Opinion of the European Economic and Social Committee on the "Communication from the Commission to the Council, the European Parliament and the European Economic and Social Committee: A European Environment and Health Strategy" (COM(2003) 338 final)
Date: 2003-12-10
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU environmental policy, public health, sustainable development

30.3.2004

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Official Journal of the European Union

C 80/51

Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission to the Council, the European Parliament and the European Economic and Social
Committee: A European Environment and Health Strategy’

(COM(2003) 338 final)

(2004/C 80/15)

On 12 June 2003 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the above-mentioned
communication.

The Section for Agriculture, Rural Development and the Environment, which was responsible for
preparing the Committee’s work on the subject, adopted its opinion on 13 November 2003. The
rapporteur was Mr Ehnmark.

At its 404th plenary session held on 10 and 11 December 2003 (meeting of 10 December), the European
Economic and Social Committee adopted the following opinion by 114 votes for, 2 against and
2 abstentions.

1. Gist of the opinion

1.1.
Environment and health issues are getting increasing
attention, at local, national and EU level. This is logical: as our
understanding of environment-related risks to our health
increases, political support for concrete action grows. Until
now Environment and Health issues have been dealt with
primarily at national and local level; now is the time for the
EU to make its contribution.

1.2.
The European Commission has launched a far-reaching
and inspiring initiative with its Communication on Environ-
ment and Health. The purpose is twofold: to provide a basis
for consultation, and to outline an action plan to be presented
in the spring of 2004. The priority group for the first six-year
action plan are children.

1.3.
The EESC welcomes this new initiative. It is timely,
with regard to enlargement, forthcoming WHO initiatives, and
with regard to the implementation of
the Johannesburg
World Summit on Sustainable Development. Moreover, the
Commission is giving a very concrete example of practical
policies for sustainable development.

1.6.
The EESC supports the proposed list of priority health
issues for children. The EESC points out, however, that it may
soon be necessary to include the issue of child obesity.

1.7.
The EESC welcomes the Commission’s broad consulta-
tive approach in launching the new initiative. The EESC regrets
that relatively limited time has been made available for this
consultation. Furthermore, the EESC would point out that with
children as the priority for the first six years, the Commission
should endeavour, together with national authorities, to estab-
lish channels of information and communication with insti-
tutions and professionals dealing with children, and if possible,
with parents. This initiative is — or could provide — a clear
example of EU-level action providing concrete advantages at
grass-roots level.

2. A long-term initiative

The communication raises, however, a number of
1.4.
questions that should be solved before the action plan is
presented. It is not clear how the new environment and health
initiative relates to a number of other Commission initiatives
— on public health, or on a number of environmental issues.
Nor is it clear how the necessary policy coordination within
the Commission will be achieved.

1.5.
The EESC regrets that the communication does not try
to set out more specific objectives for the new initiative. The
EESC suggests that the Commission should seek to adopt cycle
objectives such as the well-known Millennium objectives for
the developing countries. Such objectives, however general,
provide at least a basic platform for evaluation and follow-up.

The link between the environment and health has
2.1.
become a concrete reality. Alarming reports in the media in
particular have raised awareness of the issue, along with
anxiety levels surrounding the adverse health effects caused by
a polluted or degraded environment. In country after country,
health and environmental issues have come increasingly to the
fore,
including in the political arena. The European Com-
mission has now submitted the basis for a large-scale initiative
on health and environmental issues. The Commission’s new
communication focuses on this growing concern and attempts
to demonstrate that the EU level can make a significant
contribution towards reducing,
in the long-term, cases of
disease caused by environmental factors. Special emphasis is
given to the most vulnerable groups in society, and to children
in particular.

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The EESC welcomes the Commission’s broad approach
2.2.
to environmental and health issues. There are a number of
existing programmes and measures dealing in whole or in part
with the environment and health, but the picture is fragmented
and lacks any overall coordination or consolidation. This
makes the new initiative all the more important and urgent. It
is also important that these issues should be addressed more
from a cross-border perspective rather than just nationally or
regionally. The initiative is timely as there is currently broad
support for specific measures to reduce environment-related
diseases. The ten new Member States will, from the very outset,
be able to be play a full role in framing and implementing the
strategy. In an area in which ‘EU value added’ is often called
into question, a wide-ranging initiative in the field of the
environment and health would help to demonstrate the
benefits of such cooperation.

2.3.
The communication is designed to pave the way for a
broad consultation on priorities and specific measures before
the final strategy proposal is submitted in spring 2004. The
strategy is intended to be implemented in six-year cycles and
will be incremental in scope. It builds on five basic factors and
has been given the acronym ‘SCALE’, since it is based on
Science, focuses on Children, aims at raising Awareness, uses
Legal
instruments and includes constant Evaluation. The
first cycle, 2004-2010, will focus on four health effects:
(i) childhood respiratory diseases, asthma, allergies, (ii) neuro-
development disorders, (iii) childhood cancer and (iv) endoc-
rine disrupting effects.

The proposal

2.4.
to focus the first six-year cycle on
environment-related diseases in children is wise and appropri-
ate. There is still fairly limited knowledge of the long-term
effects on humans of environmental change and pollution.
Over the last fifty years, some two hundred new chemicals
have come into use. Adults now come into contact with
hundreds of new chemicals compared with previous gener-
ations. What
this means from a lifetime and — more
importantly — generational perspective is hard to say and is a
cause for concern. It is also logical to focus on children from
this perspective.

3. Towards a comprehensive strategy for sustainable

development

3.1.
The Commission’s broad approach to environmental
and health issues can also be seen as part of the drive
to develop new aspects of the comprehensive strategy for
sustainable development. Following the decisions taken at
the Gothenburg Council meeting in June 2001, sustainable
development became an overall objective for the EU’s develop-
ment. Although the strategy has only been partly successful in
translating practically into EU policy, it has gained considerable
importance as an indicator and as a firm reminder of the fact
that an economic, social and environmental balance needs to
be struck when framing specific measures. Moreover, there is
long-term dimension to ‘sustainable development’:
a clear,
it
future
generations do not have to live their lives in worse conditions
than the present generation has had.

involves taking responsibility for ensuring that

3.2.
The Commission has been working particularly hard
in 2003 to make the sustainable development strategy a
reality, whilst preparations are in hand for it to be reviewed.
The communication on environment and health issues must
be seen in this perspective, as one of several concrete strands
of the vision of sustainable development for the EU. The
communications on environmental technology and on inte-
grated product policy are other topical examples. However, it
has been difficult to get the sustainable development message
across to a wider audience in the Member States. It is generally
seen as a somewhat vague expression whose real meaning is
unclear. The Commission’s communication on the environ-
ment and health attempts to clarify some aspects of ‘sustainable
development’.

The communication on environment and health can
3.3.
also be seen as the EU’s follow-up to the UN conference
on sustainable development
in Johannesburg in August/
September 2003, where environment and health issues were
key agenda items.

4. The need to coordinate EU action

2.5.
The Commission communication stresses that there is
still a significant lack of information on the links between the
environment and health, not
least as regards groups of
children. Naturally, information gaps in certain areas cannot
be allowed to freeze initiatives in others. The Commission has
tried to avoid this by highlighting four important health and
disease factors affecting children. This is a wise approach, and
it also addresses the need for rapid clarification of the measures.

4.1.
The Commission’s new initiative is to be welcomed.
The approach is both appropriate and timely. However, the
question is, how does it lock in with other initiatives in the
field of health? It should be remembered that environment and
health issues are dealt with in a not inconsiderable number of
other programmes and activities. The 6th environmental action
programme contains specific indicators for measures to reduce
the health risks posed by the environment. The EU’s major
public health programme (for the period 2003-2008) adopts

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specific measures to reduce environment-related health risks.
The 6th R&D framework programme contains a section on
environment and health research initiatives. The new chemicals
policy makes it easier to track human exposure to chemicals,
even over a long time, thus providing grounds for action.

4.2.
In Europe, the World Health Organisation (WHO)
launched a specific environment and health programme with
a declaration by European health and environment ministers
in 1989. This work has continued with similar summits in
Helsinki in 1994 and London in 1999. It will be followed up
in spring 2004 in Budapest. The Commission communication
on environment and health must also be seen in this perspec-
tive, i.e. as an EU contribution to the Budapest conference.

4.3.
It is clear from the above that there is a very real need
for a coordinated, consolidated EU environment and health
policy. The Commission’s present communication gives no
indication as to how the Commission intends to solve the
problem of coordinating the various initiatives and pro-
grammes. The EESC regrets this. The EESC expects the
Commission’s forthcoming proposal for a specific environ-
ment and health strategy to spell out the shape coordination is
to take. For the EESC it would seem natural to see the public
health programme as the umbrella initiative to improve the
health of EU citizens, and the new environment and health
initiative as a more specific, in-depth part of the broader health
promotion drive. The final choice of method is perhaps less
important than actually clarifying coordination.

5. A multitude of needs

5.1.
The vast array of problems and desirable actions in
the environmental and health field do, of course, make
prioritisation a risky affair. The Commission focuses on a
limited number of objectives and on active use of present and
future research as providing the specific added value of the
new strategy and action plan. However, this restriction should
not necessarily be seen as the value added of the initiative.
Instead, there should be a clear commitment to providing the
coordination needed for measures and programmes. The EESC
believes that clarification is needed regarding the type of added
value the forthcoming strategy is expected to provide.

One of the shortcomings in the Commission’s com-
5.2.
munication is the paucity of data underpinning the choice
of priorities and target groups. There are currently some
160 million children in the European Union. Health and
disease statistics are available, as is a significant amount of
basic data from many Member States. It would have been
useful if the Commission proposal had included a comprehen-
sive data report, focusing on comparative data. The EESC
assumes that the new strategy proposal will provide relevant
statistics and other basic data in support of the concrete
proposals submitted. This would, of course, also be useful for
the debate that is expected to take place in the Member States
and at local level.

5.3.
Another shortcoming of the communication is the fact
that, apart from some general indications, it is difficult to
specify targets for the forthcoming action plan. The EESC is
fully aware of the difficulty involved in setting more concrete
targets in such a problematic area as the environment and
health sector. In this respect, the EESC would, however, refer
to the ‘Millennium Goals’ which are often used as a reference
in planning and assessing development and development aid.
In the EESC’s view, the Commission should consider the
possibility of using the Millennium Goals as a template for
environment and health objectives. This would involve trying
to give a relative picture of the improvements that should have
been made by the end of the first six-year cycle, such as a drop
in cases of certain child diseases and at certain age intervals.

5.4.
The EESC would stress that it should also be possible
to set Millennium-type goals for new cases of asthma or
allergies. For other child diseases, such as child cancer, it is
undoubtedly more difficult to set targets. With environment
and health issues, however, it is not just a matter of preventing
new cases of illness, but also of reducing major risk factors in
the long-term, e.g. water- or air-borne heavy metals. Here
too,
it should be possible to set improvement objectives.
Millennium-type objectives must, of necessity, be long-term
objectives, stretching over at least 6-7 years and preferably 10-
15 years. It will be difficult for the programme to be credible
unless it gives some clarification of the desired objectives and
of the impact assessment criteria.

The approach to the new strategy and action plan
5.5.
implies that it would be possible to focus on children as a target
group without substantially affecting other target groups. This
is clearly not the case; a number of child health measures also
have a very real impact on certain groups of adults.

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As the Council conclusions to the Commission com-
5.6.
munication also underline, a comprehensive environment and
health strategy should not be drawn up without taking socio-
economic environmental health factors into account.

6. Broad consultation with stakeholders

The EESC welcomes the approach, which aims for the
6.1.
broad, long-term involvement of stakeholders in framing and
implementing the strategy and the action plan. The social
partners and civil society organisations have a clear, important
duty to play an active role in the strategy. The EESC would
express its satisfaction at the Commission’s clear prioritisation
in this area. However, the EESC would highlight the need for
sufficient time to be provided for the consultation process,
otherwise there is a risk that this laudable initiative will give
rise to some disappointment.

It is very important that the new Member States and
6.2.
candidate countries should be involved in planning and
implementation. From the very beginning the Commission has
sought the active involvement of stakeholders in the new
Member States. In this connection, the EESC would highlight
the considerable improvements made in these countries in
terms of particle, sulphur and sulphur dioxide emissions.
Although these improvements are partly thanks to radical
industrial conversion — including closure of ageing pro-
duction plant — discrepancies in environmental protection
and policy are no longer so great as they were 5-8 years ago.
This should enable the new Member States to be usefully
involved from the outset in planning and implementing the
new environment and health strategy.

6.3.
The objectives of the forthcoming strategy require
some consideration of resources and financial assistance, and
not just for the new Member States. A strategy that does not
address the financial
implications will rapidly decline in
interest. The EESC assumes that the new strategy will shed
light on the type of resources that might be earmarked for
implementation, and that the question of support to the new
Member States will be given specific attention.

the

tools

Legislation is obviously one of

6.4.
for
implementing the strategy. However, while the issue of
environment and health has to be addressed at EU, national,
regional and local level, the communication has nothing of
note to say on the question of distribution of competences.
The responsibilities of every level should be clarified as far as
possible. In this connection, the EESC would express its hope
that the Commission will set up a standing advisory committee
on the development and assessment of the strategy.

The new environment and health strategy will make
6.5.
significant organisational demands in terms of involving the
various parties in planning and implementation. No similar
programme, focusing on children for the first six years, has yet
been undertaken at EU level. With children as the target group,
new channels of communication can be established, and there
is scope for a wide-ranging information and consultation
exercise.

6.6.
The way stakeholder participation in planning and
implementation is conducted in practice is a very important
in planning is one thing,
issue. Stakeholder involvement
involvement in actual implementation is another. Although
individual organisations might find it difficult to play an active
role in the implementation process, their contribution in
planning, garnering support and in the follow-up process is
extremely important. Raising awareness and establishing grass-
roots support and commitment will be essential, and the social
partners and civil society organisations have a key role to play
here. However, this will require a strategy with concrete and
operational objectives.

7. Research efforts and assessment

7.1.
The Commission communication stresses the import-
ance of coordinated research efforts in order to improve
knowledge of the link between the environment and health.
The 6th R&D framework programme includes specific indi-
cators for this research. While the EESC welcomes the link
made by the Commission between specific strategy efforts and
continued research, it would also point out that significant
research findings already exist in the area of the environment
and health. New research efforts should therefore build on
existing research findings. This might seem self-evident, but
there is a risk that the enthusiasm generated by the chance to
undertake new research could make people forget to take on
board existing research properly.

7.2.
The EESC would particularly highlight the need for
research into health risks resulting from a combination of
environmental factors. In recent decades the environment and
health debate has tended to focus on one environmental factor
at a time, and less often on combinations of environmental
factors where covariance can accelerate health risks.

7.3.
The research and development work implied by the
new action plan will also require a considerable number of
new researchers, and consequently more researcher training.
The availability of qualified staff could be the new programme’s
Achilles’ heel. The EESC assumes that this question will be
addressed in the forthcoming action plan.

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The communication underlines the need for evaluating
7.4.
progress in the implementation of the strategy. The EESC
welcomes the fact that the evaluation is to be part of the
strategy from the outset, but would point out that this will
necessitate concrete and measurable objectives for the strategy,
and formulating such objectives will at the same time serve as
an instrument for the definition of the strategy’s added value.

The EESC therefore calls upon the Commission to
8.3.
bridge this gap by giving meaning to the brief point in the
Communication that refers to occupational health issues. This
point should be extended to cover the whole relationship
between the environment and occupational health, within the
overall context of the new strategy and its cyclical priorities.
The social partners should be actively involved from the very
beginning.

7.5.
The new strategy and action plan will be reported to
the WHO European Conference on ‘The Future for our
Children’ in June 2005 in Budapest. The EESC welcomes the
opportunity to work with the WHO on European environment
and health issues.

7.6.
In this connection, the EESC would point out that the
WHO uses a somewhat broader definition of the environment
than that employed by the Commission in its communication.
The WHO definition includes socio-economic factors, poverty,
lack of infrastructure etc., whereas the Commission focuses on
chemical and biological pollution.

7.7.
The Commission and the EU have had limited com-
petence for health questions under the Treaties thus far. This
is currently to be found in Articles 152 and 174. The draft
constitutional treaty for the EU extends it to include cross-
border health questions in the broad sense. This should give
the Commission the basis needed for the new environment
and health programme.

8. Occupational environment

issues and the new

strategy

8.1.
The Commission believes that the strategy will develop
synergies with the Community strategy on health and safety at
work, but the communication does not elaborate on how or
where synergies might be expected or possible. The EESC
considers occupational health issues an obvious part of the
concept of environment and health and recommends giving
more attention to these issues in the strategy. The Commission
communication tends to make only passing references to
the occupational environment and related problems. This is
unfortunate, as it could create the impression that occupational
health is not generally a priority issue for the Commission.
This is clearly not the case; there is a major action programme
dealing specifically with working environment issues.

9. Specific comments

9.1.
The EESC strongly supports the reference to developing
a thematic strategy for the improvement of air quality. The
Clean Air for Europe programme, addressing in particular
nitrogen dioxide and ozone, will provide a basis for a review
of Directive l999/30/EC, which sets limit values for the
concentration of SO2, NO2, NOx, lead and particulate matter,
before the end of 2003. A proposal for a new directive on
heavy metals and polyaromatic hydrocarbons is due to be
adopted. The EESC recommends linking the efforts for improv-
ing air quality more closely to other relevant Commission
initiatives. The added value of the strategy in this context is
not clear.

The regions of the enlarged EU will differ considerably
9.2.
in their needs for concrete measures to foster better health
conditions. The EESC suggests that the strategy should investi-
gate which regions have particular difficulty with environment
and health risks, and consequently need priority treatment
under the strategy’s action programme or under other related
EU-programmes. Regions and projects that can be expected to
yield concrete, cost-effective results should also be given
priority.

9.3.
The launch of the new chemicals policy will make
available new instruments for assessing health threats, particu-
larly to children. The EESC would stress the urgent need for
the Commission to assess how the chemicals policy might,
hopefully, provide a support mechanism for the environment
and health strategy.

8.2.
The EESC would also stress that it is through the
protection of occupational health and the relationship between
industrial installations and the surrounding territory that some
of the most important environmental protection initiatives
have been accomplished. These initiatives underpin all the
legislative advances achieved by society in the area of protec-
tion of health and the environment.

Children are indoors for much of the day, and therefore
9.4.
need the indoor environment to be of a satisfactory quality (as
regards air pollution, noise, etc.). At the same time it is useful
to point out that several possible child-health measures also
include occupational health issues (e.g. nursery schools).

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Smoking is a significant environmental factor affecting
9.5.
child health. The Commission communication does not
address smoking risks to child health, despite the fact that
the evidence would appear to be convincing. The EESC
recommends that the action plan should also address the effect
of tobacco on children’s health.

9.6.
The EESC has on previous occasions addressed the
need for integrated environment and health indicators to
measure the long-term effects of the new programme. The
EESC would point out that a significant amount of develop-
ment work is being conducted on indicators for sustainable
development in the broad sense. An annual progress report on
sustainable development and on the Lisbon Strategy is pre-
pared for every Spring European Council. The EESC rec-
ommends that environment and health issues should also be
reported annually, preferably in time for the Spring European
Council.

9.7.
The EESC has also previously touched on the proposed
six-year cycle approach. The arguments for a six-year cycle
have not emerged clearly. On the other hand, perhaps the
number of years selected is not so important, as long as future
multi-annual periods can be planned well in advance, and that
the introduction of new priorities does not lead to a sudden
shift in emphasis. Long-term continuity is, of course, worth
aiming for, and should be planned for well in advance.

countries, the problem of child obesity is still fairly contained,
but the signs are that the EU will eventually have the same
problems as the US — and which countries such as the UK are
already beginning to experience. It is a moot point whether
obesity is an environment-related problem or not; it is more
to do with lifestyle than the environment. Depending on how
broadly one wishes to interpret the ‘social environment’ —
which is directly related to obesity — child obesity could
benefit from being included in the strategy.

10. The role of the EESC

10.1. Within the EESC there is considerable expertise on
environment and health issues. With enlargement this will no
doubt be enhanced by the experience of the new Member
States.

10.2.
The EESC is actively participating in the consultation
process, as part of the commitment of the Committee to these
issues.

10.3.
The EESC will use its own specific channels of
communication to disseminate information on the develop-
ment of the new initiative, once it has been launched.

9.8. With regard to child health priorities, the EESC notes
that little attention has been devoted to obesity. For most EU

10.4.
The EESC is ready to give its active support to
future efforts in this field, by way of organising stakeholder
consultations, or in other ways.

Brussels, 10 December 2003.

The President

of the European Economic and Social Committee

Roger BRIESCH