12. 6. 76 Official  Journal  of the European  Communities No C 131/13 
2. However,  it is unable  to approve  either  the 
length  of the periods  proposed  by the Commis-
sion or the dates  on which  these  periods  are to 
start  and  end.  The  periods  will  already  differ 
appreciably  in 1976  in those  Member  States 
which  have  decided  to introduce  summer  time 
this year. 
3. So as not  to complicate  the  coordination  of 
timetables  for international  and  intercontinental 
communications,  the Committee  thinks  that  it is 
highly  desirable  for  summer  time  to uniformly 
begin  in the  week  immediately  preceding  or 
following  1 April  and  end  in the week  immedi-ately  preceding  or following  1 November  each 
year. 
4. The  Committee  would  point  out  that  even 
after  this  system  has  been  introduced,  there  will 
still be two  changes  per year  in the time  relation-
ship between  those  Member  States  which  apply 
summer  time  and  those  which  do not.  This  will 
always  pose  certain  problems  for  international 
and intercontinental  communications. 
5. The  Committee  therefore  thinks  that  it is 
advisable  to examine  right  away  whether  summer 
time could  be aligned  at European  level. 
Done  at Brussels,  25 February  1976. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
Opinion  on the proposal  for a Council  Directive  relating  to the quality  of water 
for human  consumption 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the 
European  Communities  No  C 214  of 18 September  1975,  page  2. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 11 August  1975,  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 137th  plenary  session,  held  in Brussels  on 25 and  26 February  1976. 
The full  text  of the opinion  is as follows: 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the request  for an opinion  on 
11 August  1975  by the Council  of the European 
Communities, 
Having  regard  to the  Treaty  establishing  the 
European  Economic  Community,  and  in partic-
ular Article  100  thereof, 
Having  regard  to the  decision  of the Bureau  of 
the Economic  and  Social  Committee  at its meet-
ing on 23 September  1975  to entrust  the Section for Protection  of the Environment,  Public  Health 
and Consumer  Affairs  with  the preparation  of an 
opinion, 
Having  regard  to the  opinion  issued  by the 
Section  for Protection  of the Environment,  Public 
Health  and  Consumer  Affairs  at its meeting  held 
on 10 February  1976,  and  the report  prepared  by 
Sir John  Peel, 
Having  regard  to the  discussion  at its 137th 
plenary  session  held  on 25 and  26 February  1976 
(meeting  of 25 February  1976), 
No C 131/14 Official  Journal  of the European  Communities 12. 6. 76 
Whereas  water  is used  universally  for drinking 
and in preparation  of food  and  drink  and  is 
necessary  for normal  health; 
Whereas  in many  places  within  the  European 
Communities  the  quality  of water  for  human 
consumption  is satisfactory  and  has  been  so for 
many  years; 
Whereas  deviation  from  quality  standards  in 
relation  to certain  parameters  could  be a serious 
danger  to public  health,  and  so it is desirable  to 
lay down  quality  standards  with  which  all water 
intended  for  drinking  and  for  use  in the 
preparation  of food  and drink  must  comply; 
Whereas  there  is an increasing  danger  of pollu-
tion of water  by toxic  chemical  substances  and 
microbiological  organisms, 
HAS  ADOPTED  THE  FOLLOWING  OPINION: 
by 40 votes  to eight  with  three  abstentions: 
1. General  comments 
1.1. The  Economic  and  Social  Committee  wel-
comes  the general  principles  underlying  the Com-
mission's  proposals  for setting  standards  for the 
quality  of water  for  human  consumption,  but 
nevertheless  wishes  to draw  attention  to a num-
ber of the practical  problems  that  will  inevitably 
arise  within  the Member  States,  if the Directive  is 
applied  in every  detail  in its present  form.  The 
application  of all the standards  referred  to in the 
Directive  will  create,  especially,  problems  for 
industry.  The  range  of industrial  and  other 
interests  is very  wide,  but prior  consultations  did 
not take  place  and  because  of this  a certain number  of serious  problems  have  not  been 
discussed.  The  Committee  expects  these 
consultations  to take  place  right  away,  and 
considers  that  the  documents  which  have 
led to the  establishment  of specific  parameters 
(e.g. for  zinc)  should  be made  available  to the 
industries  concerned. 
1.2. The  preamble  invokes  only  Article  100  of 
the Treaty.  The  Committee  thinks  it should  also 
invoke  Article  235. 
1.3. The  Committee  feels  that  while  the reason 
behind  a number  of the  values  of the  quality 
parameters  is obvious,  in many  instances  these 
values  seem  to be arbitrary  and  unrealistic.  Some 
of these  parameters  should  be more  realistic  in 
their  limiting  values,  so as to avoid  many  existing 
satisfactory  supplies  being  unnecessarily  classified 
as unsatisfactory,  and  to avoid  subsequent  heavy 
expenditure  in seeking  to make  these  supplies 
conform  with  rigid  and  arbitrary  requirements. 
The Committee  would  point  out  that  in various 
sectors  of the foods  and  drinks  industry,  water  is 
in fact  used  which  does  not  comply  with  the 
proposed  Directive,  and  apparently  no harm  to 
public  health  has resulted. 
1.4. The  Committee  appreciates  that  the Com-
mission's  primary  aim  is the protection  of large 
populations  in urban  areas,  where  the  drinking 
water  supply  is exclusively  from  public  sources. 
However,  the  Directive  does  in fact  include  all 
water  for  human  consumption  and  therefore 
includes  private  sources  of water  from  wells  and 
bore  holes.  In many  rural  areas  within  the 
Community  such  sources  are  the  only  water 
supply  and  in many  Member  States  at the present 
time local  water  authorities  do not have  properly 
documented  information  about  the  existence  of 
these  sources,  which  remain  unanalysed.  While  it 
is obviously  desirable  that  these  sources  of water 
should  be monitored  and  controlled  eventually,  it 
will inevitably  take  a considerable  time  before 
this can be achieved. 
1.5. There  are very  special  problems  related  to 
water  which  is used  by the  food  and  drink 
industry.  It is important  that  the Directive  should 
not impose  sampling  and  other  special  controls 
on any  part  of the  industry,  which  draws  its 
water  from  the  national  potable  water  supply, 
12. 6. 76 Official  Journal  of the European  Communities No C 131/15 
and is entitled  to rely  on the  quality  of the 
publicly-supervised  water  supply.  However,  in 
some  countries  factories,  even  though  they  are 
connected  to the  public  water  supply,  also  use 
water  from  private  wells  on their  land,  either 
because  the public  water  supply  is insufficient,  for 
economic  reasons  and  because  of special  qualities 
in some  areas.  Responsibility  for the monitoring 
and sampling  of such  supplies  will  need  to be 
clearly  defined. 
1.6. The  Committee  feels  that  in laying  down 
quality  standards  the  primary  consideration 
should  be the protection  of public  health.  Conse-
quently  it should  be  possible  to distinguish 
between  parameters  which  are really  important  in 
the interests  of public  health  and  should  therefore 
apply  to all water  related  to human  consumption, 
and those  which  are  included  for  aesthetic  or 
operational  reasons.  Inevitably  there  will  be very 
heavy  financial  costs  involved  in the  sampling 
and analyses  — whether  the costs  fall  on public 
authorities,  the  food  and  drink  industry  or on 
private  individuals.  If this  is necessary  for  the 
sake of human  health,  this  financial  burden 
must  be met,  but  to involve  the  industry  in 
considerable  expense  in trying  to meet  quality 
standards  in relation  to some  parameters,  which 
are of less  importance  or even  unnecessary,  is 
unjustifiable. 
1.7. The  Committee  notes  with  satisfaction 
that the  standards  laid  down  in the  Annexes 
relate  broadly  to those  of the  World  Health 
Organization  (WHO).  However,  in many  instan-
ces the  standards  are  much  stricter  and  the 
Committee  wonders  what  justification  there  is for 
this. However,  there  is no indication  of how  they 
relate  to the  existing  standards  in the  Member 
States.  There  is a great  increase  in the  use  of 
surface  water  for  drinking  water.  On  the  Eur-
opean  continent  such  rivers  as the  Rhine  have 
their  origins  or part  of them  outside  the  Com-
munity  countries,  and  in many  instances  they  are 
heavily  polluted.  Whether  the  polluter  has  to 
spend  more  in order  to pollute  less  or the 
extractor  spend  more  in order  to comply  with  the 
standards,  economic  problems  will  inevitably 
arise.  The  Committee  would  like  to know  how 
much  of an economic  burden  may  be placed  on 
some  Member  States  in order  that  they  may 
comply  with  the standards  laid  down.  The  Com-
mittee  thinks  that  it may  be necessary,  where  the 
standards  laid  down  are  unnecessary  because 
departures  from  them  cause  no harm,  or unreal-
istic because  they  cannot  be achieved  at present, to consider  the idea  of regional  exceptions  which 
would  be granted  nationally. 
1.8. The  Committee  believes  that  there  are 
problems  related  to enforcement  which  have  not 
been  fully  examined  and  which  will  inevitably 
lead to difficulties.  Public  water  authorities  in 
many  instances  have  no control  over  the piping 
that takes  the water  from  the public  main  to the 
point  from  which  it is drawn  by the consumers  or 
manufacturers  (i.e.  the tap).  Factories  or private 
individuals  may  modify  the water  (e.g.  by soften-
ing systems).  Furthermore,  with  many  of the 
materials  being  used  for  drinking  water  pipes 
within  the Member  States,  it is very  likely  that  the 
limits  set will  be exceeded  on occasions.  Replace-
ment  will  be both  expensive  and  time  consuming. 
Legislation  will  be necessary  to give  local  water 
authorities  the right  of entry  to take  samples  for 
testing  at the  tap,  and  a system  of grants  may 
have  to be introduced,  if in fact  renewal  of piping 
is shown  to be necessary  in order  to comply  with 
the quality  standards  laid  down. 
1.9. Water  is drunk  in considerable  quantities 
by the  public  travelling  in different  types  of 
public  transport.  The  Committee  wonders 
whether  the  quality  standards  are  intended 
to apply  to these  sources  of drinking  water  and 
if so what  methods  of enforcement  are proposed 
and where  legal  responsibility  for sampling  must 
lie. 
1.10.  Natural  mineral  waters  and  medicinal 
waters  are  excluded  from  the  Directive  as are 
aerated  waters.  The  Committee  feels  that 
there  is a need  for  clarification  in regard  to 
those  waters  which  are  commonly  referred 
to as mineral  waters  and  other  forms  of bottled 
water. 
1.11.  The  Committee  believes  that  it is absol-
utely  essential  that  some  guidelines  should  be 
given  in order  to meet  with  some  emergency 
situations  and  that  these  cannot  always  be left 
to the  discretion  of the  local  authorities.  For 
example,  bearing  in mind  the  fact  that  it is 
impossible  suddenly  to cut  off  the  supply  of 
water,  and  that  it is obviously  essential  to main-
tain a water  supply  even  if, on sampling  and 
analysis,  departure  from  the standard  laid  down 
is revealed,  when  and  how  must  a local  water 
authority  act?  With  such  a large  series  of parame-
ters listed,  at which  point  does  a given  supply 
No C 131/16 Official  Journal  of the European  Communities 12. 6. 76 
become  unacceptable?  The  Committee  thinks  that 
some  guidelines  are  necessary  in relation  to the 
operation  of the  exceptional  maximum  admissi-
ble concentrations. 
2. Specific  comments 
2.1. Article  2 
2.1.1.  It  would  be better  to use  the  term 
'physico-chemical  properties'  instead  of 'physico-
chemical  structure'. 
2.1.2.  In  the  third  indent  it should  be made 
clear  where  the point  of sampling  is, if the water 
is to comply  with  the  quality  standards  laid 
down.  The  water  that  is actually  used  in the 
preparation  or preservation  of foodstuffs  or 
drinks  may,  in some  factories  be different  from 
that delivered  to the  factory  from  the  public 
water  supply  by reason  of deliberate  modifica-
tion. 
2.1.3.  There  are  also  factories  within  the 
industrial  sector  using  water  with  special  qual-
ities,  vital  to the  manufacture  of their  products 
and which  has been  used  for many  years  without 
harm  to public  health. 
2.1.4.  Furthermore,  it is unnecessary  to include 
water  used  in industry  for certain  purposes,  e.g., 
the initial  washing  of containers  and  the washing 
and transportation  of certain  raw  materials.  This 
facility  is particularly  important  in the  case  of 
waters  which  are  recycled  within  a production 
unit in order  to provide  economies  of both  water 
and energy.  In some  instances  these  recycled 
waters  may  only  be used  for the initial  washing 
which  is then  completed  with  waters  of higher 
quality. 
2.2. Article  3 
2.2.1.  Aerated  waters  are not defined.  Hence  it 
is unclear  whether  spring  waters,  such  as those  of 
France  and  Belgium,  are or are not excluded  from 
the scope  of the Directive. 
2.3. Article  4 
2.3.1.  The  Committee  believes  that  the 
parameters  referred  to in Annex  I are much  too detailed.  It would  be more  practicable  to confine 
the Directive  to specifying  maximum  limits  for 
those  substances  known  to be toxic  and  therefore 
of which  control  is essential  and  to specific 
guidelines  for all those  parameters  where  there  is 
no evidence  of a health  hazard.  In regard  to the 
reference  to guide  levels  in clause  2, however,  the 
Article  should  be amplified  to read: 
'any concentration  immediately  below  or above 
that provided  for  in the  guide  level  columns 
shall  be considered  to be entirely  satisfactory, 
provided  it is not  less  than  the  minimum 
required  concentration  (if  any).' 
2.4. Article  5 
2.4.1.  The  Committee  thinks  that  a fourth 
clause  should  be added  concerning  the establish-
ment  of some  consultative  machinery  in order  to 
deal with  the problems  that  will  inevitably  arise 
in relation  to exceptions. 
2.5. Article  6 
2.5.1.  The  second  paragraph  should  begin  'In 
most  cases  monitoring  is based  on sampling  and 
analysis  and  in such  cases',  etc. 
2.5.2.  The  criteria  for deciding  the number  and 
position  of sampling  locations  must  be defined  in 
the first  instance  — otherwise  any  specification  of 
sampling  frequency  will  be meaningless. 
2.5.3.  The  frequency  of sampling  should  not 
only  depend  upon  the  size  of the  population 
served  and  the  capacity  of the  water  supply 
installation  but also  on the relative  importance  of 
the parameters  being  measured  and  their  expect-
ed variability  in concentration. 
2.5.4.  The  location  of sampling  points  must  be 
clearly  defined.  The  term  drinking  water  implies 
emerging  from  consumers'  taps.  Therefore,  samp-
ling at household  taps  must  be the  primary 
consideration.  In cases  where  numerical  stan-
dards  are  exceeded,  sampling  could  be under-
taken  at selected  points  within  the  distribution 
system  in order  to determine  the  reason  for 
unsatisfactory  water  quality. 
12. 6. 76 Official  Journal  of the European  Communities No C 131/17 
2.6. Article  8 
2.6.1.  The  Committee  would  stress  that  all 
interests  should  be adequately  represented  on the 
Committee. to replace  certain  types  of piping  throughout  the 
Community  could  not be done  within  a two-year 
period.  Shortage  of both  trained  personnel  and  of 
finance  will  inevitably  delay  the implementation 
of other  proposals  within  the Directive. 
2.7. Article  12 
2.7.1.  The  Committee  believes  that  some  grea-
ter degree  of flexibility  is necessary  under  this 
Article.  Mandatory  criteria  related  to public 
health  must  be enforced  immediately  or with  the 
absolute  minimum  of delay.  On the other  hand, 2.8. Annexes 
2.8.1.  The  Committee  has submitted  a series  of 
detailed  comments  on the  three  Annexes,  which 
emerged  during  the discussion  within  the Section 
and which  are included  in the report. 
Done  at Brussels,  25 February  1976. 
The Chairman 
of the Economic  and  Social  Committee 
Henri  CANONGE 
ANNEX 
to the opinion  of the Economic  and  Social  Committee 
The following  amendments  were  rejected  during  the discussions: 
Item  1.3 (last  sentence) 
Delete  'and  apparently  no harm  to public  health  has  resulted'. 
Reason 
The fact  that  no cases  of damage  resulting  from  use  of the  water  are  known  does  not  prove 
that damage  has  not  occurred  or that  damage  is not possible  in the future. 
Voting 
For:  14,  against:  24,  abstentions:  2. 
No C 131/18 Official  Journal  of the European  Communities 12. 6. 76 
Item  2.1.3 
End of the paragraph  to read: 
and in some  cases  this  water  has  been  used  for  many  years  without  known  harm  to 
public  health.' 
Reason 
The fact  that  no cases  of damage  resulting  from  use  of the  water  are  known  does  not  prove 
that damage  has  not  occurred  or that  damage  is not possible  in the future. 
Voting 
For:  19,  against:  24,  abstentions:  2. 
Item  2.1.4 
Delete. 
Reason 
Use of impure  water  should  not  be allowed  even  for  initial  washing,  because  further 
washings  in pure  water  are  not  sure  to remove  completely  any  dangerous  substances  left  by 
the impure  water. 
Voting 
For:  20,  against:  22,  abstentions:  2. 
Opinion  on the  proposal  for  a Council  Directive  on waste  from  the  titanium 
dioxide  industry 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the 
European  Communities  No  C 222  of 29 September  1975,  page  110. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 29 July  1975,  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 137th  plenary  session,  held  in Brussels  on 25 and  26 February  1976. 
The full  text  of the opinion  is as follows: