No C 125/30 Official  Journal  of the European  Communities 16.10.  74 
the necessary  ability  and  knowledge.  The  licence 
should  specify  the classes  of animals  and  methods 
of slaughter  to be employed  and  should  be 
granted  only  after  a thorough  examination  of the 
ability  of the person  concerned'. 
2.2.4.  The  following  sentence  should  be added  to 
the third  paragraph  of Article  2: 
'In particular,  any  person  engaged  in the slaughter 
of an animal  shall  ensure  that  the animal's  head 
is securely  positioned,  that  it is stunned  with  as 
little  suffering  and  pain  as possible,  and  that  the 
animal  is killed  immediately  after  it has  been 
stunned'. 
2.3. Article  3 
2.3.1.  The  words  'cruel  treatment'  should  be 
replaced  by 'unnecessary  suffering  or pain'. slaughter  there  would  appear  to be a case  for the 
establishment  of a body  similar  to the  Rabbinical 
Commission  to which  representations  could  be made 
if necessary,  and  with  whom  points  of difficulty  could 
be discussed. 
2.4.2  The  Committee  also  draws  attention  to the 
question  of action  to be taken  when  a mis-cut  is 
made  during  Jewish  slaughter.  If the animal  is then 
'unclean'  and  not  to be further  touched  by the 
shochet,  facilities  should  be readily  available  for the 
prompt  stunning  of the animal. 
2.5. Article  5 
2.5.1.  If the  effect  on meat  imports  mentioned  in 
paragraph  1.4.  above  is confirmed,  the  Committee 
suggests  that  a transitional  period  be allowed  before 
imports  from  third  countries  are affected. 
2.4. Article  4 
2.4.1.  The  Committee  recognizes  the  inevitability 
of taking  into  account  national  provisions  related  to 
the special  methods  of slaughter  required  by certain 
religious  rules.  In the  context  of Mohammedan Done  at Brussels,  17 July  1974. 
The Chairman 
of the Economic  and  Social  Committee 
Alfons  LAPPAS 
Opinion  on the proposal  for a Council  Directive  on the approximation  of the laws  of 
the Member  States  relating  to the driver-perceived  noise  level  of agricultural  or forestry 
tractors  fitted  with  wheels 
The text  referred  to the Committee  has been  published  in Official  Journal  of the European 
Communities  No  C 58 of 18 May  1974,  page  23. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 1 April  1974,  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 
122nd  plenary  session,  held  in Brussels  on 17 and  18 July  1974. 
The full  text  of the Opinion  is as follows: 
16. 10.74 Official  Journal  of the European  Communities No C 125/31 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  request,  dated  2 April  1974, 
from  the Council  of the European  Communities  for 
an opinion  on the  proposal  for a Council  Directive 
on the  approximation  of the  laws  of the  Member 
States  relating  to the  driver-perceived  noise  level  of 
agricultural  or forestry  tractors  fitted  with  wheels; 
Having  regard  to  Article  100  of  the  Treaty 
establishing  the  European  Economic  Community; 
Having  regard  to the Decision  taken  by its Bureau  on 
26 March  1974  instructing  the Section  for Industry, 
Commerce,  Crafts  and  Services  to prepare  a report 
and an opinion  on the matter; 
Having  regard  to the  Opinion  delivered  on 3 July 
1974  by the Section  for Industry,  Commerce,  Crafts 
and Services; 
Having  regard  to  the  report  submitted  by 
Mr Masprone,  the Rapporteur, 
Having  regard  to the discussions  on 17 July  1974  at 
its 122nd  plenary  session  held  on 17 and  18  July 
1974,  sitting  of 17 July  1974, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by a majority  with  8 abstentions: 
The Economic  and  Social  Committee  approves  the 
proposal  for  a Directive  subject  to the  following 
comments. normally  the  case  in the  United  Kingdom,  where  a 
limit  of 90 dB (A) is laid  down  by law. 
1.3. There  is no doubt  as to the reasons  which  led 
the United  Kingdom  authorities  to  adopt  this 
standard.  In the  United  Kingdom,  as in all cold 
climates,  almost  all tractors  are  fitted  with  cabs  by 
their  users.  Although  such  cabs  are  very  crude  and 
cheap,  they  protect  tractor  drivers  from  the weather. 
However,  cabs  act  as sound-boxes  for  the  noise 
emitted  by the engine  and  other  components  of the 
tractor,  as a rule,  the  sound  level  in such  cabs, 
measured  according  to OECD  standards,  varies 
between  102  and  110  dB (A).  It was  therefore  logical 
to specify  that  such  cabs  be sound-proofed  so as to 
limit  the  noise  level  to non-harmful  and  indeed 
comfortable  limits  (90 dB (A)). 
1.4. The  Committee  does  not however  consider  that 
such  a limit  can  be imposed  on the  other  States  of 
the Community,  especially  on the  southern  regions, 
because  this  would  amount  to making  the  use  of 
sound-proofed  cabs  compulsory.  The  temperature 
inside  such  cabs  would  become  almost  unbearable, 
unless  they  were  fitted  with  air-conditioning  equip-
ment,  which  would  inevitably  entail  extra  costs. 
1.5. Moreover,  it has  been  scientifically  proven  that 
as soon  as any  part  of a sound-proof  cabin  is opened, 
the driver-perceived  noise  level  is even  higher  than 
what  it would  have  been  if there  were  no cab. 
1.6. Thus,  it is only  possible  to reduce  driver-
perceived  noise  in tractors  without  a cab by reducing 
the noise  emitted  by  the  engine  and  the  other 
component  parts  of the tractor.  v 
1. Permissible  noise  level 
1.1. The  Committee  notes  that  the  proposal  for  a 
Directive  lays  down  a limit  of 90 dB (A)  for  the 
driver-perceived  noise  level  of agricultural  tractors. 
The Committee  recognizes  that  the proposed  limit  is 
a significant  step  forward  in the protection  of drivers' 
hearing  and  is a considerable  advance  on  the 
present  situation,  where  the  driver-perceived  noise 
level  is of the order  of 102/103  dB (A). 
1.2. The  Committee  points  out,  however,  that  such 
a reduction  can  at present  be achieved  only  if the 
tractor  is fitted  with  a sound-proofed  cab,  as is 2. Driver  protection 
2.1. The  Committee  would  draw  attention  to some 
essential  aspects  of protecting  drivers  of wheeled 
agricultural  and  forestry  tractors.  Above  all  the 
Committee  considers  that  very  precise  standards 
should  be laid  down  at Community  level  to protect 
the driver  if the  tractor  rolls  over  on its side  or 
tips over  backwards.  The  Committee  is pleased  to 
note that  the  Commission  is already  studying  this 
problem  and  hopes  that  work  may  be concluded  as 
rapidly  as possible. 
No C 125/32 Official  Journal  of the European  Communities 16.10.  74 
2.2. The  Committee  feels  that  consideration  must 
be given  to the effects  of noise  levels  at the driving 
position  on hearing  and  on  the  body's  internal 
organs.  On  tractors  fitted  with  a cab,  a low-
frequency,  high-intensity  sound  wave  occurs  which 
affects  the internal  organs.  The  permissible  noise 
level  on tractors  fitted  with  a closed  sound-proofed 
cab must  therefore  be noticeably  lower  than  that 
measured  on tractors  without  a cab. 
3. Technical  aspects  and  financial  implications 
3.1. The  technical  problems  of reducing  noise  levels 
are numerous.  As  regards  the  engine  and  its 
component  parts,  it is necessary  in particular  to 
reduce  the maximum  engine  speed,  increase  the wall-
thickness  of the cylinder  block,  change  the timing  and 
alter the  shape  of the  combustion  chamber.  In 
addition,  the transmission  and  other  components 
have  to be substantially  modified  so as to minimize 
resonance. 
3.2. The  Committee  considers  that  such  modifica-
tions  do not  pose  insuperable  difficulties  from  the 
technical  point  of view,  but  their  financial  impli-
cations  are obvious.  A reduction  in engine  speed,  for 
instance,  means  increasing  engine  capacity  — and 
thus the  weight  and  cost  of the  engine  — if 
performance  is to be maintained.  Altering  the shape 
of the  combustion  chamber  and  changing  from 
direct  to pre-chamber  injection  also  means  higher 
costs  and  a 15 to 20%  increase  in fuel  consumption 
for the same  power  output.  This  increase  means  in 
turn that  the cooling  system  has to handle  a greater 
heat and therefore  has to be enlarged. 
3.3. All  this  will  oblige  manufacturers  to make  a 
number  of modifications  to tractors  and  plant,  and 
these  modifications  certainly  cannot  be made  within 
the time  limits  laid  down  by the proposed  Directive. 4. Tractors  with  and  without  cabs  — a concrete 
solution 
4.1. The  Committee  would  point  out  that,  where 
maximum  noise  levels  are equal,  the average  noise 
versus  time  levels  are higher  on tractors  with  cabs. 
4.2. The  Committee  stresses  the need  for a distinc-
tion to be drawn  between  maximum  driver-perceived 
noise  levels  for tractors  with  a cab  and  for those 
without.  The  Committee  is of the opinion  that  the 
90 dB (A) limit  can be accepted  for tractors  with  a 
closed  sound-proofed  cab,  even  though  this  will 
involve  a certain  number  of difficulties  for  the 
industry,  but that  for cab-less  tractors  a higher  limit 
is more  appropriate.  Such  a limit,  which  would 
equally  give  rise  to difficulties,  could  be 96 dB (A). 
This is the same  as the level  perceived  in practice  by 
the driver  when  a closed,  sound-proofed  cab  is 
partially  open  (windows,  doors)  for a particular  use. 
In addition,  the limit  of 96 dB (A) corresponds  on 
average  to the permissible  sound  levels  laid  down  in 
Council  Directive  No 74/151/EEC  of 4 March  1974 
on the approximation  of the  laws  of the  Member 
States  relating  to certain  parts  and  characteristics  of 
wheeled  agricultural  or forestry  tractors.  Annex  VI 
of the Directive  prescribes  a maximum  sound  level 
of 89 dB (A) for tractors  with  an unladen  weight 
exceeding  1-5  metric  tons,  this  being  measured  7-5 
metres  from  the side  of the unladen  tractor  moving 
under  full  throttle  at three  quarters  of its maximum 
speed. 
5. Method  of measurement 
5.1. The  Committee  notes  that  it is not stipulated 
whether  noise  emitted  by all variants  of each  basic 
model  (for  instance  where  two-wheel  and  four-wheel 
drive  variants  exist)  is to be measured,  or solely  that 
emitted  by the  basic  model.  The  latter  would  be 
preferable,  as it would  simplify  the test  procedure 
and reduce  costs. 
3.4. Consequently,  Community  manufacturers  will 
be at a disadvantage  in competition  with  manufac-
turers  in third  countries,  because  a large  part  of their 
production,  which  of necessity  would  be  more 
expensive,  is destined  to be exported  outside  the 
Community,  whereas  the converse  is not  the  case. Done  at Brussels,  17 July  1974. 
The Chairman 
of the Economic  and  Social  Committee 
Alfons  LAPPAS 
16. 10.74 Official  Journal  of the European  Communities No C 125/33 
ANNEX 
to the Opinion  of the Economic  and  Social  Committee 
The following  amendment  was  rejected: 
The introductory  sentence  should  read: 
'The  Committee  approves  the aim  of the proposal  for a Directive,  that  is to say  better  pro-
tection  of drivers  against  noise,  but makes  the following  comments:' 
Result  of the vote: 
for: 24 
against:  32 
abstentions:  15. 
Opinion  on the proposal  for a Council  Directive  on the disposal  of waste  oils 
The text  referred  to the  Committee  has  been  published  in Official  Journal  of the 
European  Communities  No  C 64 of 5 June  1974,  page  5. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 2 April  1974,  the Council  referred  the abovementioned  proposal  to the Economic 
and Social  Committees  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 
122nd  plenary  session,  held  in Brussels  on 17 and  18 July  1974. 
The full  text  of the Opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  request  from  the  Council  of 
the European  Communities,  dated  3 April  1974,  for 
an opinion  on the  proposal  for a Council  Directive 
on the disposal  of waste  oils; 
Having  regard  to the  Decision  by its  Bureau  on 
8 April  1974  to entrust  the Section  for Protection  of the Environment,  Public  Health  and  Consumer 
Affairs  with  the  preparation  of an opinion  on this 
subject  by virtue  of Article  22  of the  Rules  of 
Procedure; 
Having  regard  to  Article  100  of  the  Treaty 
establishing  the European  Economic  Community; 
Having  regard  to the  Opinion  delivered  by  the 
Section  for  Protection  of the  Environment,  Public