24. 10. 83 Official Journal of the European Communities No C 286/15 
Opinion on the proposal for a Council Directive amending Annexes I and III to Directive 
80/836/Euratom amending the Directives laying down the basic safety standards for the 
health protection of the general public and workers against the dangers of ionizing radia­
tion 
The text referred to the Committee has not yet been published in the Official Journal 
of the European Communities. 
A. LEGAL BASIS FOR THE OPINION 
On 13 December 1982 the Commission referred the abovementioned proposal to the 
Economic and Social Committee in accordance with Article 31 of the Treaty establish­
ing the European Atomic Energy Community. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
209th plenary session held in Brussels on 6 and 7 July 1983. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the Euro­
pean Atomic Energy Community, and in particular 
Article 31 thereof, 
Having regard to the request made by the Commis­
sion of the European Communities on 13 December 
1982 for an opinion on the proposal for a Council 
Directive amending Annexes I and III to Directive 
80/836/Euratom amending the Directives laying 
down the basic safety standards for the health pro­
tection of the general public and workers against the 
dangers of ionizing radiation, 
Having regard to the decision taken by its Bureau 
on 15 January 1983, instructing the Section for 
Energy and Nuclear Questions to draw up an 
opinion on the matter, 
Having regard to the opinion adopted by that Sec­
tion at its 81st meeting held on 10 June 1983, 
Having regard to the oral report made by the rap­
porteur, Mr Preben Nielsen, 
Having regard to the discussions at its meeting of 
7 July 1983 (209th plenary session of 6 and 7 July 
1983), 
Whereas the basic safety standards for the health 
protection of the general public and workers against 
the dangers of ionizing radiation were adopted by 
the European Atomic Energy Community in 
1959 (•) and subsequently amended in 1962 (2) and 
1966(3); Whereas the Commission submitted a number of 
proposals updating the basic standards on 27 July 
1972; 
Whereas the Economic and Social Committee 
issued an opinion on the above proposals on 
24 May 1973; 
Whereas in the light of the comments submitted to it 
the Commission revised its draft on 22 November 
1973 (4); 
Whereas the Council finally adopted the amend­
ments in a Directive dated 1 June 1976 (5); 
Whereas the Directive of 1 June 1976 required the 
Member States to align their legislation on the basic 
safety standards by 12 July 1978; 
Whereas on 30 May 1978 (6) the Commission pro­
posed that the deadline for bringing national legisla­
tion into line with the 1976 Directive should be 
extended by two years, i.e. until 12 July 1980; 
Whereas in its opinion of 12 July 1978, the Econo­
mic and Social Committee deplored the fact that the 
Directive of 1 June 1976 had not been implemented 
on schedule and stressed the need to progressively 
update Community standards to take account of 
developments in international research, and called 
for a revision of the Directive within the next few 
months; 
Whereas the Commission acknowledged the Com­
mittee's views and tabled a new proposal on 
23 November 1978; 
(') OJ No 11, 20. 2. 1959. 
(2) OJ No 57, 9. 7. 1956. 
O OJ No 216, 26. 11. 1966. (4) OJ No C 78, 5. 7. 1974. 
(5) OJ No L 187, 12.7. 1976. 
(6) OJ No C 147, 22. 6. 1978. 
No C 286/16 Official Journal of the European Communities 24. 10. 83 
Whereas the Committee in its opinion given on 
20 December ,1978 endorsed the Commission's pro­
posal, 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously, with five abstentions: 
1. The Committee would reaffirm its views 
expressed during discussion of the two 1978 draft 
Directives. On that occasion it called for regular 
updating of the basic safety standards for the health 
protection of the general public and of workers 
against the dangers of ionizing radiation, and thus 
bring Euratom standards into line with the latest 
recommendations of the International Commission 
on Radiological Protection (ICRP). 
It sees the present amendments to Annexes I and 
III as completing the Directive of 15 July 1980. 
Believing that it meets the Committee's call for a 
procedure that will gradually and regularly update 
safety standards, it approves this draft Council 
Directive, subject to the following general and spe­
cific comments: 
2. General comments 
2.1. The Committee endorses the Commission's 
view that the ICRP is a reputable scientific institu­
tion for drafting basic safety standards for protect­
ing people against the dangers of ionizing radiation. 
This should not, however, prevent the Commission 
from looking for other scientific sources which 
might provide still better data. In this connection, 
the Committee notes that the Commission has 
indeed occasionally used data other than that pro­
vided by the ICRP. 
2.2. The Committee believes that what it said in its 
opinion of December 1978 is equally relevant to the 
present proposal; these revised standards embody a 
number of guiding principles which, if respected, 
limit individual and collective doses of radiation 
arising from controllable exposures. Furthermore, 
the present draft Directive lays down maximum figures, but it is the Member States themselves who 
are responsible for improving protection. 
2.3. The Committee underlines the comments it 
made in its 1978 opinion concerning Article 6 in the 
1978 Directive. It said then that 'Article 6 of the 
revised standards set out a number of guiding prin­
ciples to be followed in limiting individual and col­
lective doses resulting from controllable exposures. 
The Committee considers that, as presently worded, 
these could be open to varying interpretations. In 
indent (a), the Committee believes that the 'advan­
tages' must take full account of the social as well as 
economic considerations. In indent (b), the Com­
mittee similarly believes that the word 'reasonably' 
cannot be interpreted solely in an economic sense. 
It must also include technical, social and medical 
factors' ('). 
3. Specific comments 
3.1. The Committee would point out that since the 
preamble to Annex III in the draft Directive refers 
to 'adults', the wording of the Annex proper should 
be amended to read 'adult members of the public' 
instead of simply 'members of the public'. 
3.2. The Committee asks that account be taken of 
the ICRP's proposal governing eye exposure to 
krypton radiation, which effectively would reduce 
the annual limit for exposure from 0,3 Sv per annum 
to 0,15 Sv. The Committee also asks that the 1980 
Directive be amended as regards the limit for the 
lens of the eye. 
The Committee urges the Commission to devise a 
procedure whereby the latest ICRP revisions are 
implemented in, or at the same time as, the present 
draft Directive. 
3.3. The Committee considers that as presently 
worded, the standards currently proposed are open 
to varying interpretations. Maximum clarity is of the 
essence if Member States are to use the Directive 
most effectively. The Committee believes that there 
is room for improvement in this area. Annexes I and 
III, which represent the main elements of the draft 
Directive, are particularly complicated. The Com­
mittee would point out that the groupings in 
Annex I are unsatisfactory and that it is unclear how 
some of the values of activities in Annex I have 
been arrived at. The Committee would like to see a 
single comprehensive table — where users could 
clearly see for each radionuclide what has to be 
done — in preference to the four groupings 
presently given in Annex I. In Annex III, a new 
(') OJ No C 128,21.5. 1979, p. 32. 
24. 10. 83 Official Journal of the European Communities No C 286/17 
column could usefully be added indicating the 
group from Annex I into which the radionuclide 
falls. 
4. Implementing of the Directive and future revi­
sions 
4.1. As regards the time-scale for introducing the 
proposed safety standards, the Committee notes 
with regret that all the Member States did not suc­
ceed in implementing the 1980 Directive on sched­
ule. 
4.2. IAEA has — together with certain other inter­
national organizations — worked out a recommen­
dation based on ICRP norms — and which in some 
ways goes further than the present draft Directive. 
The Committee requests the Commission to under­take very rapidly a major revision of the 1980 Direc­
tive, taking into account all relevant reports, espe­
cially the IAEA report. This should be done by the 
end of 1984. 
5. Final remarks 
5.1. The Committee notes with satisfaction that in 
November 1983 the Commission is organizing a 
seminar concerning 'Optimizing of protection 
against radiation'. 
The Committee hopes that the Commission will see 
that those organizations with a special interest in 
workers protection are able to attend the seminar in 
significant numbers. 
Done at Brussels, 7 July 1983. 
The Chairman 
of the Economic and Social Committee 
Francis CEYRAC 
Opinion on relations between the European Community and the United States 
A. LEGAL BASE FOR THE OPINION 
At its 201st plenary session held on 27 and 28 October 1982, the Committee, acting on 
a proposal from its Bureau in accordance with the fourth paragraph of Article 20 of its 
Rules of Procedure, decided to deliver an opinion on its own initiative on the above 
matter. 
B. OPINION OF THE ECONOMIC AND SOCIAL COMMITTEE 
The Economic and Social Committee prepared its opinion on the above matter at its 
209th plenary session held in Brussels on 6 and 7 July 1983. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to its decision of 27 October 1982, 
instructing the Section for External Relations to 
draw up an opinion on relations between the Euro­
pean Community and the United States, Having regard to the information report presented 
to it by the Section for External Relations on 
27 October 1982, 
Having regard to the report submitted by the rappor­
teur, Mr Staratzke, 
Having regard to its Rules of Procedure, and in Having regard to the opinion adopted by .the Sec-
particular Article 20 (4) thereof, tion for External Relations on 14 June 1983,