and 
safety at the workplace. 
The Chairman 
of the Economic and Social Committee 
Francois STAEDELIN 
1.1.2. Nonetheless, the changes which have since 
occurred in Member States' circumstances and legis­
lation, and the changes wrought the Community inte­
gration and the ensuing need for a new institutional 
framework, suggest to the Committee that further 
assessments and recommendations are needed. 
1.2. The Hanover European Council of June 1988 
recognized that immigration needed more detailed 
Community consideration, and instructed the Com­
mission to draw up a report on the social integration 
of migrants. 
1.2.1. This report, on the social integration of third 
country migrants residing on a permanent and lawful 
basis in the Member States (4), was followed by an 
experts' report (drawn up on the Commission's behalf) 
on policies on immigration and the social integration 
of migrants in the European Community (5). This latter 
report is an important contribution to the subject, and 
its conclusions and recommendations are considered in 
the present Opinion. Own-initiative opinion on the Status of migrant workers from third countries 
(91/C 159/05) 
On 31 January 1991 the Economic and Social Committee, acting under the fourth paragraph 
of Article 20 of its Rules of Procedure, decided to draw up an Opinion on the Status of 
migrant workers from third countries. 
The Section for Social, Family, Educational and Cultural Affairs, which was responsible for 
preparing the Committee's work on the subject, adopted its Opinion on 11 April 1991. The 
Rapporteur was Mr Andrea Amato. 
At its 286th plenary session (meeting of 24 April 1991), the Economic and Social Committee 
adopted the following Opinion by a majority vote, with two abstentions. 
(!) OJ No C 343, 24. 12. 1984. 
(2) OJ No C 188, 29. 7. 1985. 
(3) OJ No C 221, 28. 8. 1989. (4) SEC(89) 924 final, 22. 6. 1989. 
(5) SEC(90) 1813 final, 28. 9. 1990.