Opinion of the Economic and Social Committee on the 'Proposal for a European Parliament and Council decision adopting a programme of Community action 1999-2003 on pollution-related diseases in the context of the framework for action in the field of public health'
Date: 1997-10-29
Institutions: European Economic and Social Committee
Subjects: EU programme, disease prevention, health policy, pollution, public health

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3.3.3.1.
In this connection the Committee would
further stress the importance of monitoring systems for
rare diseases in order to identify trends over time and
regional clusters. As such trends do not generally emerge
until after 10 years, the Committee thinks that the
continuity of the proposed action programme should be
ensured, even after 2003.

3.4.
It goes without saying that the Commission
should ensure that there is consistency and comp-
lementarity between all the Community initiatives relat-

ing to rare diseases. This particularly applies to the
proposed action programme, current and future research
activities on rare disease and the envisaged regulation
on orphan medicinal products (where research, develop-
ment and marketing of such medications must be closely
coordinated).

3.5.
The Committee is pleased to note that, as part
of the programme, the Commission envisages fostering
cooperation with relevant international organizations
and third countries; these should include Japan and the
United States.

Brussels, 29 October 1997.

The President

of the Economic and Social Committee

Tom JENKINS

Opinion of the Economic and Social Committee on the ‘Proposal for a European Parliament
and Council decision adopting a programme of Community action 1999-2003 on pollution-
related diseases in the context of the framework for action in the field of public health’ (1)

(98/C 19/03)

On 27 June 1997 the Council decided to consult the Economic and Social Committee, under
Article 129 of the Treaty establishing the European Community, on the above-mentioned
proposal.

The Section for Protection of the Environment, Public Health and Consumer Affairs, which
was responsible for preparing the Committee’s work on the subject, adopted its opinion on
7 October 1997. The rapporteur was Mr Lemmetty; co-rapporteurs: Mr Fuchs and Mr Linssen.

At its 349th plenary session (meeting of 29 October 1997), the Economic and Social Committee
adopted the following opinion by 106 votes in favour and 3 abstentions.

1.

Introduction

The Commission has presented a communication
1.1.
concerning a programme of Community action on
pollution-related diseases in the context of the frame-
work for action in the field of public health. The
communication is accompanied by a proposal for a
European Parliament and Council Decision adopting a
programme of Community action on pollution-related
diseases to be carried out within this framework in the
period 1999-2003.

1.2.
The action programme is based on Articles 3(o)
and 129 of the Treaty establishing the European Com-
munity which set health protection as a priority objec-

tive. In its communication of 24 November 1993 on the
framework for action in the field of public health (2), the
Commission defined a framework for future action at
Community level in order to attain these objectives.

1.2.1.
Following on the Communication, the Com-
mission has also recently adopted action programmes
on injury prevention and rare diseases.

1.3.
The Economic and Social Committee has empha-
sized the link between environmental pollution and
health on a number of occasions in the past. In its

(1) OJ C 214, 16. 7. 1997, p. 7.

(2) COM(93) 559 final, 24. 11. 1993.

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opinion of 6 July 1994 on the Commission’s framework
communication on public health (1), the Committee
urged the Commission to adopt a broad approach to
the issue stressing the importance of the environment
for the promotion of health.

The present communication and proposal for an
1.4.
action programme are concerned mainly with health
problems caused by environmental pollution. Pollution
contributes to many of the major causes of morbidity
and mortality in the European Community; among the
examples cited by the Commission are respiratory
problems, allergies, cancers, cardio-vascular diseases
and infectious diseases, neurological disorders and
immunological impairment. In addition, auditory and
other adverse health effects caused by noise have become
an issue of growing importance.

1.4.1.
Allergies are amongst the commonest chronic
disorders affecting up to one third of the population in
developed countries and the prevalence is increasing (2).
It has to be pointed out, however, that when the
Commission proposal refers to ‘allergies’, it means, for
the most part, respiratory allergic conditions (i.e. it is
not concerned with food allergies or allergies caused by
skin contact).

— there is evidence that current levels of exposure to
pollutants represent a health risk and, furthermore,
the number of people exposed to pollutants is
considerable;

— the disease produces a substantial burden of mor-
bidity and/or mortality and/or there is evidence that
it is becoming considerably more widespread; and

— Community action yields added value compared to

measures taken by Member States.

1.9.
Applying these criteria, the Commission iden-
tifies diseases related to air pollution, primarily respirat-
ory diseases and allergies, as priority areas for the
proposed programme.

2. Community action programme on pollution-related

diseases 1999-2003

2.1.
The Commission proposes a five-year action
programme focusing mainly on prevention of asthma
and other respiratory diseases and allergies.

The prevention of pollution-related diseases has
1.5.
three elements: first, reducing the amount of pollutants
by taking action at their source; second, seeking to limit
people’s exposure to them; and third, mitigating the
effects on individuals who are exposed to them.

2.2.
The programme will be implemented by increas-
ing the level of information on pollution-related diseases,
improving risk perception and risk management with
respect to pollution-related diseases and supporting
measures aimed at prevention of the diseases covered by
the programme.

1.6.
Although data on pollution-related diseases does
exist at Community level and in the Member States, the
data at Community level does not provide a clear picture
of the relationship between environmental pollution and
ill health.

2.3.
The proposal provides for consultation with
Member States, relevant international organizations and
third countries. In addition, the programme will be
subject to ongoing evaluation and evaluation reports
will be drawn up at specified intervals.

The Commission gives overviews of action taken
1.7.
in Member States and at international and Community
level to address the problem of pollution-related diseases.

The proposal lays down the financial framework
2.4.
for only the first year (1999) of the programme, leaving
a decision on the financial framework for the last four
years until a later date.

1.8.
In the light of the above considerations, and
taking account of the action being taken in this field
elsewhere and the limited resources available, the Com-
mission proposes the following selection criteria for
determining priority areas for the programme:

— public health measures relating to the disease con-
cerned are not being undertaken as part of other
Community programmes;

3. General comments

3.1.
The Economic and Social Committee welcomes
the Commission’s communication and proposal for a
Community action programme. All in all, the Com-
mission document shows a high level of competence and
specialist knowledge.

(1) OJ C 388, 31. 12. 1994.
(2) European Allergy White Paper. The UCB Institute of

Allergy, May 1997.

3.2.
The Committee endorses the action programme
because it is well reasoned and the proposed measures
are clearly set out. It is also timely, well-founded and

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provides for a major Community contribution to the
measures being taken in the field of public health. In
addition, and even if there is already a large body of
information on pollution-related diseases,
the pro-
gramme will yield necessary added value.

4.3.
Regarding the third specific objective (‘Respirat-
ory diseases and allergies’), the Committee stresses that,
using the same general criteria, the action programme
could have been targeted at some other important
diseases.

3.2.1.
The Committee considers the overviews of
existing measures being taken at various levels, as
presented by the Commission, to be particularly useful.
In addition,
the
proposed mix of horizontal and disease-specific
measures is practicable.

the Committee is convinced that

3.2.2.
The Committee stresses the importance of
reducing the amount of pollutants by taking action at
their source.

The Committee has a number of observations to
3.3.
make, which should not, however, detract from the
value of the proposal or the importance of the subject it
addresses.

4. Specific comments

4.1. With regard to the first specific objective of the
action programme (‘Improvement of information’), the
Committee would underline the importance of compiling
scientific data on the causal relationship between pol-
lution and disease and of collating and evaluating
existing data on causality in cooperation with Member
States.

4.2.
As for the second specific objective (‘Risk percep-
tion and management’), the Committee would point out
that in order to i) prevent needless alarm among the
general public and ii) encourage people to minimalize
exposure to environmental risks, considerably more
than the provision of information alone is needed.
Research in the field of risk communication shows that
people are calmed much more by proper communication
in which their fears are taken seriously than by data.
For this, they must have confidence in those providing
the information. Furthermore, attention must also be
paid to such aspects as the social environment and
competence of the persons concerned.

4.2.1.
In this context the Committee would also
underline that communication and the provision of
information should be organized systematically; it is
particularly important to study the target group before-
hand.

Brussels, 29 October 1997.

4.3.1.
In this connection, the Committee would like
to emphasize the importance of preventing also other
allergies, such as food allergies.

4.4.
The Committee is pleased to note that it will
receive copies of the evaluation and implementation
reports.

4.5.
The Committee would highlight the importance
of cooperation with national authorities, the European
Environment Agency, the WHO and third countries.

4.5.1.
It is also important to acknowledge the work
that the USA Environmental Protection Agency (EPA)
has carried out in the field of risk assessment and
management with respect to pollution related-diseases.
The Committee considers it important for the Com-
munity to be able to benefit from such work.

4.6.
In order to avoid unnecessary duplication of
work, the Committee urges the Commission to ensure
that the proposed measures are consistent with and
complementary to actions envisaged under the health
monitoring programme (1) and any other Community
action relevant to pollution-related diseases, such as
those under the framework of the Fifth Community
Action Programme for the Environment — ‘Towards
Sustainability’ (2).

In the view of the Committee, a weakness of the
4.7.
programme is the uncertainty surrounding its funding.
Whilst the Committee understands the reasons for this,
it would be desirable if the Commission could put
forward at least an outline of the funding requirements
for the years 2000-2003, and if the budgetary authorities
could ensure that such requirements were subsequently
met — a multiannual programme should not run the
risk of remaining uncompleted on account of budgetary
matters.

(1) Proposal: OJ C 338, 16. 12. 1995 — ESC Opinion: OJ

C 174, 17. 6. 1996.

(2) Proposal: OJ C 138, 17. 5. 1993 — Opinion ESC: OJ C 287,

4. 11. 1992.

The President

of the Economic and Social Committee

Tom JENKINS