WRITTEN QUESTION E-2061/03

by Stavros Xarchakos (PPE-DE) to the Commission

(20 June 2003)

Subject: Pollution and noise pollution levels in Greek schools

According to research carried out by the Chemistry Department of Athens University which was published in the Greek press, ventilation is inadequate in 75 % of the school buildings inspected, concentrations of carbon dioxide were found above the ceiling of 1 800 mg/m3, high levels of formaldehyde were detected and maximum permissible noise levels were exceeded. The research covered 20 building with natural ventilation in ten different public schools in Athens. The researchers were particularly concerned by the fact that concentrations of carbon dioxide were above the highest permissible levels set by the American guide to indoor air quality (1 800 mg/m3) and in some cases were even in excess of 3 000 mg/m3.

The concentration of formaldehyde was also a cause for concern (in excess of 0,1 mg/m3, the highest permissible level). This is due to the frequent use of boards made of wood particles (Novopan) in the construction of desks and partitions between buildings.

As regards noise levels, the research concluded that they were very high: 61 decibels inside the buildings (the ceiling is 45) and 77 decibels outside (the ceiling is 65). Many pupils complained of coughs and headaches and also mentioned that they were frequently tired and had difficulties concentrating on their lessons.

What is the Commission's views of the conclusions of this research carried out by Athens University?

Have the ceilings for atmospheric pollution and noise levels set by Community law been exceeded?

What measures can the Commission take immediately vis-à-vis the Greek authorities to protect the health of Greek pupils who, according to the same research, spend 14 000 hours in school buildings before leaving school?

Answer given by Mrs Wallström on behalf of the Commission

(13 August 2003)

Several Council Directives are relevant in this context.

Council Directive 89/391/EEC of 12 June 1989 on the introduction of measures to encourage improvements in the safety and health of workers at work(1) imposes an obligation on employers to be in possession of an assessment of the risks to safety and health at work and to decide on the protective measures to be taken. Employers are required to implement these measures on the basis of several principles of prevention, among them: avoiding risks, combating the risks at source, and developing a coherent overall prevention policy.

Although Article 3(a) of Directive 89/391/EEC excludes students, since they are not included in the definition of worker, unless they are trainees or apprentices, the Directive still applies, because the Honourable Member's question concerns the situation in Greek schools in general, thus including the health and well-being of teachers, who are naturally workers within the meaning of the Directive.

Regarding exposure to carbon dioxide (CO2) at work, Council Directive 98/24/EC of 7 April 1998 on the protection of the health and safety of workers from the risks related to chemical agents at work(2) requires the Commission to propose indicative occupational exposure limit values. The one established for CO2 by Commission Directive 91/322/EEC of 29 May 1991 on establishing indicative limit values by implementing Council Directive 80/1107/EEC on the protection of workers from the risks related to exposure to chemical, physical and biological agents at work(3) is 9 000 milligrams per cubic metre (mg/m3) or 5 000 parts per million (ppm). There is no EU occupational exposure limit value for formaldehyde.

In addition, the results of the research carried out by the Chemistry Department of Athens University seem to show that air exchange rates in schools with high CO2 levels are extremely poor. In the absence of indoor combustion sources, CO2 concentrations in indoor air can be seen as an indicator of good or poor ventilation. For formaldehyde the threshold of irritation is reported to be as low as 0,1 mg/m3 after a short exposure time, but a significant increase in the symptoms of irritation in healthy subjects starts at levels above 0,3 mg/m3. In order to avoid complaints, in particular from sensitive people (e.g. schoolchildren), the formaldehyde concentration should remain below 0,1 mg/m3 as a 30-minute average. This is recommended as an air quality guideline value by the World Health Organisation (WHO). Elimination of indoor sources of formaldehyde (e.g. wooden products such as particleboard and plywood containing urea-formaldehyde resins) along with good ventilation should significantly improve indoor air quality in schools. The Commission has not yet set guide values for air pollutants indoors. In the framework of the INDEX (Indoor Exposure Limits for Pollutants) project, which is funded by the Directorate-General for Health and Consumer Protection, the Commission is investigating the possibilities of setting and implementing exposure limits for priority pollutants indoors. The project started in December 2002 and is due to be completed after 24 months.

Regarding the situation in Greek schools which is the responsibility of the Greek authorities as presented in the recent studies carried out by Athens University, the conclusions suggest that the Greek authorities need to ensure better ventilation in schoolrooms and to eliminate materials emitting formaldehyde and possibly other chemical substances which might have a direct impact on health and comfort.

As regards noise levels at work, Council Directive 86/188/EEC of 12 May 1986 on the protection of workers from the risks related to exposure to noise at work(4) provides that where the daily personal exposure of a worker to noise is likely to exceed 85 A-weighted decibels (dB(A)), personal ear protectors must be made available to workers. Where the daily personal noise exposure of a worker exceeds 90 dB(A), personal ear protectors must be used. Thus the noise levels recorded by the University of Athens (61 decibels inside and 77 decibels outside) are below the ceilings laid down in the Directive. The 45 dB and 65 dB ceilings mentioned in the Athens research are not EU requirements.

However, the Commission does recognise that noise can affect children's learning capacity, and the conclusions of the Athens University research reflect this.

Directive 2002/49/EC of the European Parliament and of the Council of 25 June 2002 relating to the assessment and management of environmental noise(5) requires the competent authorities of the Member States to make strategic noise maps and draw up action plans to reduce noise pollution near major transport infrastructure and in large towns and cities. However, the Directive does not define harmonised limit values on the basis of which noise reduction measures should be implemented, the setting of such limits being left to the discretion of the Member States.

The Commission is taking action in this area. To help the Member States evaluate the damaging effects of noise on people, Article 6 of Directive 2002/49/EC suggests the use of dose-effect relations. Pursuant to Annex III to the Directive, specific relations could be defined for vulnerable groups of the population, including children. To that end, the Commission is currently investigating the feasibility of defining such specific relations.

(1) OJ L 183, 29.6.1989.

(2) OJ L 131, 5.5.1998.

(3) OJ L 177, 5.7.1991.

(4) OJ L 137, 24.5.1986.

(5) OJ L 189, 18.7.2002.