10. 9. 79 Official  Journal  of the European  Communities No C 227/31 
8. The  Committee  is pleased  that,  alongside  external 
safety,  the  programme  also  covers  the  safety  and 
protection  of people  working  with  plutonium.  The  first 
programme  has  shown  that  the irradiation  of workers 
and the public  which  results  from  plutonium  processing 
can be kept  below  the  levels  permitted  by current 
radiation  protection  standards;  but  the development  of 
alternative  technologies  under  the  programme  is of 
particular  importance,  in view  of the  aim  of reducing 
irradiation  to the absolute  minimum. 
9. Without  going  into  the  technical  details  of the 
programme,  which  embraces  five  projects,  the 
Committee  thinks  that  the programme  is balanced  and 
properly  coordinated  with  the activities  of the Member 
States. 
10. Given  the importance  of cross-frontier  transport 
the relatively  large  appropriation  proposed  for Project  3 
(transport  of plutonium  and  plutonium  fuels)  seems 
justified  in a Community  programme. 
11. The  extremely  important  question  of research  and 
development  work  on safeguards  against  the illegal  use 
of plutonium  is deliberately  dealt  with  only  briefly  in the 
programme.  Within  the  Community,  this  area  is 
Done  at Brussels,  23 May  1979. discussed  and  coordinated  in ESARDA  (European 
Safeguards  Research  and  Development  Association),  and 
the necessary  research  and  development  is dealt  with 
mainly  by Community  establishments  in direct  projects. 
12. The  Committee  refers  to the  international 
discussions  in INFCE  (International  Nuclear  Fuel  Cycle 
Evaluation)  which  are  drawing  to a close.  The  aim  of 
those  technical/political  discussions  is to study  the 
various  nuclear  fuel  cycles  in connection  with  the 
non-proliferation  of nuclear  weapons  and  to conclude 
international  agreements.  In  all  probability,  the 
programme  under  review  is flexible  enough  to 
accommodate  any  INFCE  findings;  but  it should  be 
examined  as soon  as the findings  are announced,  and  if 
necessary  adjusted.  However,  the  decision  on  the 
programme  under  review  should  not be deferred  until  the 
end of the INFCE  discussions,  since  any adjustments  will 
be relatively  minor. 
13, The  Committee  notes  that  the  Advisory 
Committee  on Programme  Management  is to play  its 
now traditional  role,  and  that  the programme  is to be 
reviewed  and  progress  report  drawn  up at the end  of the 
second  year.  The  Economic  and  Social  Committee 
should  be sent  a copy  of the progress  report. 
The Chairman 
of the Economic  and  Social  Committee 
Fabrizia  BADUEL  GLORIOSO 
Opinion  on the proposal  for a specific  Council  Directive  on the overall  migration  limit  for the 
constituents  of plastic  materials  and  articles  intended  to come  into  contact  with  foodstuffs 
The text  referred  to the Committee  has  been  published  in Official  Journal  of the European 
Communities  No  C 141  of 16 June  1978,  page  4. 
A. LEGAL  BASIS  FOR  THE  OPINION 
On 13 June  1978  the Council  referred  the abovementioned  proposal  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 168th 
plenary  session  held  in Brussels  on 22 and  23 May  1979. 
The full  text  of the opinion  is as follows: 
No C 227/32 Official  Journal  of the European  Communities 10. 9. 79 
THE  ECONOMIC  AND  SOCIAL  COMMITTEE, 
Having  regard  to the  Treaty  establishing  the European 
Economic  Community,  and  in particular  Article  198 
thereof, 
Having  regard  to the  request  made  by the  Council  on 
13 June  1978  for an opinion, 
Having  regard  to the  decision  taken  by its Bureau  on 
19 June  1978  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  at its meeting  held  on 24 April  1979, 
Having  regard  to the report  submitted  by the rapporteur, 
Mr Ramaekers, 
Having  regard  to the  discussions  at its 168th  plenary 
session  held  on 22 and  23 May  1979  (meeting  of 22 May 
1979), 
HAS  ADOPTED  THE  FOLLOWING  OPINION 
by 71 votes  to two  with  eight  abstentions: 
1. General  comments 
1.1. The  Committee  approves  the  Commission's 
efforts  to  implement  the  outline  Directive  of 
23 November  1976  on the approximation  of the laws  of 
the Member  States  relating  to materials  and  articles 
intended  to come  into  contact  with  foodstuffs  (1). 
1.2. The  Committee  recognized  that  it is useful  to 
adopt  specific  Directives  on  plastics  materials  and 
articles  intended  to come  into  contact  with  foodstuffs, 
for three  basic  reasons. 
The first  is the protection  of the health  of the consumer. 
Here  regulations  are needed  to ensure  preventive  action. 
The selond  reason  concerns  the elimination  of barriers  to 
trade.  Here  the  great  diversity  of national  regulations 
means  jthat  harmonization  is a necessity. 
The third  reason  is concern  that  the  composition  and 
organoleptic  characteristics  of  foodstuffs  remain 
unaltered. The adoption  of an overall  migration  limit  and  rules  for 
its verification  will  make  it possible: 
(a) to obviate  the  need  for  establishing  and  then 
monitoring  specific  migration  limits  for  all 
substances  which  may  be toxic  at levels  in excess  of 
the overall  migration  limit; 
(b) to reduce  the potential  danger  represented  by most  of 
the substances  used  in the  manufacture  of plastics 
materials; 
(c) to reduce  cumulative  effects. 
1.3. Nevertheless,  the  Committee  would  point  out 
that the  Commission's  proposal  is not  complete;  it 
represents  only  a first  step  towards  the control  of plastics 
materials  and  articles  intended  to come  into  contact  with 
foodstuffs. 
It is important  that  most  of the substances  are covered, 
but the  potential  danger  of the  remaining  substances  is 
not negligible.  We  have  only  to think  of vinyl  chloride 
monomer,  for which  the specific  migration  limit  has just 
been  set at zero,  in view  of the possibilities  of analysis. 
Moreover,  certain  packaging  materials,  notably  some 
kinds  of polyethylene,  are  likely  to fail  the  tests.  The 
Committee  thus  urges  the Commission  to deal  with  this 
problem. 
In conclusion,  the Committee  would  like  to see this  first 
step followed  as soon  as possible  by others,  such  as the 
drawing  up of a positive  list of substances  which  could  be 
used  in the  manufacture  of materials  and  articles 
intended  to come  into  contact  with  foodstuffs;  this  list 
should  indicate  the  specific  migration  limits  or other 
suitable  limits. 
In putting  forward  this  proposal,  the  Committee  is 
endorsing  the opinion  issued  by the Advisory  Committee 
on Foodstuffs  as well  as the comment  in its opinion  on 
the principle  of positive  lists  referred  to in its opinion  of 
27 February  1975  (2). 
1.4. The  Committee  is fully  aware  of the fact  that  the 
drawing  up of a positive  list represents  a heavy  workload 
which  cannot  be completed  overnight.  For  this  reason  it 
makes  the following  proposal  to the Commission: 
— First  stage:  the  drawing  up of the  positive  list  of 
plastic  monomers. 
— Second  stage:  the drawing  up of the same  type  of list 
for the additives  used  in the manufacture  of plastics 
materials. 
1.5. It  believes  that  this  would  enable  the 
requirements  of Article  2 of the outline  Directive  - safety 
(1) OJ No L 340,  9. 12. 1976,  p. 19. (2) OJ  No C 108,  15. 5. 1975,  p. 72. 
10. 9. 79 Official  Journal  of the European  Communities No C 227/33 
and inertness  of the  material  — to be met  with  the 
minimum  of delay,  since  monomers  are the main  raw 
materials  used  in the manufacture  of plastics  materials. 
1.6. The  Committee  observes  that  certain  require-
ments  may  have  economic  repercussions. 
2. Specific  comments 
2.1. Article  1 
The Committee  approves  this  Article,  which  describes 
the origin  and  the scope  of the Directive. 
It would,  however,  like  to see a revision  of the wording 
of paragraph  3 so as to make  it clear  that  'preparations 
for surface  coatings'  means  the coating  itself  and  not the 
raw material  used  in its manufacture. 
2.2. Article  2 
The Committee  accepts  the  adoption  of an overall 
migration  limit,  subject,  however,  to the comments  set 
out above. 2.3. Article  3 
The Committee  approves  the adoption  of common  rules 
for the  verification  of the  overall  migration  limit  but 
recognizes  the  advisability  of having  an 'adaptation 
clause'  allowing  a Member  State  provisionally  to adapt 
these  rules  on migration  where  those  laid  down  in the 
Directive  prove  inappropriate. 
2.4. Article  5 
The Committee  would  like  to see other  specific  measures 
taken  on the basis  of the outline  Directive  so as to attain 
the objective  of the scope  of the harmonization. 
2.5. Article  6 
The Committee  agrees  with  the time  scale  laid  down  for 
the implementation  of the  Directive,  but  notes  that 
publication  of the classification  of foodstuffs  according 
to type  of simulant  used  in the tests  is needed  as soon  as 
possible. 
The Committee  recognizes  that  there  will  be legal  and 
practical  problems  but insists  that  they  must  not serve  as 
a pretext  for  postponing  the  implementation  of the 
Directive. 
Done  at Brussels,  22 May  1979. 
The Chairman 
of the Economic  and  Social  Committee 
Fabrizia  BADUEL  GLORIOSO 
ANNEX 
to the  opinion  of the  Economic  and  Social  Committee 
The following  amendment  was  rejected  during  the debate: 
Paragraph  2.5 
Delete  both  indents  and  substitute: 
'The  Section  prefers  that  the time  scale  laid  down  for the implementation  of the proposed  Directive  be 
postponed  until  the  publication  of the  classification  of foodstuffs,  the agreement  on an acceptable 
method  for determination  of overall  migration  and  the  positive  list are  available.' 
Reason 
The amendment  draws  attention  to the premature  nature  of the proposal  and  particularly  the essentials  to 
facilitate  administration  in practicable  application. 
Voting 
For:  18;  against:  41;  abstentions:  22.