No C 204/34 Official  Journal  of the European  Communities 30. 8. 76 
Penultimate  sentence  of 2.7.1. 
'As regards  the  present  proposal,  however,  it must  be recognized  (a) that  producer  groups 
at present  account  for only  a very  small  part  of the  trade  in potatoes  for human  consumption 
and (b)  that  contracts  are  gradually  playing  an increasing  role  in relations  between  pro-
ducers,  merchants  and  processors.' 
Voting 
for: Large  majority, 
against:  8, 
abstentions:  18. 
Opinion  on proposals  for: 
— a Council  resolution  concerning  the  determination  of criteria  for sulphur  dioxide 
and suspended  particulate  matter  in urban  atmospheres 
— a Council  Directive  concerning  health  protection  standards  for  sulphur  dioxide 
and suspended  particulate  matter  in urban  atmospheres 
The text  referred  to the Committee  has been  published  in Official  Journal  No C 63 of 
19 March  1976,  page  5. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 8 March  1976  the  Council  referred  the  abovementioned  proposals  to the 
Economic  and  Social  Committee  in accordance  with  Article  198  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 
140th  plenary  session,  held  in Brussels  on 30 June  and  1 July  1976. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  Treaty  establishing  the Euro-
pean  Economic  Community,  and  in particular  Article 
198 thereof, 
Having  regard  to the request  for an opinion  made  by 
the Council  of the  European  Communities  on 
8 March  1976, 
Having  regard  to the decision  taken  by its Chairman 
on 10 March  1976,  instructing  the  Section  for 
Protection  of the  Environment,  Public  Health  and 
Consumer  Affairs  to draw  up an opinion  and  a 
report  on the matter, 
Having  regard  to the opinion  issued  by the  Section 
for Protection  of the  Environment,  Public  Health 
and Consumer  Affairs  on 8 June  1976  and  the report 
submitted  by the rapporteur,  Mr Eboli, Having  regard  to the discussion  at its 140th  plenary 
session,  held  on 30 June  and  1 July  1976  (meeting  of 
30 June  1976), 
HAS  UNANIMOUSLY  ADOPTED  THE  FOLLOWING 
OPINION: 
The Economic  and  Social  Committee  approves  the 
proposals,  subject  to the comments  set out below. 
1. General  comments 
1.1. The  Committee  agrees  with  the  aim  of the 
proposals.  Such  measures  help  considerably  to 
protect  health. 
30. 8. 76 Official  Journal  of the European  Communities No C 204/35 
1.2. It  is pleased  that  the  Commission  has  based 
its proposals  on  a thorough  study  of the  two 
pollutants,  and  gives  a vast  and  clearly  representative 
bibliography. 1.8. However,  the  Committee  attaches  great 
importance  to the  work  of perfecting  the  analysis 
methods  for  suspended  particulates  and  sulphur 
dioxide,  in order  to make  monitoring  of air quality 
standards  as precise  as possible  and  thus  ensure  that 
the goals  of the Directive  can be achieved. 
1.3. The  proposed  Directive  allows  a certain 
amount  of leeway  as regards  the  date  by which  the 
standards  are  to be met.  This  has  obviously  been 
done  because  of the  economic  problems  involved. 
Nevertheless,  from  the  health  point  of view  early 
application  of the  standards  is desirable.  The  Com-
mittee  would  like  to see them  given  effect  as soon  as 
possible,  though  the present  two-stage  deadline  (1982 
and 1987)  should  be retained. 
1.4. On  the  basis  of current  scientific  knowledge 
and the  epidemiological  studies  that  have  been 
carried  out,  the Committee  considers  that  the selected 
standards  will  be adequate  to control  the  level  of 
suspended  particulate  matter  ('black  smoke'),  which 
is the  more  dangerous  of the  two  pollutants.  The 
sulphur  dioxide  standards  are  a function  of  the 
'black  smoke'  standards. 1.9. The  Committee  would  stress  the  importance 
in this  regard  of the  Committee  (set  up by Article  8) 
which  is to be responsible  for amending  the Directive 
in the  light  of technical  and  scientific  progress.  The 
said Committee  should  also  be assigned  the  task  of 
constantly  updating  the analysis  methods  in the  light 
of the latest  scientific  knowledge. 
1.10.  The  Committee  thinks  the  above  Committee 
should  be given  the  results  of the  epidemiological 
study  being  carried  out  by the  Commission  into  the 
effects  of this  type  of pollution  on children. 
1.11.  Finally,  it is noted  that  the Commission  took 
an active  part  in the  most  recent  WHO  meetings  on 
the subject  and  has  taken  account  of these  meetings 
in the Directive. 
1.5. The  Committee  considers  the  limits  for  the 
two pollutants  to be justified,  in view  of the  fact 
that they  are  based  on epidemiological  studies  that 
have  included  high-risk  groups  (children,  old  people, 
and sufferers  from  cardiovascular  disorders,  etc.) 
among  their  subjects  and  that  these  groups  cannot 
be left  out  of account  when  laying  down  health 
standards  for the whole  population. 2. Specific  comments 
2.1. Comments  on  the  proposal  for  a Council 
resolution  concerning  the  determination  of 
criteria  for  sulphur  dioxide  and  suspended 
particulate  matter  in urban  atmospheres 
2.1.1.  Third  recital 
1.6. Furthermore,  the  Committee  feels  that  the 
limits  in Annex  I are  less  severe  than  they  appear 
because  they  are medians  of daily  means  and  because 
winter  is treated  separately. 
1.7. The  Committee  would  draw  attention  to the 
technical  limitations  of the  analysis  methods  to be 
used  to measure  the  concentrations  of the  pollutants. 
The limitations  mean  that  the resultant  measurements 
will not  always  be absolutely  comparable.  This  said 
the Committee  must  approve  use  of these  methods 
in the  present  state  of scientific  knowledge,  since 
they appear  to suit  the  requirements  laid  down  by 
the Directive. 2.1.1.1.  The  third  recital  should  be amended  to 
read: 
'Whereas  in the  current  state  of scientific  and 
technical  knowledge,  analysis  of criteria  permits  in 
particular  the  identification  of the  levels  of pollu-
tion which  have  certain  undesirable  or harmful 
effects  on man,  and  selection,  with  a sufficient 
degree  of accuracy,  of "exposure  levels"  for  the 
preparation  of quality  objectives  and  standards.' 
2.1.2.  Annex  I 
2.1.2.1.  The  Committee  considers  that  expressions 
such  as 'several  days',  'slightly  lower'  and  'long 
No C 204/36 Official  Journal  of the European  Communities 30. 8. 76 
term',  which  are used  repeatedly  in this  Annex,  give 
an impression  of vagueness  which  could  be damaging 
when  the exposure  levels  in Annex  II are considered 
for acceptance. 
2.1.2.2.  The  Committee  suggests  replacing  'several 
days'  by 'less  than  a month',  deleting  'slightly',  and 
replacing  '100  [i g/m3  as long  term  averages'  by 
'an average  of 100  fi g/m3  over  a prolonged  period' 
(to avoid  confusion  with  the  concept  'long-term 
exposure'  in Annex  II). 
2.2. Comments  on  the  proposal  for  a Council 
Directive  concerning  health  protection 
i standards  for  sulphur  dioxide  and  suspended 
particulate  matter  in urban  atmospheres 
2.2.1.  Fourth  recital 
2.2.1.1.  The  fourth  recital  should  be amended  to 
read: 
'Whereas  the health  protection  standards  for those 
two pollutants  consist  of concentrations,  observed 
over specified  periods  of time,  below  which  it 
appears  from  current  scientific  and  technical 
knowledge  that  there  is no unacceptable  hazard  to 
health.' 
This  qualification  is necessary  because  the proposed 
Directive  provides  for revision  of the standards  in the 
light  of new  scientific  and technical  knowledge. 
2.2.2.  Article  1 
2.2.2.1.  The  Committee  recommends  the addition 
of 'simultaneously  present'  after  'suspended 
particulates'  in Article  1 (1),  to make  it clear  why 
the two  pollutants  are linked  in the tables  in Annexes 
I and II. 
2.2.3.  Article  3 
2.2.3.1.  Article  3 (1) should  be amended  to read: 'The  Member  State  shall,  where  this  has  not  been 
done  already,  establish  a measurement  network 
for these  pollutants  in all urban  areas  where  the 
concentrations  may  approach  or exceed  the  air 
quality  standards  listed  in Annex  I. The  measure-
ment  networks  shall  have  regard  to the  Council 
Decision  of 24 June  1975  establishing  a common 
procedure  for the exchange  of information  between 
the surveillance  and  monitoring  networks  based 
on data  relating  to atmospheric  pollution  caused 
by certain  sulphur  compounds  and  suspended 
particulates.' 
2.2.4.  Article  4 
2.2.4.1.  The  words  'ar ground  level'  should  be 
added. 
2.2.5.  Article  9 
2.2.5.1.  The  following  should  be  added  to 
Article  9(1): 
'The  Committee  shall  in any  case  be convened 
at least  once  a year.' 
2.2.6.  Annex  I 
2.2.6.1.  The  Committee  suggests  that  '(determined 
as "black  smoke")'  be  added  after  'suspended 
particulates',  as is the  case  in Annex  I of the 
proposal  for a resolution. 
2.2.7.  Annex  III 
2.2.7.1.  The  chapter  on  suspended  particulates 
should  conclude  with  the  first  part  of the  note, 
namely: 
'This  method  is still  adequate  for  this  purpose, 
though  there  is a need  for more  refined  methods 
to determine  physical  and  chemical  composition  of 
particles  due  to the changing  pattern  of fuel  usage 
in the Community.' 
A new  note  applying  to both  sulphur  dioxide  and 
suspended  particulates  should  state  the  need  to 
promote  studies  into  new  analysis  methods  for  the 
two pollutants. 
Done  at Brussels,  30 June  1976. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE