30. 11.77 Official  Journal  of the European  Communities No C 287/11 
performance  of the  heat  regulating  systems  available 
on the market. 
2.3. Draft  Council  recommendation  on  the  rational 
utilization  of energy  in industrial  undertakings 
2.3.1.  The  Committee  is  in  favour  of  the 
establishment  of bodies  in each  Member  State  lo 
promote  energy  conservation,  especially  if these 
bodies  enjoy  the  support  of  the  Community 
authorities. 
2.3.2.  However,  the recommendation  regarding  the 
establishment  of machinery  in firms  for  compiling 
and implementing  an  energy  conservation 
programme  — in particular  the  appointment  of an 
energy  manager  in firms  with  more  than  100 
employees  — and  those  firms'  obligation  to report  on 
energy  consumption  and  the  results  of energy  saving 
operations  is neither  suitable  nor  necessary  for 
attaining  further  significant  cuts  in  energy 
consumption.  It would  be sufficient,  the Committee 
thinks,  if such  firms  were  left  to decide  for themselves 
Done  at Brussels,  29 September  1977. whether  to designate  energy  managers  to keep  un 
touch  with  the competent  national  bodies. 
2.3.3.  The  Committee  believes  that  it is important 
to guard  against  a proliferation  of agencies  in the 
Member  States  dealing  with  rational  energy  use. 
2.4. Draft  Council  recommendation  on  the  creation 
in the  Member  States  of advisory  bodies  on 
combined  heat  and  power  production  in  the 
industrial  sector  and  for district  heating 
2.4.1.  The  work  involved  in  promoting  the 
combined  production  of heat  and  power  for industry 
and for  district  heating  might  well  be carried  out 
under  the supervision  of the  agencies  in the Member 
States  which  should  have  overall  responsibility  for 
rational  energy  use. 
2.4.2.  The  Committee  believes  that  the 
Community  can  play  a useful  coordinating  and 
catalytic  role  in this  area  which  promises  significant 
savings,  but where  much  work  has  yet to be done. 
The Chairman 
of the Economic  and  Social  Committee 
Basil  de FERRANTI 
Opinion  on the  proposal  for  a Council  Directive  on the  approximation  of Member 
States'  laws,  regulations  and  administrative  provisions  on the  protection  of the  health 
of workers  occupationally  exposed  to vinyl  chloride  monomer 
The text  referred  to the  Committee  has  been  published  in Official  Journal  of the 
European  Communities  No  C 291  of 6 December  1976,  page  5. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 1 December  1976,  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 
151st  plenary  session,  held  in Brussels  on 28 and  29 September  1977. 
The full  text  of the opinion  is as follows: 
No C 287/12 Official  Journal  of the  European  Communities 30. 11. 77 
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  for  an opinion  made  by 
the Council  of  the  European  Communities  on 
1 December  1976, 
Having  regard  to  the  amendments  which  the 
Commission  of the  European  Communities  made  to 
the above  proposal  (second  paragraph  of Article  149 
of the  EEC  Treaty)(1), 
Having  regard  to the  decision  taken  by its Bureau  on 
14 December  1976,  instructing  the  Section  for  Social 
Questions  to draw  up an opinion  and  a report  on the 
matter, 
Having  regard  to  the  opinion  delivered  by  that 
Section  at its meeting  on 15 September  1977, 
Having  regard  to  the  report  presented  by  the 
rapporteur,  Mr van  Rens, 
Having  regard  to the  discussions  at its 151st  plenary 
session,  held  on 28 and  29 September  1977  (meeting 
of 29 September), 
Whereas  the  European  Community  has  an obligation 
to promote  improved  working  conditions  and  an 
improved  standard  of living  for  workers  and  their 
families  as well  as to promote  prevention  and  control 
of occupational  diseases; 
Whereas  the  Economic  and  Social  Committee  has  in 
its past  opinions  and  reports  stressed  the  need  for 
more  and  a better  quality  of life  and  has  stressed  the 
importance  of protection  of the  health  of the  worker 
and his family; 
Whereas  the  International  Labour  Organization  has 
adopted  a Convention  and  a Recommendation  on 
occupational  cancer  (Convention  No  139  on  the 
prevention  and  control  of  occupational  hazards 
caused  by  carcinogenic  substances  and  agents; 
Recommendation  No  147  on  the  prevention  and 
control  of  occupational  hazards  caused  by 
carcinogenic  substances  and  agents); 
Whereas  recent  occupational  studies  and  scientific 
evidence  do  indeed  implicate  vinyl  chloride  as a 
human  carcinogen  which  manifests  itself  in liver 
(') OJ  No C 219,  14. 9. 1977. angiosarcoma,  and  suggest  that  it may  also  manifest 
itself  in multiple  tumour  sites; 
Whereas  no  level  of  exposure  to  a chemical 
carcinogen  should  be  considered  toxicologically 
insignificant  for humankind; 
Whereas  the  Economic  and  Social  Committee 
supports  meaningful,  enforceable  laws  such  as this 
draft  Directive  which  will  ensure  more  healthful  and 
safer  work  environments, 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
uanimously: 
The Committee  approves  the  proposal  subject  to the 
following  comments: 
1. General  comments 
1.1. The  Committee  has  always  been  extremely 
concerned  about  the  safety  and  protection  of workers 
at the workplace.  In view  of this  and  the  fact  that  the 
proposal  is the  first  of its kind,  the  Committee  has 
taken  the  opportunity  to  make  a number  of 
comments  which  go beyond  the  strict  scope  of the 
proposal.  By  doing  so  the  Committee  wishes  to 
demonstrate  its concern  for health  welfare  and  safety, 
and express  support  for future  activities  in this  area. 
1.2. The  Committee  requests  the  Commission  to 
take  steps  to draw  up  a European  programme  for 
health  protection  and  safety  at work  with  clear-cut 
priorities.  The  detection  and  prevention  of 
occupational  diseases  should  be one  of the  priorities. 
The Committee  has  repeatedly  called  for  measures  to 
prevent  occupational  diseases.  The  state  of 
knowledge  and  preventive  action  in this  area  are  still 
unsatisfactory.  The  European  Foundation  for  the 
Improvement  of Living  and  Working  Conditions  in 
Dublin  can  and  should  be  involved  in  the 
preparatory  work.  But  first  of all it is necessary  to 
take  stock  of what  has  happened  so  far  in the 
Community.  Furthermore,  the  necessary  funds  should 
be made  available  as soon  as possible  in order  to 
conduct  and  coordinate  medical  research  into  the 
effects  of dangerous  substances.  The  European  Coal 
and Steel  Community  is exemplary,  through  the 
common  research  fund  it had  created  in order  to 
study  illnesses  and  diseases  in the  coal  and  steel 
industry.  The  Committee  urges  the  Commission  to 
investigate  how  the  requisite  funds  should  be 
collected.  Thought  could  be given  to a levy  on the 
30.11.77 Official  Journal  of the European  Communities No C 287/13 
output  or added  value  of the  chemical  industry.  In 
this connection  the  Committee  would  propose  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)  a data  bank  designed  to record  the 
effects  of dangerous  materials. 
1.3. In  the  present  state  of knowledge  on  this 
matter  no level  of exposure  to a chemical  carcinogen 
should  be considered  toxicologically  insignificant  for 
humankind.  For  carcinogenic  agents  a definitive  safe 
level  cannot  be established  by application. 
1.4. The  Committee  urges  the  Member  States  to 
without  delay  ratify  ILO  Convention  139  and 
implement  ILO  Recommendation  147  and  the  EC 
Commission's  recommendation  on  occupational 
diseases.  If the  latter  recommendation  does  not  have 
sufficient  legal  impact,  the  Committee  would 
recommend  more  binding  instruments. 
1.5. The  Committee  also  thinks  it would  be a 
good  thing  to centralize  all Commission  activities 
in this  field,  or at least  ensure  effective  coordination. 
1.6. The  Committee  recommends  the  establish-
ment  of  a system  for  recording  exposure  to 
dangerous  substances  and  the  medical  status  of 
persons  who  come  into  contact  with  such  substances. 
This  system  could  be readily  linked  to national  vital 
statistics,  either  records  of death  or,  preferably, 
cancer  registry.  Linking  to the  national  records  is 
essential  for  tracing  past  employees,  even  when  they 
are no longer  working. 
1.7. The  European  Community  and  the  national 
governments  have  an obligation  to make  generally 
available,  in a non-expensive  form,  and  in readily 
comprehensible  wording,  information  about 
dangerous  substances  used  in  industry  and  the 
hazards  associated  with  their  use.  Employers  too 
should  be obliged  to inform  their  workers  about:  (a) 
the types  of dangerous  chemicals  used  and  produced 
in their  plants;  (b)  any  dangerous  effects  they  may 
have;  (c) the measures  to protect  workers.  Copyright protection  of data  of the  hazards  and  their  nature  of 
chemicals  should  be abolished.  If codes,  trade  names, 
etc., for chemicals  are used  it is absolutely  essential  to 
indicate  also  the chemical  composition. 
1.8. If  medical  findings  show  clearly  that  a 
substance  is  dangerous,  not  only  must  the 
Community  and  the Member  States  bring  the hazards 
to the  attention  of the  public;  at all events,  legal 
steps  must  be taken  to ensure  suitable  protection  and 
control  of  dangerous  substances.  Economic  and 
competitive  advantages  should  never  be procured  at 
the expense  of deliberately  endangering  the  lives 
and health  of workers. 
1.9. The  world-wide  chemical  health  hazards  that 
exist  in  the  working  environments  cause  also 
occupational  illnesses  and  serious  diseases  other  than 
cancer  and  these  should  also  be given  very  serious 
attention.  The  incidence  of some  cancers  can  also  be 
related  to occurrence  of other  morbid  conditions  in 
the same  tissues  or organs.  Chronic  or repeated 
injuries  to the  same  tissues  have  not  been  adequately 
studied  to permit  unqualified  conclusions.  The  study 
of possible  associations  between  cancer  and  other 
intercurrent  diseases  also  requires  control  of 
numerous  other  factors  known  to be  related  to 
cancer  risks.  The  problems  are  further  compounded 
by difficulties  in making  a prompt  and  accurate 
diagnosis  of  one  or  both  conditions  and  in 
distinguishing  between  the  effects  of cancer  and  of a 
primary  independent  disease  (cirrhosis,  primary  liver 
disorders  in immune  cell  carcinoma). 
1.10.  Most  cancer  cases  are  attributable  to 
environmenal  factors.  Cancer  is  therefore  not 
unavoidable,  except  in a small  number  of cases. 
Technological  progress  must  not  lead  to an increase 
in cancer  and  occupational  diseases  in general.  Above 
all it must  be instrumental  in bringing  about  a sharp, 
rapid  decline  in cancer  and  other  occupational 
diseases  caused  by  working  with  dangerous 
substances. 
2. Specific  comments 
2.1. The  Committee  will  not  enter  into  details  of 
the Commission's  proposal,  particularly  in view  of its 
highly  technical  nature.  The  essential  features  should, 
however,  emerge  in the course  of these  comments. 
No C 287/14 Official  Journal  of the European  Communities 30. 11.77 
2.2. The  object  of the  proposed  Directive  is to 
align  laws,  regulations  and  administrative  provisions 
protecting  workers  exposed  to the  effects  of vinyl 
chloride  monomer  (VCM)  in their  working  area.  The 
draft  Directive  covers  works  in which:  (a)  vinyl 
chloride  monomer  is produced,  reclaimed,  stored, 
discharged  into  containers,  transported  or used  in 
some  other  way;  (b) where  vinyl  chloride  monomer  is 
converted  into  unformed  vinyl  chloride  polymers 
(PVC). 
2.3. The  draft  Directive  sets  out  to ensure  the 
protection  of the worker  by the establishment  of: 
— limit  values  for the atmospheric  concentration  of 
VCM  in the working  area, 2.7. Some  recent  research  indicates  that  exposure 
to VCM  may  be responsible  for  cancer  in organs 
other  than  the  liver,  and  that  there  may  be 
teratogenic  effects.  None  of this  work  has  yet  been 
confirmed,  and  has  indeed  been  contradicted.  So far 
it has  not  been  possible  to demonstrate  mutagenic 
effects  on germ  cells  in animals  exposed  even  to very 
high  doses  of VCM,  although  chromosomal  changes 
have  been  demonstrated  in blood  cells.  However,  in 
view  of uncertainty  in these  very  important  areas,  the 
Committee  emphasizes  the  urgent  need  for  further 
research.  In the  Committee's  view,  it is essential  to 
conduct  more  research  into  the  effects  mentioned 
above.  'If medical  research  points  to the  existence  of 
mutagenic  or  teratogenic  effects,  the  Committee 
consideration  should  be  given  to  introducing 
arrangements  for  monitoring  the  health  of  the 
workers'  families  concerned'. 
— measuring  and  monitoring  techniques  necessary 
for this  purpose,  as well  as other  preventive 
measures, 
— guidelines  for medical  surveillance. 
2.4. The  draft  Directive  has  taken  into 
consideration  not  only  the  generally  reversible  VCM 
syndrome  known  as 'occupational  acro-osteolysis'  but 
also more  recent  evidence  from  epidemiological 
studies  and  animal  experimentation  which  indicates 
that prolonged  and/or  repeated  exposure  to high 
concentrations  of VCM  in the  atmosphere  may  also 
cause  skin  diseases  and  liver  disorders. 
2.5. Furthermore,  the  draft  Directive  points  out 
that VCM  should  also  be regarded  as a carcinogen 
which  may  cause  angiosarcoma,  a rare  malignant 
tumour  which  can  also  occur  in a very  few  cases 
without  any  known  cause. 
2.6. Vinyl  chloride  came  to public  attention  in 
1974  when  several  workers  who  had  handled  the 
substance  over  long  periods  began  developing 
angiosarcoma,  a rare  and  invariably  fatal  type  of liver 
cancer.  "Without  wishing  to  comment  on  the 
consequences  or  give  a final  judgement,  the 
Committee  would  point  out  that  workers  exposed  to 
high  concentrations  of vinyl  chloride  were  later 
discovered  to have  a significant  excess,  not  only  of 
angiosarcoma  of the liver,  but also  of cancer  of other 
organs  such  as the  respiratory  system,  the  brain  and 
the lymphatic  system. 2.8. The  Committee  would  like  to point  out  that 
the 'total  cumulative'  effect  of  the  chemical 
environment  upon  the  worker  and  his  family 
especially  in the  industrialized  parts  of Europe,  must 
be taken  into  account.  Today,  the  workplace 
environment  continues  to be the  primary  laboratory 
in which  the  carcinogenicity  to humans  of certain, 
substances  is first  revealed.  The  Committee  stresses 
that exposure  to a certain  substance  may  be relatively 
harmless  by itself  but  may  become  cocarcinogenic 
through  the  action  of other  catalysts  or promoters 
(i.e.,  cigarette  smoking,  hydrocarbons  or  a 
combination  of  several  substances).  The 
Commission  should  look  into  the  cumulative  effects 
of promoters  and  catalysts.  The  question  of 
'cumulative  effects'  should  not  be misused  as a reason 
or excuse  for  not  tackling  this  problem  or  not 
investigating  other  substances  or a combination  of 
substances. 
2.9. The  Committee  would  suggest  that  the latency 
period  of the  VCM  related  diseases  be  closely 
observed  and  be taken  into  account.  Given  the  fact 
that the latency  period  of the diseases  may  be as long 
as 25 years,  it seems  certain  that  more  deaths  from 
angiosarcoma  and  other  tumours  will  be discovered 
in the  population  of workers  exposed  to VCM.  The 
reason  for  this  is that  there  are  still  many  workers 
who  were  exposed  to very  high  concentrations  of 
vinyl  chloride  monomer  before  1974.  Due  to the long 
interval  often  between  exposure  and  the development 
of cancer,  many  group  comparisons  and  their 
interpretation  are  complicated  by  differences  in 
medical  care  facilities  and  inability  to recognize  and 
diagnose  the disease. 
30.11.  77 Official  Journal  of the  European  Communities No C 287/15 
2.10.  The  Committee  would  like  to point  out that 
it is very  difficult  to assume  that  the  individual 
worker  is employed  in one  working  area  alone.  The 
mobility  of the  workers  employed  or occasionally 
employed  in VCM  plants  and  their  course  of duties 
at perhaps  other  parts  of the  plant  or other  plants 
thereafter  must  be given  more  consideration. 
2.11.  'As  is the case  with  many  other  occupational 
illnesses,  some  illnesses  which  may  be brought  on by 
exposure  to VCM  may  also  have  other  causes;  this 
makes  compensation  more  difficult  to settle'.  Liver 
complaints,  for instance,  can  be caused  by a number 
of things,  and  when  a worker  in a VCM  plant 
changes  his job  it is often  difficult  to establish  to 
what  extent  any  cirrhosis  has resulted  from  exposure 
to VCM,  especially  if the  disease  does  not  develop 
until  some  time  after  he stopped  working  in the 
VCM  plant. 
2.12.  The  proposed  Directive  is concerned  with  a 
new,  statistically  defined  reference  value  — the 
technical  long-term  limit  value  — which  should  be 
regarded  as a mean  annual  value.  The  limit  values  for 
shorter  reference  periods  are based  on data  obtained 
by extensive  measurement  of VCM  concentrations  in 
the PVC  industry.  These  results  coincide  with  data 
for other  harmful  substances  and  for other  sectors  of 
industry.  A mean  ratio  is established  between  the 
limit  values  for  shorter  reference  periods  and  the 
technical  long-term  limit  values.  The  figures  are given 
in Annex  I to the proposal. 
2.13.  The  Committee  appreciates  the drive  shown 
by the Commission  in introducing  this  new  reference 
value  (the  technical  long-term  limit  value).  According 
to the  representatives  of the  Commission,  it is 
intended  to use  this  method  in future  for all toxic 
substances.  It is difficult  for  those  who  are  not 
experts  in the  field  to grasp  the  full  scope  of the 
method  advocated  by the Commission  and  to make  it 
comprehensible  to workers  in the  VCM  industry 
and manageable  by  them.  In view  of this  the 
Committee  has expressed  certain  misgivings,  some  of 
which  are of a psychological  nature.  A further  factor 
is that  the TLV  method  cannot  identify  all biological 
and epidemiological  hazards. 
2.14.  The  Committee  therefore  requests  the 
Commission  to consider  the  case  for  re-examining 
this method,  involving  long-term  limit  values,  and 
where  necessary,  to adjust  the method  or try to make 
it more  readily  understandable  by all those  involved 
in its implementation.  At all events  short-term  values must  be communicated  to workers  in writing  in order 
to allow  them  to form  an opinion. 
2.15.  The  Committee  notes  that  the draft  Directive 
applies  only  to the manufacture  of the monomer  and 
the polymer  but not to the processing  of the polymer, 
although  there  is frequently  a monomer  residue  after 
polymerization.  The  Committee  urges  the 
Commission  to prepare  also  a Directive  on  the 
processing  of the  polymer,  on the  storage,  handling 
and use of VC and  PVC,  as well  as on packaging  and 
repackaging  for  those  products  not  covered  at 
present  by the  proposal  for  a Council  Directive  on 
the approximation  of the laws  of the Member  States 
relating  to materials  and  articles  containing  vinyl 
chloride  monomer  and  intended  to come  into  contact 
with  foodstuffs  (i.e.,  cosmetics,  medical  supplies, 
water  pipes  . . .). 
2.16.  The  Committee  would  also  like  to point  out 
that the Commission  should  give  specific  attention  to 
the environmental  effects  of VC.  Concern  has  been 
expressed  about  possible  risks  to the general  public. 
The reference  to the  environment  in Article  3 (4) 
makes  a rather  strange  impression  and  is out of place 
in the  proposed  Directive.  The  Committee  realizes 
that the object  of this  subparagraph  is to ensure  that 
hygiene  in PVC  plants  is not  improved  by venting 
greater  quantities  of VCM  to the  atmosphere.  It 
would  like  the  Commission  to bring  out  a draft 
Directive  on environmental  aspects  within  a year  if 
possible. 
2.17.  The  Committee  endorses  the  ultimate 
objective  of the Directive,  which  is to achieve  a level 
of exposure  to vinyl  chloride  as close  to nil  as 
technically  feasible.  This  would  mean  employing  the 
most  advanced  technology  to work  out  standards 
designed  to minimize  the  level  of exposure  to 
chemical  carcinogens.  This  future  objective  can  be 
achieved  more  quickly  by adjusting  the Directive  to 
scientific  and  technological  progress  as frequently 
as possible.  The  Committee  considers  that  the 
Directive  should  be reviewed  not  only  every  two 
years  but as often  as this  is technically  feasible  or is 
called  for on account  of radical  developments. 
2.18.  The  Committee  suggests  that  in the case  of 
existing  plants,  many  of which  already  have  an 
emission  level  much  lower  than  that  prescribed  in the 
Directive  (3 ppm),  it should  be possible  to bring  the 
emission  level  into  line  with  the final  objective  of the 
Directive,  i.e.,  an emission  level  as close  to nil as 
technically  feasible,  after  a period  of adjustment 
lasting  several  years.  This  period  of adjustment 
should  end  by 1 January  1980  at the latest. 
No C 287/16 Official  Journal  of the European  Communities 30. 11. 77 
2.19.  Although  the  Committee  welcomes  the 
Commission  proposals  to  lower  to  3 ppm  the 
maximum  concentrations  for new  and  existing  plants, 
it notes  that  many  existing  plants  already  have  lower 
concentration  levels  and  that  this  is technically 
feasible  (progress  toward  a level  close  to nil).  The 
Committee,  therefore,  recommends  that  the Directive 
stipulate  that  for  new  firms  a level  as close  to nil as 
possible  be  adhered  to.  The  Committee  could, 
however,  agree  to a level  of 1 ppm  in the case  of new 
plants  for a very  short  transitional  period. 
2.20  The  Committee  welcomes  the  Commission 
proposal  to lower  the alarm  threshold  to 15 ppm. 2.24.  Since  it is necessary  to lay  down  at least  a 
maximum  concentration  over  a period  of 15 minutes, 
during  which  time  there  may  be considerable  peaks, 
and since  the  maximum  concentration  should  be 
set as low  as possible,  the Committee  considers  that 
research  should  be  conducted  into  the  possible 
effects  of peak  values  and  into  the  results  of 
long-term  exposure  to low  concentrations. 
2.25.  The  Committee  proposes  that  the  medical 
records  of workers  employed  in VCM/PVC  works 
should  be kept  during  the  lifetime  of the  worker 
so as to take  account  of the  latency  period  and  any 
change  in his jobs  thereafter. 
2.21.  The  Committee  would  like  to point  out  that 
the availability  and  provision  of industrial  medical 
surveillance  services  to small  plants  has  been  a major 
problem  for  decades.  The  scope  for  improving 
medical  services  should  be investigated. 
2.22.  The  setting  of a limit  value  for  atmospheric 
concentration  in the  working  area  requires  careful 
stipulation  of how  measurements  are  to be carried 
out and  what  methods  are  to be used  for  processing 
the resultant  measurements.  In the Committee's  view, 
the Directive  should  clearly  prescribe  continuous 
measurement  methods  and  do so in greater  detail.  At 
all events,  the method  to be prescribed  must  give  the 
same  results  in all  the  Member  States,  and  a 
maximum  concentration  over  a period  of 15 minutes 
must  be laid  down.  Use  should  be made  of fixed 
measuring  equipment  installed  at a large  number  of 
points  and  linked  to a central  panel  and  a panel  in 
each  section  of the  plant.  An automatic  warning  can 
then  be  given  if the  permissible  concentration  is 
exceeded.  Proper  care  must  be  taken  to  ensure 
uniform  application  of the  measurement  methods,  so 
that plants  cannot  get  round  their  obligations  to 
comply  with  the  Directive  and  provide  safe 
conditions  for  their  workers.  If personal  measuring 
instruments  are  used,  these  can  only  provide 
supplementary  comparative  data. 
2.23.  The  Committee  welcomes  the  insertion  of 
Article  9 (2).  This  must  at all events  lead  to workers 
and their  representatives  being  regularly  briefed  about 
the measurements  made  and  being  given  opportunities 
of seeing  how  measurements  are carried  out. 2.26.  The  Committee  trusts  that  national 
authorities  will  do all in their  power  to ensure  that 
works  medical  officers  have  the  requisite 
qualifications  and  experience  to detect  and  treat 
occupational  illnesses.  Moreover,  chromosome 
abberrations  should  be included  in the guidelines  for 
medical  surveillance  given  in Annex  2, 'bearing  in 
mind  that  the  lists  in the  guidelines  are  only  for 
guidance,  and  not  to be regarded  as a series  of 
compulsory  tests  to be carried  out  in every  case'. 
2.27.  In  view  of the  harm  that  can  be sustained 
from  frequent  X-ray  exposure,  the  Committee 
questions  the minimum  requirement  in the guidelines 
for medical  surveillance  that  the  hand  bones  be 
X-rayed  every  two  years. 
2.28.  All  medical  data  on  the  worker's  health 
status  must  — with  the  worker's  consent  — be made 
available  to the  worker's  personal  physician.  These 
data  must  also  be centralized;  this  means  that  they 
must  conform  to certain  standards  and  quality 
requirements. 
2.29.  The  Committee  appreciates  the  efforts  made 
by a number  of firms  within  the  Community  and 
outside  the Community  in cooperation  with  workers 
and trade  union  representatives  to reduce  the  levels 
of exposure  considerably  and  to diminish  the  danger 
to workers.  The  willingness  of these  firms  to publish 
and exchange  the  information  obtained  by  their 
research  workers  and  by research  workers  financed 
by them  has  made  a valuable  contribution  and  these 
activities  therefore  should  be  continued.  The 
Committee  would  like  the  European  Community  to 
30. 11.77 Official  Journal  of the  European  Communities No C 287/17 
do much  more  work  in this  field,  as pointed  out, 
especially  in paragraph  1.2. 
2.30.  Although  the  Committee  realizes  that  the 
setting-up  of a committee  as provided  for  in Article 
11 is not  entirely  unusual,  it would  warn  against activities  becoming  too  fragmented  and  removed 
from  political  debate.  Since  the present  proposal  is, to 
some  extent,  a prototype  for  future  Directives,  steps 
should  be taken  to ensure  that  coordination  is good 
and that  representatives  of both  employers  and 
workers  are involved  in its review. 
Done  at Brussels,  29 September  1977. 
The Chairman 
of the Economic  and  Social  Committee 
Basil  de FERRANTI