5. 4. 83 Official Journal of the European Communities No C 90/27 
9. Article 11 
9.1. In addition to the European Parliament, the 
Done at Brussels, 24 February 1983. 
The full text of the opinion is as follows: 
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 made by the Council on 
28 September 1982 for an opinion on the proposal for a 
Directive on the use of sewage sludge in agriculture, 
Having regard to the decision taken by the Bureau of 
the Economic and Social Committee on 13 October 
1982 instructing the Section for the Protection of the 
Environment, Public Health and Consumer Affairs to 
draw up an opinion on the matter, 
Having regard to the discussions at the abovementioned 
Section's 72nd meeting held on 1 February 1983, 
Having regard to the oral report submitted by the 
rapporteur, Mr Kolble, Economic and Social Committee should also be infor­
med every two years about progress on the implemen­
tation of the Directive. 
The Chairman 
of the Economic and Social Committee 
Having regard to the discussions on 24 February 1983 
during the 205th plenary session held on 23 and 
24 February 1983, 
HAS ADOPTED THE FOLLOWING OPINION 
unanimously: 
1. General comments 
1.1. This proposal is welcomed by the Committee. It is 
designed to harmonize provisions on the agricultural 
use of sewage sludge, which is desirable both for waste 
disposal and ecological reasons. The Commission 
intends that the harmonization should give due 
consideration to the legitimate interests of agriculture, 
and to public health, consumers and the environment. Francois CEYRAC 
Opinion on the proposal for a Council Directive on the use of sewage sludge in agriculture 
The text referred to the Committee has been published in Official Journal of the European 
Communities No C 264 of 8 October 1982, page 3. 
A. LEGAL BASIS FOR THE OPINION 
On 28 September 1982 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 205 th 
plenary session held in Brussels on 23 and 24 February 1983. 
No C 90/28 Official Journal of the European Communities 5. 4. 83 
1.2. To achieve these aims, sludge must be rendered 
inoffensive prior to its use in agriculture and 
unjustifiable gradual contamination of the soil must be 
prevented. 
1.3. The Committee feels that the main aims in this 
regard are the production of uncontaminated food and 
fodder, maintenance of soil fertility and the protection 
of ground and surface water. 
1.4. In addition, the correct use of sludge requires that 
farmers be given adequate guidance on precautions to 
be taken to avoid contamination of food and feed crops. 
1.5. In any case, users should not be held responsible 
in as far as it is up to treatment plants to ensure that 
sludge correctly complies with the mandatory values 
laid down in the Directive. 
1.6. The Commission has not yet proposed the 
standard analysis and measuring methods to be used for 
adapting the Directive to technical progress. Although 
the Committee agrees that this is an unsatisfactory 
situation, it feels even now, that it is urgently necessary 
for the use of sewage sludge to be covered by 
harmonized standards in all Member States. The 
Committee invites the Commission to pay special 
attention to drawing up uniform analysis and measuring 
methods and to draft provisions on this matter at the 
earliest opportunity. 
1.7. The Commission proposes that changes needed to 
adapt limit values and sampling analysis methods to 
technical progress should be referred to a Committee on 
Adjustment to Technical Progress. This would mean 
that the Economic and Social Committee would have no 
opportunity to give its views. Consequently, the 
Committee asks that the Commission at least hold 
consultations with representatives of interested parties 
on the Economic and Social Committee before 
submitting amendments to the Technical Progress 
Committee. 
1.8. The Committee assumes that the Commission will 
actively pursue its efforts (in application of Council 
Directive 76/464/EEC of 4 May 1976 concerning 
pollution caused by certain dangerous substances 
released into Community waters), to ensure that 
measures are taken 'at source' to prevent as far as 
possible dangerous substances from entering sewage 
sludge. 2. Specific comments 
Article 2 
2.1. Sewage sludge from plants treating only urban or 
similar effluents and serving less than 5 000 inhabitants 
per year is excluded from the scope of the proposed 
Directive. Given the urban concentration in several 
regions of the Community, the Committee questions 
whether this limit of 5 000 inhabitants is reasonable 
and wonders whether there should not be an exemption 
under Article 12 for cases of a special nature. 
Article 3 
2.2. The Committee notes that the Commission has 
not specified mandatory values for certain trace 
elements such as chromium, mercury and arsenic and 
stresses the urgency of this problem. The Committee 
also points to the potential hazards and suggests the 
article be amended. 
Articles 4, 5 and 6 
2.3. The Committee approves the proposed system for 
limiting the level of dangerous substances (Article 4) 
in sewage sludge, and the accumulation (Article 5) 
and concentration of dangerous elements in the soil 
(Article 6). 
2.4. The Committee feels that the provisions of 
Articles 5 and 6 are adequate per se. However, it has 
serious doubts as regards the adequacy of Article 5, 
when taken in conjunction with Annex I B. This is more 
particularly so in view of the fact that in the interests of 
protection of the environment and agriculture, it is 
necessary to ensure that the amount of dangerous 
substances in the soil remains below the limit values for 
as long a period as possible. For this reason the 
Committee recommends, in the interests of guaranteeing 
longer-term safety for the whole of Europe, that Article 
5 should prescribe stricter limitation of accumulation 
(e.g. the calculation period of more than 10 years). 
Article 8 
2.5. The Committee feels that in certain cases a 
six-week minimum time gap between the spreading of 
sludge on the soil and the harvesting of crops grown 
thereon is inadequate and does not take into account 
certain local factors. It would be appropriate therefore, 
5. 4. 83 Official Journal of the European Communities No C 90/29 
as indeed indicated by the Commission in its 
explanatory memorandum, to lay down a whole range 
of minimum intervals in accordance with local 
conditions. 
The Committee feels that Article 8 (3) should be 
reworded as follows: 
'Member States shall prohibit the spreading of 
sludge on crops whose products would be in direct 
contact with the sludge and which are supplied raw 
to consumers.' 
Article 9 
2.6. The Committee feels that the pH value indicated 
here does not take all the local characteristics of soils 
into account. 
Done at Brussels, 24 February 1983. 
The full text of the opinion is as follows: 
THE ECONOMIC AND SOCIAL COMMITTEE, 
Having regard to the Treaty establishing the European 
Economic Community, and in particular Articles 51, 
198 and 235 thereof, Article 17 
2.7. The Committee requests that in its report to the 
Commission, each Member State should indicate its 
sampling and analysis method, in order to assist the 
Commission in devising a common method of analysis. 
2.8. With regard to the penultimate phrase of this 
Article the Committee proposes that the following 
sentence be inserted after the words 'difficulties 
encountered': 
'Member States should equally report any disease or 
adverse effects on man, animals or plants 
attributable to or resulting from the spreading of 
sludge.' 
The Chairman 
of the Economic and Social Committee 
Francois CEYRAC 
Having regard to the request made by the Council of 
the European Communities on 17 January 1983 for an 
opinion on the proposal for a Council Regulation 
amending Regulation (EEC) No 1408/71 on the 
application of social security schemes to employed Opinion on the proposal for a Council Regulation amending Regulation (EEC) No 1408/71 
on the application of social security schemes to employed persons, to self-employed persons 
and to their families moving within the Community and Regulation (EEC) No 574/72 
laying down the procedure for implementing Regulation (EEC) No 1408/71 
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 17 January 1983 the Council referred the abovementioned proposal to the Economic 
and Social Committee in accordance with Articles 51, 198 and 235 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 205th 
plenary session held in Brussels on 23 and 24 January 1983.