Opinion of the European Economic and Social Committee on the ‘Communication from the Council, the European Parliament, the European Economic and Social Committee — The European Environment and Health Action Plan 2004-2010’(COM(2004) 416 final)
Date: 2004-12-15
Institutions: European Economic and Social Committee
Subjects: EU policy, EU programme, action programme, environmental policy, health policy

28.6.2005

EN

Official Journal of the European Union

C 157/65

Opinion of the European Economic and Social Committee on the ‘Communication from the
Council, the European Parliament, the European Economic and Social Committee — The European
Environment and Health Action Plan 2004-2010’

(COM(2004) 416 final)

(2005/C 157/10)

On 10 June 2004, the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the abovementioned communi-
cation.

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 16 November 2004. The rapporteur was Mr
Braghin.

At its 413th plenary session, held on 15 December 2004, the European Economic and Social Committee
adopted the following opinion by 146 votes, with two abstentions.

1. Gist of the Opinion

— developing scientific methods for risk assessment and stan-
dardising and testing methods so as to ensure a solid scien-
tific basis for the endpoints and targets to be achieved;

The Committee, believing environmental and health
1.1
issues to be strategic priority objectives, but considering that
the proposed plan falls short of presenting a cohesive and
comprehensive plan of concrete actions with accompanying
timescales, urges the Council and the European Parliament to
support the Commission's efforts to define a more concrete
action plan, and thereby to ensure that an integrated approach
is adopted for such matters, with more clearly defined objec-
tives and precise guidelines for the establishment of appropriate
Community and national policies.

1.2 With this objective in mind, the EESC recommends that
the relevant authorities continue to engage with renewed
commitment and with the full participation of experts and
stakeholders with a view to:

— identifying existing possibilities for integrating the identified
objectives
that are
into specific research programmes
related to the theme, as well as actions provided for in the
action programme for public health and the Community
programme for the environment;

— taking immediate steps to include environmental and health
issues as priority areas in the recently initiated FP7 debate,
and to do likewise in the future debate on the new public
health action programme;

— identifying the financial resources, within the context of
such programmes, to be allocated to the three main objec-
tives identified as priorities (with which the EESC fully
concurs) and the 13 declared objectives;

— implementing and promoting cooperation and bench-
marking activities to accelerate the consolidation of data
relevant to effective action, and to identify successful inter-
ventions at national, regional and local level, which could
be applied to other territories;

— defining the precise responsibilities and duties of the rele-
vant authorities and identifying efficient cooperation and
action coordination procedures, and the financial resources
earmarked to implement them.

The EESC recommends that further efforts be made to
1.3
find specific ways to rise above a predominantly cognitive
approach and to adopt a genuine and authentic action plan
with specific and, wherever possible, quantitative objectives. It
urges the Commission to take steps to accelerate the implemen-
tation of the action plan and to identify the objectives and
actions that are particularly relevant to the second phase of the
plan itself.

Finally, the EESC reminds all European institutions and
1.4
Member States of their political responsibility to ensure that
due attention is paid to the fundamental objectives outlined in
the Communication under
consideration during ongoing
discussions regarding the funding of the European Union and
it urges the
its activities from 2007 to 2013. Furthermore,
Commission to draft, in good time, the necessary documenta-
tion to provide more targeted appropriations for these widely
shared priorities.

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2. Summary of the Commission Communication

— reviewing policies and improving communication (actions

9-13).

2.1
The Commission launched an Environment and Health
Strategy in June 2003 (referred to as the SCALE initiative (1))
proposing an integrated approach involving closer cooperation
between the health, environment and research areas. Its added
value is the development of a Community System integrating
information on the state of the environment, the ecosystem
and human health. This will render the assessment of the
overall environmental impact on human health more efficient
such as: cocktail effects,
by taking into account effects
combined exposure, and cumulative effects. The strategy's ulti-
mate goal is to develop an environment and health ‘cause-effect
framework’ that will provide the necessary information for the
development of Community policy dealing with sources and
the impact pathway of health stressors.

2.2
The Strategy puts special emphasis on children in so far
as their exposure and susceptibility are greater than those of
adults. The challenge now is to put into practice the commit-
ments regarding children's right to grow and live in healthy
environments.

2.3
The SCALE initiative involved 150 experts subdivided
into 9 technical working groups and an equal number of repre-
including members of
sentatives from all Member States,
national agencies, research centres, universities, health and
environmental services,
industry and social enterprises that
have helped to draft recommendations in consultative and
coordination groups, regional conferences, fora, and informal
meetings amongst Member States.

2.6
The Action Plan focuses particularly on gaining a better
understanding of the links between environmental factors and
respiratory diseases, neurodevelopmental disorders, cancer and
endocrine disrupting effects, all with a rising incidence in chil-
dren. The Action Plan will set up targeted research actions to
improve and refine knowledge of the relevant causal links, and
at the same time, health monitoring will be improved to obtain
a better picture of disease occurrence across the Community.

The other key information aspect is to monitor exposure
2.7
to environmental risk factors, including food, the home envir-
onment, and behaviour that could be associated with health
risks, such as specific life styles.

2.8
In order to achieve the Action Plan, the Commission
will engage with and promote cooperation with the European
Environment Agency, the European Food Safety Agency and
the principal stakeholders (Member States, national, regional
and local authorities, health, environmental and research
centres, the industrial and agricultural sectors, and other rele-
vant bodies). It will also coordinate with international organisa-
tions, such as the WHO, OECD and relevant United Nations
agencies.

The Action Plan for the period 2004-2010 outlined in
2.4
the Communication (2) is designed to give the EU the scientifi-
cally grounded information needed to help all 25 EU Member
States reduce the adverse health impacts of certain environ-
mental
factors and to endorse better cooperation between
actors in the environment, health and research fields.

2.9
In 2007 the Commission will carry out a mid-term
review of the implementation of the Action Plan. The Commis-
sion will implement the actions through existing initiatives and
programmes, which already have allocated resources, notably
the Public Health Programme, the Sixth Framework Programme
for Research and under the operational budget of the services
concerned.

2.5

The Action Plan has three main themes:

— improving the information chain to understand the links
between sources of pollution and health effects (actions 1-
4);

— filling the knowledge gap by strengthening research and
addressing the emerging issues on environment and health
(actions 5-8);

(1) Communication from the Commission on a European Environment
and Health Strategy COM(2003) 338 final. The EESC delivered its
opinion on this Communication at its 404th plenary session of 10
December 2003. The rapporteur was Mr Ehnmark. OJ C 80 of
30.3.2004

(2) Communication from the Commission – The European Environ-
ment and Health Action Plan 2004-2010, COM(2004) 416 final of
9.6.2004, Volumes I and II

3. Problematic issues within the scope of the Action Plan

The Committee, like the Commission and the Member
3.1
States, pays ever
increasing attention to environment and
health issues and upholds the need for a clear strategy and effi-
cient action plan to ensure an integrated approach to these
issues and to contribute to the development of appropriate
Community and national policies. These should successfully
contribute to citizens' wellbeing and quality of life through
sustainable development.

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3.1.1
The preparatory work was complex. It was subdivided
into a series of tightly-scheduled working groups and meetings,
which took place during the year. The EESC commends such
commitment and recognises the value of the work undertaken
by the participants, and in particular by the experts involved in
the technical phases. However, the EESC maintains that the
limited time available prevented an in-depth analysis of
complex and hitherto little-understood areas. As a consequence,
the Communication generally fails to present a cohesive and
comprehensive plan of specific actions, nor does it specify any
clear deadlines for their implementation.

3.1.2
The differences in scope between the Commission's
and Member States' competencies in the fields of environment
and health undoubtedly complicated the process of establishing
their respective responsibilities, and therefore, the actions to be
proposed within the context of the principle of subsidiarity.
The EESC considers that the Commission and the Member
States should intensify their efforts to coordinate and accelerate
the process of acquiring basic knowledge and exchanging infor-
mation and data and to allocate appropriate funding for the
proposed actions.

3.1.3
initial, not
the final, phase of
comments were framed within this context.

The EESC therefore considers the action plan to be the
the process. The following

they are amongst the most vulnerable, but, in the future, also
the elderly and workers exposed to health hazards). It is there-
fore advisable to first allocate the necessary funds for the key
issues and objectives identified. These needs should be taken
into consideration during the ongoing discussions of the EU
budget for 2007-2013, and its breakdown.

3.3
Another extremely sensitive issue is the legal and finan-
interaction with other independent bodies and organisa-
cial
tions. Many actions will be implemented as part of interna-
tional cooperation projects, and this will provide greater scope
for the proposed initiatives. However, there is a risk that the
focus and pace of implementation might suffer. The coordina-
tion and cooperation mechanisms envisaged do not guarantee
cohesive and uniform development of the relevant actions, nor
will
it be easy to identify the parties responsible for imple-
menting specific phases of the actions.

The diversity of stakeholders and their fields of compe-
3.3.1
tence and expertise (consider, for instance, organisations such
as the WHO and the Environment Agency on the one hand
and local and regional authorities on the other) will add to the
complexity of implementation, and perhaps result in cumula-
tive delays
in identifying objectives and the appropriate
measures to achieve them.

3.2
In particular, the EESC draws attention to the need for
appropriate funding since the action plan has not been allo-
cated specific funds for the implementation of the actions it
outlines. It is assumed that each action can be integrated in
existing initiatives and EU funded programmes such as the EU
Public Health Programme,
the Sixth Environment Action
Programme (mentioned in Volume II only), and the Sixth
Framework Programme for Research.

3.3.2
The EESC believes that the roles and responsibilities of
the parties involved should be clearly identified (especially
those pertaining to the Commission, Member States and
regional and local authorities) and that competencies should be
specifically assigned according to the type of actions required
and the respective competencies delegated under the Treaties.
The Communication under consideration does not clarify these
crucial points and thereby confirms the concerns expressed by
the Committee in its earlier opinion on a European environ-
ment and health strategy. (1)

3.2.1
This approach could help to avoid the dispersion of
funds and the futile duplication of projects with identical objec-
tives, but imposes upon the identified strategic priorities the
measures and structures of programmes
that are geared
towards other objectives that do not necessarily coincide with
the objectives outlined in the Communication.

The specific actions described in Volume II do not
3.4
define precise objectives to be achieved, but serve to identify
needs and — in the best hypothesis — tools that the Commis-
sion and other stakeholders might use to respond to knowledge
deficits or needs. Regrettably,
the
EESC's (2) concerns are likely to be confirmed, i.e. that the lack
of concrete objectives other than the so-called Millennium
Goals, constitutes a serious shortcoming that calls into question
the viability of the plan itself.

it would appear

that

The EESC considers the promotion of health to be a
3.2.2
strategic priority objective, especially where the more vulner-
able sectors of the population are concerned (i.e., primarily
children, who are the target beneficiaries of SCALE because

(1) Opinion on a European Environment and Health Strategy, point 6.4
– OJ C 80 of 30.3.2004. The rapporteur was Mr Ehnmark. See foot-
note 1.

(2) Ibid, point 5.3

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3.5
The actions in the plan all share one common factor:
they offer specific details for the first two- or three-year period
but are more general, not to say vague, for the subsequent
four-year period. This framework gives rise to concern since
the plan should result in the practical
implementation of a
strategy, which by definition aims to make a significant long-
term impact. Nor can this shortcoming be justified by the fact
that the resources to be made available as of 2007 have not yet
been specified. The clarity of the desired results is a basic
requirement to ensure that funding commensurate with the
strategy's importance is made available by political decision-
makers.

3.6
The 2007 mid-term review cannot be deemed sufficient.
The EESC recommends two mid-term reviews, one in 2006,
and the other in 2008.

3.6.1
The first mid-term review would make it possible to
take into consideration the results of a series of programmes
and/or actions (not mentioned in the Communication) that are
nearing completion, and would facilitate a rapid assessment of
progress made during the first two years. This would provide a
firm foundation prior
to initiating actions that would be
financed by new appropriations from the 2007 budget.

3.6.2
The second review would ensure that preparations for
subsequent phases and further cycles are based on specific and
timely assessments, extending their application to other vulner-
able target groups (the elderly, for instance), on the basis of a
deeper analysis of
the progress achieved and the obstacles
encountered.

4. Specific comments

4.1
The first group of actions is intended to improve the
information chain by developing integrated environment and
health information to better understand the links between
sources of pollutants and health effects. The EESC regrets that
information needs are still so great, despite the adoption of a
Community action programme 1999-2003 on pollution-
related diseases (1) and a Community action programme on
health monitoring (2) within the framework for action in the
field of public health. It also regrets the fact that the Communi-
reports on the
cation is not accompanied by progress
programmes, and reports on the specific shortcomings to be
remedied during the plan's first implementation phase.

4.1.1
Action 1 (developing environmental health indicators)
and Action 2 (developing integrated monitoring of the environ-
ment, including food, to allow the determination of relevant
in their
are predominantly
human exposure)

cognitive

(1) OJ C 19 of 21.1.1998
(2) OJ C 174 of 17.6.1996

approach. As a result, the development of the actions in the
second phase is poorly conceived. Even in a knowledge deficit
situation, targets such as the comparability and accessibility of
health related data should have been mentioned explicitly, with
a view to facilitating the interoperability and integration of
existing databases, recommending, where appropriate, the allo-
cation of
the
including financial
required methodological studies, and networking existing data,
with the long-term view of creating a European database in the
future.

resources,

resources,

for

4.1.1.1
The EESC recommends, in order to integrate envir-
onmental and human health monitoring, the timely selection of
clinical/epidemiological and experimental research activities to
enhance and refine our knowledge of the causal links between
specific environmental factors and disease.

The biomonitoring action (the use of biomarkers that
4.1.2
are indicative of environmental exposures, diseases, and/or
disorders and genetic susceptibility) appears to be more an
account of the — albeit real — difficulties involved, than a
course of action. The EESC recommends that immediate steps
be taken to define the mandate and targets of the multidisci-
plinary working group on coordination, in order to ensure that
it is an effective and, indeed, a credible operational tool at both
national and Community levels.

The EESC recommends that priority spheres of
4.1.2.1
action and optimal coordination procedures amongst specia-
lised operational centres be developed on the basis of activities
carried out by existing technical working groups, in order to
obtain optimal biomonitoring results. It further recommends
that cohort studies (in particular, mother-child studies) be
developed to evaluate bio-indicators for exposure effectively.

support

4.1.3
Similarly, Action 4 (enhancing coordination and joint
activities on environment and health) proposes the establish-
for
ment of a consultative group and general
exchanges between the relevant authorities. The EESC considers
these proposals to be entirely inadequate since it does not
believe that a consultative group would be sufficient to ensure
the regular exchange of data and best practice. Therefore, in
view of the fact that the responsibility for health and environ-
ment is shared by several ministries, the Committee urges the
Member States to appoint as soon as possible a body or
authority with the responsibility and necessary powers and
tools to coordinate efforts to achieve the desired goals. Simi-
larly, the EESC urges the Commission to set up more appro-
priate coordination bodies and to propose more incisive tools
to facilitate the process.

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4.2
The second group of actions aims to ‘integrate and
strengthen European environment and health research’. The
concrete actions outlined in the Communication annexe are
the intention to consolidate fundamental
also indicative of
information rather
than the intention to set up concrete
research projects. Action 5 consists of an analysis of what has
already been achieved within the framework of the JRCs or
existing research projects, together with plans for conferences
on the subject. Action 6 is an analysis of the causes and
mechanisms of specified diseases and the establishment of a
Europe-wide research network rather than an attempt to ‘target
research on diseases, disorders and exposures’ since it fails to
indicate what course research should take. Finally, Action 7
aims to establish a methodological system to develop risk
assessment methodologies taking account of complex interac-
tions and externalities, and a methodological system for harmo-
nising and validating these methods.

4.2.1
The EESC recommends that the current large scale
epidemiological data deficit be remedied as soon as possible,
especially in matters relating to neurobehavioural disorders in
Europe, where there is insufficient scientific data regarding
infants and children but where there is sufficient evidence to
establish an etiological link, even if this cannot be exclusively
attributed to environmental factors.

4.2.2
The EESC recommends that interdisciplinary research
on health and the environment should be made priorities in
the Seventh Framework Programme for Research. Furthermore,
immediate steps should be taken to ensure that the specific
programmes that are already funded have the resources they
need to enable us to add to our knowledge and identify effec-
tive intervention tools and methods in the health and environ-
mental sector.

4.2.3
Action 8 (Ensuring that potential health and environ-
mental hazards are identified and addressed) puts forward more
precise objectives. It aims to find ways to improve the health
sector's early assessment and preparation for extreme climate
change and other global environmental hazards. The EESC
upholds these objectives, even if they are not strictly related to
the overall objective of the SCALE initiative, i.e. safeguarding
children's health. The EESC hopes that such actions should

Brussels, 15 December 2004

make it possible to set up an appropriate programme with
specifically allocated funds in the medium term. It should not
be incorporated, as proposed, in an unsuitable framework that
lacks specifically allocated funds.

4.3
The next two actions (Actions 9 and 10) aim to develop
awareness raising, risk communication, training and education.
They raise some interesting points but do not provide a solid
basis for a real communication and training strategy that
promotes appropriate behavioural changes and focuses the
actions of Member States, which are responsible for this sphere
of action. The EESC has already pointed out that ‘raising aware-
ness and establishing grass-roots support and commitment will
be essential, and the social partners and civil society organisa-
tions have a key role to play here’. (1)

4.3.1
The last actions proposed (Actions 11, 12 and 13) aim
to review and adjust risk reduction policy for risks that are
directly related to the diseases primarily targeted by the plan
(respiratory diseases, neurodevelopmental disorders, cancer, and
endocrine disruption effects). They recommend initiatives such
as pilot schemes, developing networks, encouraging coordina-
tion, or simply following developments regarding electromag-
netic fields. In general, this reads more like a list of good inten-
tions rather than an attempt to draw up a list of concrete and
exhaustive conditions for high-risk scenarios. The EESC believes
that such proposals are not commensurate with the grievously
harmful effects on health already outlined in the previous
Communication on the strategy. Nor are they likely to produce
a genuine reduction policy within a reasonable period of time.

The EESC strongly recommends that research into
4.3.2
factors that affect air quality in offices and homes should be
addressed as a matter of urgency (as indicated in Action 12).
Scientific data should be compiled by a clearly specified dead-
line in the not-too-distant future,
in order to facilitate a re-
assessment of the 1999 recommendation on electromagnetic
fields. For the EESC, the lack of any specific objectives and
outcomes expected within a specified timeframe raises the
concern that the plan will not even succeed in identifying effi-
cient mechanisms for the coordination of existing Community
level activities, or coordination with Member States.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

(1) OJ C 80 of 30.3.2004