Opinion of the Economic and Social Committee on the "Communication from the Commission — Adapting to change in work and society: a new Community strategy on health and safety at work 2002-2006" (COM(2002) 118 final)
Date: 2002-07-17
Institutions: European Economic and Social Committee
Subjects: action programme, employment policy, occupational health, occupational safety, social change

C 241/100

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Official Journal of the European Communities

7.10.2002

initiatives which have been planned but have yet to be
carried out,

— ensuring the efficiency of the new system of indicators,
standardisation and comparability of data, monitoring
and control in order to carry out impact assessments,
with a view to boosting the programming potential and
direction of actions under the Socrates programme,
without causing an unnecessary and unconstructive
administrative burden for recipients,

Brussels, 17 July 2002.

— further

streamlining

procedures,
especially those regarding the payment of often very
modest amounts of funding.

and accelerating

3.4.
The Committee therefore asks the Commission to give
due attention to these issues and to the measures deemed
appropriate, in the interim evaluation report on the implemen-
tation of the Socrates II programme which it is to submit to
the European Economic and Social Committee by 30 June
2004.

The President

of the Economic and Social Committee

Göke FRERICHS

Opinion of the Economic and Social Committee on the ‘Communication from the Commission
— Adapting to change in work and society: a new Community strategy on health and safety at
work 2002-2006’

(COM(2002) 118 final)

(2002/C 241/19)

On 11 March 2002, the Commission decided to consult the Economic and Social Committee, under
Article 262 of the Treaty establishing the European Community, on the above-mentioned communication.

The Section for Employment, Social Affairs and Citizenship, which was responsible for preparing the
Committee’s work on the subject, adopted its opinion on 20 June 2002. The rapporteur was Mr Etty.

At its 392nd Plenary Session (meeting of 17 July 2002), the Economic and Social Committee adopted the
following opinion with 123 votes in favour and five abstentions.

1.

Introduction

1.1.
The Commission’s Communication comes after a
period of several years without much strategic thinking on
health and safety at work. In that period, the world of work
has changed considerably and new problems have come up in
the EU which urgently need to be addressed.

1.3.
The Commission has prepared this Communication in
close consultation with all the parties concerned. The European
Economic and Social Committee has played its part in this
process by means of the Explanatory Opinion of July last year,
which had been requested by Commissioner Diamantopoulou
in December 2000 (1).

1.4.
In the present Opinion, the Committee will not repeat
elements from its July 2001 Opinion which have been taken
on board by the Commission.

1.2.
In addition to that, the forthcoming enlargement of
the EU poses a host of challenges in the area of health and
safety at work which have to be addressed systematically and
with vision.

(1) Opinion on the Request by the European Commission for the
Committee to draw up an exploratory opinion in anticipation of
the Commission Communication on health and safety at work,
OJ C 260, 17.9.2001.

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2. General remarks

2.1.
The Communication is a highly interesting and promis-
ing document, which responds positively to many of the
observations and suggestions made in the Committee’s
Exploratory Opinion. Generally speaking, the analytical part
provides the proper basis for the 2002-2006 strategy pro-
posals. The main problems in occupational health and safety
are addressed. Though it is not clear how the Commission
wants to tackle each and every issue it raises, the text gives
sufficient indications on the sort of action to be taken.

This said, it must be noted that what is clearly missing

2.2.
in this outline for a strategy is an action plan.

2.3.
This omission is worrying. The Committee relates it
directly to the concerns it has expressed repeatedly in several
opinions delivered in the last few years about the lack of
resources (both in terms of staff and of finances for the relevant
Commission services). It notes with regret that, once again,
these concerns have been completely ignored. It fears that the
silence which the Commission maintains on this issue could
undermine the credibility of the operational part of the
Communication.

2.4.
Ten years ago, the Directorate for Public Health and
Health and Safety at Work had four units working on
occupational health and safety and one on public health. In a
‘streamlining operation’, carried out in 1993-94, the balance
in this Directorate was shifted to three units for public health
and only two for occupational health and safety. In 1998, a
further reduction took place at the cost of occupational health
and safety when activities concerning public health and
occupational health and safety were officially separated: four
units went to DG Health and Consumer Protection, only one
unit
for occupational health and safety was left in DG
Employment and Social Affairs.

In 1992, 150 EC officials were working in the Directorate for
Public Health and Health and Safety at Work. The overwhelm-
ing majority of them (130) were working on occupational
health and safety. Today, the sectors for occupational health
and safety in DG Employment and Social Affairs have only
24 staff: 12 A-officials, 3 B-officials and 6 secretaries, plus
3 national experts.

The Committee thinks that these facts and figures, which
document its repeatedly expressed concern, do not require any
comment. It urges the Commission seriously to consider this
state of affairs, doing this in the light of their own strategy
document as well as the Committee’s Exploratory Opinion of
July 2001, and to draw conclusions and outline policies which
will do justice to their objectives for the period 2002-2006.

2.5.
The Committee calls on the Commission to present as
soon as possible an action plan on implementation of the
strategy, which it should put before the Advisory Committee
for Safety, Hygiene and Health (ACSHH). This action plan
should contain precise financial allocations for each and
every activity mentioned in the Communication. It urges the
Parliament to pay special attention to this aspect.

3. Specific remarks

The Committee has taken note with great interest of
3.1.
the sections on gender and age in the analytical part of the
Communication. However, with one or two small exceptions,
these key points in the analysis have not been reflected in the
action-oriented part of the document. The issues discussed
may not all be easy to legislate for; but the Commission could
take initiatives, for instance to raise awareness, or to identify
(through the Bilbao Agency) good practices. The Commission
could also examine ergonomics in relation to gender and take
initiatives.

3.2.
The figures underpinning the analysis on gender-
related issues are not convincing. It appears that in some
cases the problems identified are function-specific rather
than gender-specific. That should have consequences for the
measures to be taken.

3.3.
Another critical remark as regards the analytical part
should be made concerning the consequences of ‘non-quality’
of work (as expressed in the introduction to the Commission
text). The figures given by the Commission regarding conse-
quences, in terms of loss of productive capacity and compensa-
tory payments and benefits, appear to be far too low.

3.4.
Important elements in the operational part of the
Communication deal with the planned legislative action on
ergonomic issues, in particular RSI, and with the involvement
of workers and employers in addressing the issue of stress.

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3.4.1.
The VDU Directive (90/270/EEC) is not an adequate
vehicle for additional measures regarding RSI, as there are
many more RSI risk factors which are not linked to visual
display screen work. The Committee thinks that the main
problem with the VDU-Directive is in its implementation in
practice, especially as regards Article 3 on ‘analysis of work
stations’ and Article 7 on the interruption and/or reduction of
the workload at the display screen. The Committee would
recommend, however, the need to amend the Manual Handling
Directive (90/269/EEC), especially as regards repetitive hand-
ling of small loads. In a general sense, the Committee reiterates
what it has stated earlier in its July 2001 Opinion on the
procedure to be followed before decisions are taken on
amendments to existing legislation (national reports, including
the views of employers’ organisations and trade unions; a
synthesis report to be drawn up by the Commission on the
basis of these reports; and consultation of the ACSHH on this
report).

3.5.
The proposal regarding stress is useful. A clear deadline
must be set for the conclusions of the consultations with the
social partners, to be started later this year. The Committee
refers furthermore to its observations on psychosocial risk
factors in its July 2001 Opinion.

be overlooked. Bearing in mind that the year 2003 is the Year
of the Disabled, the EU could contribute by training specialists
from NGOs representing the interests of the disabled who
could,
jointly with employers and trade unions, make an
important contribution to the exchange of good practices
within the EU.

A major element

3.8.
in the Committee’s Exploratory
Opinion were suggestions for open coordination as a means
of developing a new approach for the improvement of health
and safety at work in practice (1). It welcomes the Commission’s
acknowledgement of the importance of the proposed innova-
tive approach. It would have liked to see firmer support for it.
Member States should be expected, rather than simply be
encouraged, to achieve joint precise targets in order to reduce
work-related accidents and work-related illnesses. In addition
to the Committee’s earlier suggestions, the Commission might
wish to look into efforts to set sectoral targets (which have
been made for example in the Netherlands and the UK) and
regional targets (e.g. as in Italy and Spain). The latter might be
an interesting issue to seek the views of the Committee of the
Regions on.

3.9.
The Committee is somewhat disappointed about the
relative lack of attention paid to the small and medium-sized
enterprises. In this connection, it reiterates its suggestions
made under the heading of soft law and other non-legislative
measures in its Exploratory Opinion (2).
In this context,
the Commission should also look again at the issue of
implementation of workers’ responsibilities for health and
safety conditions in SMEs and at the example given of a roving
and or regional health and safety representative (Sweden,
Finland).

The Committee notes with interest the way the Com-
3.6.
mission envisages to promote well-being at work.
is
indeed a matter of mainstreaming. The same can be said for
harassment and bullying at work, where actions should not be
restricted to the area of health and safety, but expanded into
employment and discrimination policy. Different forms of
violence increasingly experienced by employees at work (both
in the public and private sector, inflicted, inter alia, by patients,
clients and customers) should also be addressed.

It

3.10.
There is nothing in the Communication on the
recognition of work-related diseases. There is a great need for
improvement here. The Committee draws the attention to the
discussion at the International Labour Conference of June
2002 on Recording and notification of occupational accidents
and diseases and hopes that the cooperation with the ILO will
inspire the Commission to take new initiatives as regards the
declaration and recognition of work-related diseases in the EU.

In addition to what the Committee has said on
3.11.
Eurostat on its July 2001 Opinion, it underscores the import-
ance of harmonising statistics on work-related accidents and
illnesses. Present disparities make for a completely distorted
picture of reality in the different Member States.

3.7.
The Commission should make a bigger effort with
respect to measures to adjust the working environment to
(re)integrate (physically and mentally) disabled people in the
labour market. Companies should be stimulated and helped to
make ‘reasonable adjustments’ in work places and equipment
in keeping with the Directive on Equal Opportunities of 2000.
In this connection, persons with learning difficulties must not

(1) OJ C 260, 17.9.2001, op. cit, point 3.3.2.
(2) OJ C 260, 17.9.2001, op. cit, point 3.2.

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3.12.
As regards the Bilbao Agency, the Committee would
like to support the Commission’s idea to set up a ‘risk
observatory’. However, it is important to pay special attention
in the work of this new function in the Agency to the
assessment of new risks. The Commission will have to clarify
what it means exactly by the term ‘risk observatory’. The
Committee thinks that serious work on new risks and a
validation of new risks might be a task which cannot be taken
on by the Agency without extra funding.

3.13.
It is a pity that the Communication has very little to
say about the Dublin Foundation. In connection with what has
been said about the importance of paying attention to new
risks (for example with a view to the stimulation of a
prevention culture),
the Committee wishes to stress the
importance of the Foundation’s survey on working conditions
(since 1990). The Committee expects that the Memorandum

of Understanding and the regular contacts between the Bilbao
Agency and the Dublin Foundation will help to avoid dupli-
cation and stimulate cross-fertilisation.

3.14.
One final element, not addressed in the Committee’s
Exploratory Opinion, but certainly important, is public pro-
curement. The Committee strongly recommends that the
Commission ensures that its own public procurement policy
contain a health and safety paragraph. This should be done
without excessive bureaucratic burdens on SMEs, taking into
account as a point of departure that there is no reason to
exempt SMEs from health and safety legislation, but that every
possible effort must be made to help them to comply with it
and to promote it at their workplaces (1). Contracts should
only be granted to contractors who have proper safety and
health policies and practices.

(1) OJ C 260, 17.9.2001, op. cit, point 3.2.2.

Brussels, 17 July 2002.

The President

of the Economic and Social Committee

Göke FRERICHS