Opinion of the Committee of the Regions on the 'Communication from the Commission accompanied by a 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: 1997-11-20
Institutions: European Committee of the Regions
Subjects: action programme, air quality, disease prevention, public health

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EN

Official Journal of the European Communities

C 64/91

Opinion of the Committee of the Regions on the ‘Communication from the Commission
accompanied by a 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’

(98/C 64/16)

THE COMMITTEE OF THE REGIONS,

having regard to the Communication from the Commission accompanied by a 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 (COM(97) 266 final, COD 97/0153) (1);

having regard to the decision taken by the Council on 27 June 1997, under Article 129 and
198c, first paragraph of the Treaty establishing the European Community, to consult the
Committee of the Regions on the matter;

having regard to its decision of 8 March 1996 to direct Commission 8 — Economic and Social
Cohesion, Social Policy and Public Health — to draw up the opinion;

having regard to the draft opinion (CdR 287/97 rev.) adopted by Commission 8 on 24 September
1997 (rapporteur: Mrs Bolger),

unanimously adopted the following opinion at its 20th plenary session on 19 and 20 November
1997 (meeting of 20 November).

1.

Introduction

2. Pollution-related diseases

The Committee of the Regions (COR) welcomes this
opportunity to comment on the Commission’s proposed
action programme on pollution-related diseases in the
context of the framework for action in the field of public
health.

timely that

It is most
the Commission, European
Parliament and Council should focus their attention on
the issue of environmental pollution, as the diseases
associated with that pollution are escalating. The Com-
mittee of the Regions acknowledges the stringent efforts
made by the Commission, European Parliament and
Council
in tackling the problems associated with
environmental pollution.

When the environment is discussed it is usually in the
context of environmental risks to public health. Threats
to health, especially children’s health have provoked an
apparently strong reaction from potential victims. Given
the increase in the proliferation of pollution-related
diseases within the Union, it is only correct than an
action programme should be devised and implemented
with a view to minimizing the risk to the citizen and
children in particular.

a) Definition of pollution-related diseases

For the purpose of this opinion, the term ‘pollution-
related diseases’ shall be taken to mean, those diseases
which are caused, provoked or aggravated by environ-
mental pollution. In the context of public health,
‘pollution’ can be defined as an environmental imbalance
or disturbance, man made or naturally occurring, which
can have an adverse effect on human health. These
pollutants range from water contamination and chemical
emissions to the air and soil’s physical corruption. Due
to the broad nature of the field of environmental
pollution, the Commission has correctly taken a some-
what focused approach when drawing up the Programme
for Community Action 1999-2003 on pollution-related
diseases. The Commission has chosen to concentrate
its resources on health problems associated with air
pollution. Air issues include toxic pollutants, acid rain,
urban smog and smoke.

b) Proliferation of pollution-related diseases

(1) OJ C 214, 16.7.1997, p. 7.

Over the past number of decades, the increase in
industrialization and rapid population
urbanization,

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growth has led to an increase in the prevalence and
concentration of pollutants. Communities have histori-
cally grown up around the workplace and in the recent
past the workplace was often the source and cause of
air pollution. While diseases arising from water pollution
and poor hygiene have to a large extent been alleviated,
their place has been taken by diseases which are caused
by neglectful lifestyles and exposure to harmful air
pollutants.

The gravity of the present situation is best illustrated by
briefly looking at the extent of morbidity and mortality
caused by pollutants which have attacked the respiratory
system. It has been suggested that one-third of the
world’s health burden is inflicted by diseases that could
be abated by focusing on the complex relationship
between environmental and other factors, in particular
the combating of unclean air.

A direct correlation exists between air pollution and the
prevalence of respiratory diseases. One such respiratory
disease is asthma. Asthma is an allergic disease of the
human airways. Air passages are known to become
inflamed in response to a number of environmental
factors. Allergens, when combined with man-made air
pollutants, are probably the most important of these
and a close link between exposure and development of
asthma has been demonstrated. Other environmental
factors such as tobacco exposure, viruses and outdoor
pollutants have all been demonstrated to aggravate
individuals who have asthma.

The morbidity rate due to asthma increased by some
27 % between 1974 and 1984 in the European Com-
munity. The trend among children was even more
worrying with the doubling of the prevalence of the
disease in children over the same period. In Ireland, a
relatively unpolluted country, 14 % of the population
suffer from asthma and asthma accounts for more than
one hundred deaths in Ireland each year. This figure,
like that in many more Union Member States, is on the
increase.

Chronic Obstructive Pulmonary Disease (COPD), of
which the most common forms are bronchitis and
emphysema, and allergies have spiralled over the last
twenty years, thus causing a major health problem,
especially in urban areas. Since the 1970s, the incidence
of allergic rhinitis in both adults and children has
doubled in a number of Community states. It is estimated
that prevalence rates in the Community as a whole range
from 2 % to 10 %.

3. Threats

a) Outdoor air pollution

The nature of outdoor air pollution has changed
dramatically. Whereas once outdoor air pollution stem-

med from the burning of fossil fuels, it is now clearly
related to outdoor allergens and vehicle emissions.

Outdoor environmental allergens such as pollen and
animal dander cause considerable discomfort to many
over the course of the summer season. Pollen allergy, in
particular, is rife contributing to allergic symptoms, like
conjunctivitis and rhinitis. The level of pollen in the
atmosphere has not increased over the years. It can be
reasonably assumed therefore, that the rapid increase in
allergies stems from a depletion or weakening of the
body’s defense system.

Vehicle emissions are rich in oxides of nitrogen, which
under certain circumstances will produce ozone. How-
ever, while the public is well informed on the continual
erosion of the ozone layer and the harmful effects
associated with global warming, the more directly
relevant causes of allergic and respiratory diseases are
ignored to a considerable degree.

It may take a unified global response to circumvent the
damage already inflicted on the ozone layer. In contrast,
each citizen can affect and influence their indoor
air-quality and lifestyle quite easily.

b) Indoor pollution

Indoor air pollution is considered to play a significant
role in the proliferation of allergies. Indoor air quality
is influenced by a wide range of elements. Radon
concentrations, tobacco smoke, unvented kerosene heat-
ers and dust particles are all contributing factors to the
causation of indoor air pollution. Presently, there is the
fear that individual air pollutants, although damaging,
are not as worrying as a combinatory effect of air
pollutants. While the human body may be able to fend
off singular air pollutants, it cannot ward off a cocktail
of pollutants.

One of the most harmful forms of air pollution is
cigarette smoking and, while to smoke or not to smoke
is a personal decision, it should certainly be public policy
that nobody should smoke to pollute the air of their
fellow citizens in public buildings or on public transport.

Society has started to take a mature approach to
smoking. All Union States have introduced legislation
prohibiting smoking in many public areas. A greater
effort has been made at national and regional level to
inform the public of the harmful effects associated with
smoking. It is imperative that the progress made in this
domain should be built on with continued research into
the relationship between smoking and cancer and other

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respiratory diseases. Although smoking falls entirely
under the aegis of the cancer programme, any relevant
information obtained during the proposed related dis-
eases action programme should be transferable.

Regions fully concurs with the Commission’s view that
all exposure to asbestos should be reduced as much as
possible, using the best available technology without
incurring excessive costs.

4. The indoor environment

The nature of the indoor environment has changed in
recent years. Much of Europe’s population now lives in
tightly sealed buildings with double glazing and no
chimneys. Central heating is common, maintaining high
temperatures and low humidity. New ‘energy efficient’
housing is designed to keep the weather out, and
consequentially, to keep pollutants in. The house dust
mite, in Greek ‘dermatoghanid’, meaning ‘skin-eating
spider’, thrives in such conditions and reproduces at
alarming speeds. Wall to wall carpeting, thick upholstery
and bedding also help to harbour the mite.

In such an environment, young children tend to increas-
ingly become hyper-sensitive. A child’s immune system
is not given time to develop as it faces a barrage
of attacks from its earliest days in the homestead.
Furthermore, parental care may have overstepped the
limits of what is actually beneficial for the child. Often
in attempting to protect the child from the elements,
parents safeguard a child to an excessive degree, thus
rendering the child’s immune system useless. It is
a question of balancing a child’s exposure to the
environment and protection from the elements.

A greater awareness of the hidden dangers, such as
droppings of house dust mites, fungal spores and animal
dander may go a long way towards circumventing
many harmful allergies. As the European Commission
correctly suggests, information campaigns should be
embarked upon as a means of notifying the general
public of the deleterious effects associated with indoor
and outdoor air pollution.

In the workplace one of the most common forms of
pollution emanates from asbestos materials. For some
time, it has been recognized that asbestos can be harmful
to human health. Exposure to high levels of asbestos
particles in the atmosphere can cause asbestosis, pleural
effects, bronchial carcinoma and mesothelioma. These
diseases have been observed in workers exposed to
asbestos by reason of their occupation.

The Commission, Parliament and Council are to be
commended on their introduction of legislation in 1983
(83/447) protecting workers from exposure to asbestos.
It is imperative, however, that the provisions made for
the workplace are replicated in domestic housing. Many
houses built in the 1950s and 1960s contain asbestos
piping though which water flows. The potential for
contamination is too great and the Committee of the

While the Commission’s proposed action programme
does not specifically refer to the eradication of diseases
associated with asbestos, the Committee of the Regions
calls on the Commission to examine this topic, in some
detail, at a future date.

5. The prevention of pollution-related diseases

The decision to what extent we will control our air
pollution and pay the necessary costs is a political one
and includes the concept of ‘acceptable risk’. The
work carried out under the Fourth Action Programme
(Research and Technological Development) in regard
to the identification of atmospheric pollutants must be
built on and brought to a new stage. It is only by fully
understanding the causation of respiratory diseases that
the problem can begin to be tackled.

The Commission, having taken on board the research
supported by the Community and Community legis-
lation in the environmental sector, has, in the proposal
to combat pollution-related diseases, devised a three-
pronged strategy. First, reducing the amount of pol-
lutants by taking action at their source; second, acting
to limit the amount of people’s exposure to them; and
third, mitigating the effects on individuals who are
exposed to them.

While it may appear necessary to reduce the levels of all
pollutants, it is neither feasible nor cost-effective. A
more realistic approach to the task of reducing air
pollutants is to focus a campaign on the individual. A
citizen may prove willing and able to change their
personal behaviour, thus complementing the legislative
environmental framework already laid down in relation
to industrial actors or car manufacturers. Changes to
modes of transport, fuel users and vehicle emission
control technology should be specifically targeted and
promoted as a priority, in order to progress more rapidly
in making widely beneficial improvements to public
health.

6. The quest for information

As mentioned in the Commission’s communication
concerning the Community Action Programme on pol-

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lution-related diseases, a prerequisite for undertaking
such preventive action is the collection of appropriate
statistical information on the causation and the extent
of the problems. Data exists concerning exposure to
pollutants in many Member States. However, it has
been difficult to determine the precise relationship
between exposure to pollutants and the long-term health
of the citizen.

data has been compiled, it may be possible to draw
causal
links between environmental pollutants and
diseases.

The information gleaned from this statistical data will
allow expert and citizen alike a clearer picture of the
risks and the solutions to the problems associated with
environmental pollution.

In order to ascertain accurate data, an infant’s exposure
to pollutants must be monitored from its earliest days
to a stage at which it can be considered to be developed
and mature. This analysis can be carried out with
the use of personal monitors, which are practically
weightless. An analysis of personal exposure to pol-
lutants depends on the air pollutant concentrations that
are present in the locations the person moves through,
as well as the time spent
in each location. This
necessitates the constant monitoring of exposure. A
modelling of human exposure to air pollution cannot
take place in the absence of comprehensive statistical
analysis.

The establishment of the European Environmental
Agency has facilitated the collection of some of the
statistical data referred to above. It is imperative that
this agency should continue to work closely with national
and regional authorities in compiling information on
air and water pollution. It is often at the national and
regional level that the most relevant problems related to
air pollution can be identified. Thus, it is expedient to
bear in mind the principle of subsidiarity when drawing
up an action plan to combat pollution-related diseases
in the Union. As the Commission states, Community
action shall only be taken in this field if by reason of its
scale or effects the proposed action can be better achieved
by the Community, compared to the action at national
level. Furthermore, Community action must be pro-
portional to the proposed objectives.

7. Community action against pollution-related dis-

eases

As the prevention of respiratory diseases and allergies
falls outside the ambit of other Community programmes,
there is evidence that respiratory diseases and allergies
present a health risk and result in morbidity and/or
mortality, the Commission has wisely decided to focus
its measures within the Commission’s proposal on the
curtailment of these diseases.

The Commission has outlined three broad objectives
which are aimed at reducing the rapid proliferation of
pollution-related diseases. The first of these objectives
involves the improvement of information on pollution-
related diseases. Once a comprehensive list of statistical

Secondly, the Commission contends that an increased
level of understanding in relation to pollution-related
diseases will enable both Community and national
bodies to implement a coherent risk management strat-
egy. The public perception of risks to public health are
often misinformed and consequently lead to unnecessary
public concern. While the public may preoccupy their
thoughts with the associated dangers of electro-magnetic
fields, salmonella or BSE, potentially more deadly
pollutants lie hidden in the homestead. Daily low-level
exposure to thousands of contaminants, in dosages too
small to detect, take a dramatic toll on our immune
system defences. Moreover, the public have continually
underestimated smoking’s contribution to the causation
of respiratory and cardio-vascular diseases.

Information campaigns are required to inform citizens
of the hidden dangers which lurk in domestic housing.
Dust mites and bacteria thrive in the absence of
ventilation. Winter temperatures necessitate insulation
and heating. However, when the house or workplace is
vacant, even for short periods of time, rooms should be
well ventilated. Just as humans need to breathe, walls,
ceilings and floors require an exchange of air. Infor-
mation campaigns must encourage citizens to ventilate
both houses and the workplace. Local and regional
authorities’ input into information campaigns is vital,
as they have a key role to play in providing public
information and changing public attitudes.

The third strand of the Commission’s strategy in dealing
with pollution-related diseases concerns activities which
would directly reduce the prevalence and/or incidence
of respiratory and allergic diseases. It is envisaged
that actions would be devised to reinforce and link
information campaigns. In addition, resources would be
channelled into the promotion of best practices. In
developing a European strategy, the Commission should
be encouraged to examine best practice in each Member
State and to channel resources into the promotion of
best practices.

8. The budget

The Committee of the Regions, while understanding the
current financial perspective, calls on the Commission

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to increase the proposed allocation of expenditure under
the Commission’s proposal on pollution-related diseases
post 1999. The Commission’s proposed programme
on pollution-related diseases has been allocated ECU
1,3 million for the year 1999, in keeping with current
financial perspectives. The Commission has
rec-
ommended that the financial framework for the final
four years of the programme (2000-2003) shall be
determined in detail after the establishment of the future
financial perspectives. It is the opinion of the Committee
of the Regions that expenditure under this programme
would increase by a sizeable amount post 1999. To
make a telling contribution in the fight against pollution-
related diseases, substantial funding is required. Infor-
mation is invaluable and should not be circumscribed
simply because of present financial constraints.

9. Concluding remarks

The Committee of the Regions would like to pay tribute
to the Commission’s innovative and encouraging work

carried out to date in the realm of environmental
pollution. This process has been complemented by
Council and Parliament’s interest and support.

The task of alleviating problems associated with environ-
mental pollution is challenging but certainly not insur-
mountable. The clear priority of the Commission’s
proposed action on pollution-related diseases is to
reduce the suffering inflicted on citizens generally, and
children in particular, by environmental pollution. In
addition, the socio-economic benefits accruing from a
reduction in the prevalence of pollution-related diseases
are not insignificant. Many days of work are lost each
year throughout the Union as a result of pollution-related
diseases. Moreover, the burden placed on a nation’s
health care system is considerable.

The Committee of the Regions lends its support to the
Commission’s proposed action programme on pollution-
related diseases. It is imperative, however, that sufficient
finance be set aside to enable regional, national and
Community actors to play a significant role in the battle
against pollution-related diseases.

Brussels, 20 November 1997.

The Chairman

of the Committee of the Regions

Pasqual MARAGALL i MIRA