No C 318/32 Official Journal of the European Communities 12. 12. 88 
Opinion on the proposal for a Council Directive concerning the minimum safety and health 
requirements for work with visual display units (fourth individual Directive within the 
meaning of Article 13 of Directive ...) (l) 
(88/C 318/13) 
On 23 March 1988 the Council, acting in pursuance of Article 118 A of the EEC Treaty, 
asked the Economic and Social Committee for an Opinion on the abovementioned proposal. 
The Committee instructed its section for social, family, educational and cultural affairs to 
prepare its work on this matter. The Section adopted its Opinion on 14 September 1988. 
The rapporteur was Mr Meyer-Horn and the co-rapporteur was Mr Etty. 
The Committee adopted the Opinion set out below at its 258th plenary session (meeting of 
28 September 1988) by 71 votes to 56, with 1 abstention. 
1. Introduction 
1.1. The present draft Directive is based on 
Article 118 A of the EEC Treaty and the Commission's 
programme concerning safety, hygiene and health at 
work(2). The Directive is the fourth of the individual 
Directives covering a specific subject announced in 
Article 13 and Annex I of the proposed Framework 
Directive of 7 March 1988 (3). It relates to minimum 
safety and health requirements in respect of work with 
visual display units (VDU). 
This fourth individual Directive dealing with VDU 
work should therefore be taken together with the frame­
work Directive. The latter Directive sets out a large 
number of general health protection provisions appli­
cable at the workplace which are complemented by the 
minimum requirements concerning VDU work set out 
in the present draft Directive. The two Directives thus 
both apply together to the field of VDU work. 
1.2. In order to take account of the specific nature 
of small and medium-sized undertakings it is pointed 
out in the Explanatory Memorandum that there is to 
be a certain flexibility as regards the implementation of 
the Directive, depending on the size of the undertakings 
concerned. Account is also to be taken of 'socio-econ­
omic factors'. 
As was already observed in the Committee's Opinion 
on the framework Directive (4), this does not in any 
way imply that different safety and health protection 
requirements in respect of VDU work are to be laid 
down depending on the size of the undertakings con­
cerned. The flexible approach with regard to the mini­
mum requirements should rather be embodied in 
accompanying measures designed to make it easier for 
small and medium-sized undertakings to observe the 
minimum requirements and the timetable for their 
introduction. 
1.3. In drawing up the draft Directive the Com­
mission consulted the Advisory Committee on safety, 
hygiene and health protection at work set up under 
(!) OJNoC 113,29.4. 1987, p. 7. 
(2) OJ No C 28, 3. 2. 1988. 
(3)(4) ESC Opinion of 28 April 1988 (OJ No C 175, 4. 7. 1988, 
p. 22). Council Decision 74/325/CEE of 27 June 1974. The 
Opinion of that Committee is however not published. 
1.4. Under the draft Directive Member States are to 
adopt the necessary legal and administrative provisions 
by 1 January 1991 are to inform the Commission of 
the standards and technical specifications adopted and 
are to report to the Commission on the practical appli­
cation of the Directive, indicating also the views of the 
two sides of industry. The Commission is to be assisted 
by a committee, which still has to be set up, in the 
implementation of the supporting measures set out in 
the draft Directive. 
It would be advisable for that committee to include 
expert representatives from the interest groups con­
cerned, in particular employers and employees. The 
Advisory Committee on safety, hygiene and health pro­
tection at work should also be involved, as should the 
Economic and Social Committee and the European 
Parliament, when amendements are being made to the 
Directive (see ESC opinion, points 2.12 and 2.13) (5). 
2. General comments 
2.1. The following observations complement those 
set out in the Committee's Opinion on the framework 
Directive (6). The views expressed in the latter Opinion 
also apply to safety and health protection in respect of 
VDU work. 
The draft Directive sets out minimum health and safety 
requirements for VDU operators. The Committee wel­
comes the fact that this proposal will bring about a 
further improvement in the health protection afforded 
to workers in some Member States where comparable 
national provisions do not exist or fall short of the 
proposed minimum requirements. The Committee also 
welcomes the proposed retention of higher levels of 
health protection in other Member States where the 
rules which go further than the proposed minimum 
requirements have been in force for many years. 
(5) OJ No C 175, 4. 7. 1988, p. 22. 
(6) OJ No C 175, 4. 7. 1988, p. 28. 
12. 12. 88 Official Journal of the European Communities No C 318/33 
2.2. The draft Directive contributes towards the 
standardization of the health protection provisions 
applicable to VDU work. As a result of the broad 
definition given in the draft Directive, future EC pro­
visions will apply to all VDU work: this is to be wel­
comed. However, care should be taken to ensure that 
the draft Directive covers VDU units and their accessor­
ies but not other equipment such as calculating 
machines with displays. 
2.3. The provisions laid down in the Annex to the 
draft Directive cover only a few fields of application. 
They do not cover, for example, the following areas: 
working document, food rests, the lay-out of equip­
ment, space needed for working with VDU, and the 
whole body of regulations relating to the minimization 
of exposure to X-rays, low-frequency electromagnetic 
fields, ultraviolet rays, electrostatic charges and ultra­
sound. Moreover the essential requirements set out in 
Annex I are far from complete. 
Furthermore, the authors of the draft Directive use 
terms such as 'adequate', 'flexible arrangement', 'psy­
cho-social factors' and 'aspects of health' without being 
more precise. Generally speaking, framework legis­
lation ought preferably to refer in respect of these terms 
to the definitions given in European standards. 
2.4. The draft Directive does not regulate the restric­
tions or breaks in the working time of persons doing 
monotonous VDU work on a continuous basis. Such 
restrictions are standard practice in some Member 
States; in the Netherlands, for example, they are rec­
ommended by the industrial safety inspectorate. In the 
Commission's view the restrictions or breaks in work­
ing time for VDU users may be regulated by national 
collective agreements. 
2.5. The draft Directive does not contain any pro­
visions with regard to the problem of harmful radiation 
which may occur in open-plan offices containing many 
VDU, especially where these are older models. Accord­
ing to the EC Commission the level of such emissions 
is far below the level of emissions from—much larger 
—television screens (though the TV viewer does sit 
further away from the screen than a VDU operator). It 
would, nonetheless, be appropriate to make a pre­
cautionary reference in the draft Directive to radiologi­
cal protection standards. In Germany, for exemple, 
there is paragraph 4.1.12 of the safety rules for office 
workstations equipped with a VDU [ref. GUV (statu­
tory accident insurance) 17.8] which regulates protec­
tion against X-rays. The establishment of minimum 
European requirements on the effects of electrostatic ' 
charges, ionizing radiation and electromagnetic waves 
is not yet possible given the current level of scientific 
knowledge in this field. However, stringent limits have already been introduced 
in Sweden in all three areas. The experience of public 
administrations in Sweden shows that such limits can 
be adhered to. Manufacturs have adjusted to the new 
requirements for the Scandinavian market. In the Feder­
al Republic of Germany, strict regulations concerning 
X-rays are already in force. 
3. Comments on the individual Articles 
3.1. Under Article 1 (2) and Article 2 the draft Direc­
tive is to apply to any user of a VDU. This field of 
application is approved. It ensures that there are no 
differing interpretations and rules at national level. 
Steps must be taken to ensure that display screens used 
outside offices (e.g. those used at airports and reception 
deks and for industrial control systems and monitoring 
operations in hospitals and in energy supply and distri­
bution undertakings) are also covered by the present 
Directive. 
The definition of a display screen given in the Directive 
is questionable insofar as it embraces all electronic 
screens, e.g. pocket calculators, digital watches, cash 
registers. This cannot be the intention, hence the need 
for a narrowing of the definition. 
3.2. For the sake of clarity, reference should be made 
in Article 4 to the consultation of workers or their 
representatives, as provided for in Article 8. 
There are some discrepancies in the different language 
versions of Article 4 (1). The German version speaks 
of Gefahren (dangers) whilst the French version speaks 
of risques (risks). 
A list of the various safety and health risks should 
perhaps be given in national framework regulations or 
standards. 
The term 'insofar as is reasonably possible' should be 
replaced by 'insofar as this is necessary to protect the 
health of workers' (see the Committee's Opinion in 
respect of Article 7 of the Commission Directive) (*). 
3.3. It is not clear whether the qualification 'insofar 
as is reasonably possible' in Article 6 (adaptation of 
workstations to comply with the minimum require­
ments) is meant in a financial or technical sense, particu­
larly as reference is also made in point 9 of the Annex 
to the need to take account of the 'psycho-social factors' 
applicable to work using VDU. In this case, too, the 
(') OJ No C 175, 4. 7. 1988, p. 28. 
No C 318/34 Official Journal of the European Communities 12. 12. 88 
qualification should be linked to health-protection 
requirements for employees or other objective con­
straints, such as the depreciation period for the equip­
ment, with reference being made to the framework 
Directive. 
3.4. There is a need to make a more precise reference 
in point 9 of the Annex ('operator/computer interface') 
to the stipulation in Article 7 (2) that workers are to 
be informed on 'all aspects' of 'physical or mental 
problems'. 
3.5. A reference should be made in Article 8 to the 
stage in the preparations at which workers or their 
representatives are to be consulted on the measures 
taken pursuant to this Directive which concern them 
directly. As regards definitions, attention is drawn to 
the Framework Directive of 27 November 1988 and 
the Committee's Opinion on the draft Directive (point 
2.2) (i). 
3.6. An ophthalmological examination of workers 
prior to commencing work at a workstation equipped 
with a VDU is stipulated in the first paragraph of 
Article 9. This is endorsed, although it will cause prob­
lems in some Member States with a less-developed 
medical infrastructure and—as in other areas of work 
—may have social consequences for workers found to 
be unsuitable because of eyesight problems. It would 
seem doubtful whether these consequences could be 
avoided by stipulating that these initial examinations 
should be carried out only at the request of the worker. 
It would therefore be desirable if the minimum Com­
munity rules provided for regular examinations, as is 
the case in some Member States, allowing a certain 
flexibility in those countries whose medical services are 
not yet adequate. 
In order to make matters clearer, it should be stipulated 
in the second paragraph of Article 9 that employers 
have to pay the cost of special glasses for workers, 
if the ophthalmological examination shows that such 
glasses are necessary for VDU work, bearing in mind 
that the focussing distance involved is different to that 
for normal reading. 
3.7. It is not clear from the wording of Article 11 (1) 
whether the 'laws, regulations and administrative pro­
visions' to be enacted by the Member States are necess­
ary in cases where, safety regulations and standards 
have been drawn up by professional associations or 
standards institutions and have virtually the same 
power as laws. It also appears necessary to specify in 
Article 11 that, under the draft Directive, the two sides 
of industry retain the right to adopt more far reaching 
provisions in collective agreements with regard to safety 
and health at work. 
(') OJ NoC 175,4.7. 1988, p. 22. 4. Comments on the Annex on minimum requirements 
concerning work with visual display units (VDU) 
4.1. The Annex setting out the minimum require­
ments contains a number of misleading or unclear 
terms. The Commission should add to the Annex a 
technical report. This technical report should preferably 
be drawn up in collaboration with the European Com­
mittee for Standardization (CEN) by a standards com­
mittee, on which the two sides of industry would play 
an active role. 
4.2. In the German version of paragraph 1 (display 
screen) the rules are mandatory ('shall be'), while other 
versions, such as the Spanish, say 'should be'; the differ­
ent versions should be aligned. 
Also, the German versetzbar is not the same as mobile 
in the French version, which means beweglich in 
German (and implies that it can also be rolled). 
As well as being rotatable, tiltable and movable, the 
screen should also be of a certain minimum size so as 
to display a sufficient amount of information. 
It should also be explicitly laid down that the screen 
should not emit rays that according to the state of the 
art are harmful to health (see 2.5). 
4.3. The rule in the first paragraph of point 2 that 
the keyboard is to be separate from the screen would 
mean that portable VDU with directly incorporated 
keyboards could no longer be used in an office. Instead 
of referring to a 'position avoiding muscle fatigue' and 
a 'space (...) sufficient to provide support for the hands 
and arms' it would be better to have a drawing showing 
an ergonomically designed VDU workstation (see 
Appendix), as in point 4.6.8 of the previously mentioned 
German safety standard GUV 17.8 or in the Digest of 
Working Conditions No 5/1986 of the International 
Labour Office (ILO). 
If the keyboard is to be separate from the screen it 
would also be a good idea to refer to standards which 
(as in GUV 17.8, point 4.3.1) lay down that the key­
board must not slip or slide about. 
4.4. Likewise, the directions about the work desk in 
paragraph 3 should be supplemented by the drawing 
mentioned in 4.3, which is reproduced in the Appendix. 
The rule that the document holder shall be situated on 
the desk on the same level as the screen is inappropriate. 
It would be better to have a rule like that in point 3.4 
of DIN standard 66234, whereby the document holder 
is to be situated in such a way as to minimize the need 
to maintain awkward positions for long periods and 
frequently make unnecessary adjustments when chang­
ing one's glance. 
12. 12. 88 Official Journal of the European Communities No C 318/35 
4.5. The rule in paragraph 6 that neither the screen 
nor the operator should be facing a window is unnecess­
ary, especially as glare from windows can be cut out 
or reduced by using specially coated windows or blinds. 
It would be better to have a rule which specifies the 
result to be achieved: VDU workstations should be so 
designed that sources of light, such as windows or 
lamps, and brightly coloured fixtures or walls cause 
no direct glare and, as far as possible, no disturbing 
reflections on the screen. 
4.6. The rule in paragraph 7 on the noise of the 
printer should be supplemented, because there are 
soundproofed printers, or laser printers which are virtu­
ally silent, and there should be some clarification about 
the noise level which does disturb concentration or 
understanding of speech. If it is decided to express this 
in decibels, it should be borne in mind that the noise 
level at the workplace should not exceed 55 dB (A) for 
predominantly mental tasks, or 70 dB (A) for simple or 
predominantly mechanized office tasks and comparable 
tasks; the noise level produced by office machinery, as 
Done at Brussels, 28 September 1988. recorded at the workstation, should accordingly be less 
than 70 dB (A). 
4.7. The rule about 'an adequate level of humidity' 
in paragraph 8 should refer to precise standards. It is 
doubtful whether these can be laid down throughout 
the Community. 
The Directive should therefore only lay down that 
in air-conditioned workplaces not only the rules for 
temperature but also those for humidity should be laid 
down at national level. 
4.8. The 'principles of software ergonomics' and 
'psycho-social factors' mentioned in paragraph 9, which 
are to be taken into account when writing programmes, 
should also refer to national or European standards. 
These should include principles of 'dialogue manage­
ment' and guidelines for the adaptation of the properties 
of computer programmes (dialogue systems) to the 
intellectual characteristics of the people working with 
them, having regard, in particular, to cases where wor­
kers carry out monotonous procedures on a continuous 
basis. 
The Chairman 
of the Economic and Social Committee 
Alfons MARGOT 
No C 318/36 Official Journal of the European Communities 12. 12. 88 
APPENDIX 
imtrtl 
Example of an economically designed VDU workstation with a working top which cannot be adjusted in 
height and with the workstation's equipment arranged one behind the other