Opinion of the European Economic and Social Committee on the Quality standards for the contents, procedures and methods of social impact assessments from the point of view of the social partners and other civil society players
Date: 2007-05-31
Institutions: European Economic and Social Committee
Subjects: EU law, EU statistics, company constituted under civil law, social impact, social partners

27.7.2007

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Official Journal of the European Union

C 175/21

Opinion of the European Economic and Social Committee on the ‘Quality standards for the
contents, procedures and methods of social impact assessments from the point of view of the social
partners and other civil society players’

(2007/C 175/06)

In a letter dated 19 September 2006, Mr Wilhelm Schönfelder, Ambassador Extraordinary and
Plenipotentiary, Permanent Representative of the German Republic to the EU, acting on behalf of the
German Council Presidency, requested the European Economic and Social Committee to draw up an
opinion on abovementioned proposal.

The Section for Single Market, Production and Consumption, which was responsible for preparing the
Committee's work on the subject, adopted its opinion on 3 May 2007 The rapporteur was Mr Retureau.

At its 436th plenary session, held on 30 and 31 May 2007 (meeting of 31 May), the European Economic
and Social Committee adopted the following opinion by 102 votes to 3 with 5 abstentions.

1. Introduction

citizens expect Europe to be social — or the Single Market to be
socially compatible — and express in many ways their wish to
be associated to the process of bringing the EU closer to them.

the German Presidency for an exploratory
The request of
opinion on ‘Quality standards for the contents, procedures and
methods of social impact assessments from the point of view of
the social partners and other civil society players’ illustrates the
will of the German government to focus on better regulation in
cooperation with the Portuguese and Slovenian Presidencies and
as a follow-up to the Six Presidencies Declaration of 2004.
Thereby,
for all new
projects will be a key element of the German action plan. These
impact in the regulation
would (…)
take account of social
process’ (2).
‘Impact assessment can be defined simply as a
method for identifying the anticipated or actual effects of an
intervention. The aim of impact assessment is to improve the
evidence base on which decisions are made, and thereby
improve the quality of decision-making’ (3).

‘comprehensive impact assessments (1)

2. General comments

On the occasion of the European Commission conference on
the further development of Impact Assessments in the European
Union (held on 20 March 2006 in Brussels), it has been said
that ‘there is a broad consensus that principles underpinning the
European Commission's Impact Assessment system are sound’
and that, furthermore, they must include economic, social and
environmental impacts (4). In the first place, impact assessments
have been introduced in the context of the upstream improve-
ment of
the European Union.
Taking account of the social dimension or consequences of EU
legislation is inherent to abiding the Social Agenda. European

the regulatory framework of

(1) Abbreviated in “IAs”.
(2) ‘Europe — succeeding together’, Presidency programme, 1 January to
30 June 2007 — issued by the German Federal Government (see
also
http://www.eu2007.de).

(3) From ‘European Governance Reform: The Role of Sustainability Impact
Assessment’, C. Kirkpatrick, S. Mosedale, University of Manchester,
2002.

(4) The European Parliament is proposing a fourth pillar for impact assess-
ments, that of fundamental rights. The question of whether to treat
fundamental rights separately or mainstream them in the three other
proposed pillars is still open. In any event, the impact on fundamental
rights must be assessed.

2.1 The European Commission's initiative to implement impact assess-

ments — A short retrospective

The European Commission's initiative of 2003 to implement an
i.e.
impact assessment procedure for all major drafts,
those
in the Work
included in the Annual Policy Strategy or
Programme of the Commission, is based on the fact that these
proposals have a potential economic, social and/or environ-
mental impact and/or require some regulatory measure for their
implementation (5). This initiative had been launched with a
view to gradually integrate impact assessments into the legisla-
tive process by 2005 (6).

Since 2003, a lot has been said on IAs in general but little of
social aspects of IAs in particular.

2.2 Social aspects

in IAs — a short

review of

the European

Commission's work

2.2.1
Logically enough, DG ‘Education and Culture’ and DG
include
‘Employment, Social Affairs and Equal Opportunities’
social aspects in their IAs. Furthermore, the ‘principle of propor-
tionate analysis’ (7) induces differences in the degree of integration
of social elements in other areas. This raises the question of
whether or not social aspects (including items related to the EU
Social Agenda) need be considered as a bottom line and also

(5) ‘The inclusion of social elements in Impact Assessments’, p. 13. Docu-
ment issued by the Instituto per la ricerca sociale, January 2006. This
institute has compiled Commission documents (decisions, regulations,
communications and directives) over a period of 3 years — i.e. between
2003 and 2005.
(6) In June 2005,

the European Commission published its ‘Impact

Assessment Guidelines’, ref. SEC (2005)791. See also under
http://ec.europa.eu/enterprise/regulation/better_regulation/impact_as-
sessment/docs/sec_2005_791_guidelines_annexes.pdf.

(7) The principle of proportionate analysis implies variations in ‘the degree
of detail to the likely impacts of the proposal. This means that the depth
of the analysis will be proportionate to the significance of its likely
impacts’. COM(2002) 276.

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how to deal with proposals not related to social issues or likely
to have a weak social consequence. Empirically, the study of the
Istituto per la ricerca sociale (see e.g. footnote 2) reveals that
‘IAs lacking consideration for social aspects tend to concentrate
in the economic field. Here, one third of the IAs includes social
aspects only marginally or not at all’ (8).

2.2.2
Obviously, ‘when the social relevance of the measure is
self-evident (…), social aspects are widely considered and quite
the impact assessment document’ (9).
developed throughout
There, ‘the employment issue clearly emerges as the most recur-
rent and stressed social consequence’ (10).

According to the Istituto per la ricerca sociale,

2.2.3
‘the
degree to which social elements are considered is not necessarily
“proportionate (…)” to the policy content and its likely impact.
(…) In many cases these impacts are only described generically
(…)’ and ‘are based on (…) shared assumptions (…). Such rela-
tions are seldom discussed when taking into account the specific
content of the measure, the target population and interested
territorial areas, the specific choice of policy instruments and
the effect of the implementation process’ (11). The study carried
out by this institute also states that ‘several IAs have not envi-
saged any correlation with other policy domains or EU policies’.
While the work involved in conducting impact analyses is
considerable, the latter must not be incomplete or superficial, or
their shortcomings will undermine the value of the legislation.

2.3 The role of stakeholders in IAs

2.3.1
Evaluation of the impact of a legislative draft is not a
‘tick box activity’. It also needs to be monitored — ideally by or
in close cooperation with users of the law, especially those who
will be most directly concerned. Since the social dimension is
one of the three assessment criteria for EU policies there is a
need to organise a standard procedure — both transparent and
straightforward — for the collection of targeted inputs in the
context of IAs. A few options can be mentioned:

— consultation via Internet: large scale on-line consultation is
not appropriate for specific legal drafts with social conse-
quences. On-line consultation needs to be narrowed down
to those actors directly involved. Targeted consultation
requires thematic networking (thematic IA web commu-
nities?) and a minimum of structure and coordination —
and monitoring;

— consultation
constraints,
degree of precision;

via

stakeholders

time
this option might not allow for the proper

forums:

due

to

(8) ‘The inclusion of social elements in Impact Assessments’, p. 28.
(9) Ibid, p. 30.
(10) Ibid, p. 31.
(11) Ibid, p. 77.

— consultation of formal advisory platforms: this raises the
question of involving such bodies as the European Economic
and Social Committee in the social IA process (this actually
could also apply for IAs in the area of sustainable develop-
ment). By definition, such bodies have been set up to intro-
duce pluralism between interests and correlation between
policies;

— targeted consultation with relevant stakeholder: is called for

by a number of civil society organisations.

3. Basic methodological statements

A number of questions must be posed in order to deter-

3.1
mine what methodology could be recommended:

— What is the state of the art,

i.e. what has the European
Commission achieved in terms of including social aspects in
its IAs?

— Does an assessment of the social impact of a draft apply to
all legislative proposals or does each draft require a separate
ad-hoc study?

— What is the role of the stakeholders? How can they best be

associated to the process?

— What could be the role of the European Economic and
Social Committee as an assembly of representatives of orga-
nised civil society and as a strategically ideally situated ‘hub’
for contacts and networking?

— To what extent have the contributions of the social partners
and of the main NGOs been taken into account by the
Commission in assessing the social impact of its proposals?
How can they best be involved?

— Should we not envisage a more precise code of conduct
than that currently used by the Commission, or ethical rules
for such social impact assessments?

— Along what lines should social IAs be made (internally or
through outsourcing by way of calls for tenders and if so on
the basis of what criteria)?

4. Internal considerations

In view of the complexity and importance of evaluating
4.1
the social consequences of
legislative proposals, all actors
concerned, i.e. social partners as well as representatives of civil
society organisations, should reflect upon the following metho-
dological issues:

— What form should such a study take and what should be its

scope?

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— Does such an evaluation cover a large spectrum of items (e.
g. ‘Better Lawmaking’, Green Book on ‘Matrimonial property
regimes incl. mutual recognition’) or should we focus on
topics with a clear social content (e.g. port services, mari-
time safety, Green Book on ‘Modernising labour law’)?

— What does it
drafting?

imply in terms of preparatory work and

— In view of

the need for a ‘scientific’ approach (the title
mentions ‘quality standards’), do we have to determine
implicit standards based on practical cases and experience or
do we need to develop these standards in the first place?

A public hearing at

4.2
the Committee has given social
NGOs, social partners, other actors of organised civil society
and experts a chance to express their views and discuss the draft
opinion so as to pass clear messages to the European institu-
tions in general and to the Commission in particular.

Ultimately and in view of the fact that social IAs are an
4.3
element of paramount importance in the EU decision-making
process, the Committee should make proposals on how to bring
about improvements and better integrate civil society organisa-
tions in this procedure.

5. Social indicators: general considerations and methodolo-

gical issues

5.1
Several different social indicator systems already exist at
national and international level, but it is necessary to ascertain
how useful and how suitable they would be for the specific
purposes of impact analysis.

Social

5.2
indicators have been developed in a number of
countries over the past thirty years as an alternative to assessing
the appropriateness and impact of economic policies in terms of
basic, quantitative data, with a view to ‘steering’ social develop-
ment in parallel with economic development and developing
the capacity to measure social well-being and its evolution.

5.3
As a result, there has been a significant growth in the
amount of social statistics available, particularly in major areas
of collective responsibility such as education, health, social
protection, the environment, housing, transport, research and
unemployment. However, unless
is organised,
summarised and interpreted, it does not automatically lead to
the creation of social indicators.

this data

and/or

action’ (12). As

An indicator is ‘merely a statistic, to which particular
5.4
judge-
importance is attached for the purposes of knowledge,
ment
are
concerned, it is not simply a question of compiling social statis-
tics, from various sources, for each country, but of structuring
this data in order to assess the current situation in relation to
specific themes, selected on the basis of their relevance to the
impact analysis.

analyses

impact

far

as

(12) Bernard Perret, Indicateurs sociaux, état des lieux et perspectives,

CERC Working Papers, No 2002/01, (French version only)
www.cerc.gouv.fr.

5.5
It is quite possible that in some areas, only sparse or
fragmented studies and surveys may be available, making it
impossible to conduct a cost/benefit analysis. For example, we
already know that certain categories of pesticides are harmful to
health and that concentrations in excess of a certain threshold
cause serious illness. Yet, although a decision to reduce the use
of chemical pesticides would have a positive impact on the
health of the general population and of workers exposed to
these pesticides, it would be impossible to produce exact figures
on the long term benefits of this policy within the framework
of a proportional impact study.

5.6
On the other hand, the social and health aspects would
clearly justify the proposed measure and would provide conside-
rable reinforcement for the economic arguments (which would
include the reduction of production costs for agriculture and the
resulting increase in competitiveness). In addition, the funda-
mental right to a clean environment could be raised in support
of the proposal.

5.7
In practice, we now have access to a considerable volume
of social statistics and these have also diversified in accordance
with the changing foci of public debate in the various countries
(such as working conditions, employment of young people,
older people and women, crime, income inequalities, discrimi-
nation at work and relocations). Further, although few social
indicators were drawn from this mass of statistics until very
recently, fortunately, in the new socio-economic climate which
has developed over the past ten years, where emphasis is again
being placed on the role of the state in social policy and regu-
lating the market,
again being
acknowledged.

relevance

is once

their

5.8
However, social indicators do not always serve any great
purpose if they stand alone, and take on more meaning if they
are integrated into a broader concept, such as social and
economic development or sustainable development. They now
come from an increasingly diverse range of sources, not just
central government but also from NGOs, and the think tanks
operated by major foundations. They are also being presented in
increasingly diverse ways, ranging from the selection of statistics
to thematic surveys, and the compilation of data to form
composite thematic or general indicators.

5.9
A number of international bodies publish social indica-
tors and statistics and conduct comparisons between their
member states. In this connection, the main bodies of relevance
for the EU countries are (in no particular order) the OECD, the
UNDP,
Eurostat,
UNESCO, the World Bank and the ILO.

European Commission, particularly

the

5.10
This very diversity of sources poses a number of
problems in itself: firstly, with regard to the quality of the statis-
tics, in that not all countries have sophisticated Statistics Offices,
secondly in terms of comparability and thirdly in terms of
harmonising concepts. For,
for
‘the
the EU countries is a
measuring the social convergence of

choice of

indicators

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highly political issue. The indicators used for comparisons are
not neutral: they not only reflect priorities but also sometimes
particular understandings about what kind of
society is
desirable, which may legitimately vary from one state to
another. The example of unemployment demonstrates that
some indicators may have tangible and possibly even negative
impacts on policy orientation (13). Notwithstanding, as things
currently stand, the construction of indicator systems is left
entirely to technicians.’ (14)

The use of GDP and growth as indicators of social well-
5.11
being has been particularly critiqued within the UNDP, which
has developed its own HDI (human development index), notably
under the impetus of Amartya Sen's work on poverty, famine
and democracy and his critical analysis of the use of purely
economic, quantitative indicators, which won him the Nobel
Prize in Economics.

Data on access to drinking water, male and female
5.12
literacy,
the health system and the outcome of campaigns
against pandemics, participation in the democratic process,
gender and life expectancy, perinatal and infant mortality are all
relevant for assessing a society's level of wellbeing and the envir-
onmental situation. However, this data is not directly correlated
with GDP.

The UNDPs first composite HDI

5.13
indicators therefore
provoked broad debate and controversy, since the ‘rich’ coun-
tries were sometimes well below the top ranking in terms of
‘gross national happiness’. Nevertheless, in view of its solidity (it
covers education, life expectancy and incomes adjusted to take
account of poverty) this indicator has become the most widely
accepted alternative to the purely economic indicators.

are

Social

statistics

a necessary

5.14
to
economic statistics and, in that the public ascribes considerable
importance to the key social issues, they also have a political
import which it is imperative for governments to take into
account.

complement

Above and beyond narrow economistic thinking and
5.15
financial short or medium-termism, we must, in all objectivity,
recognise that other obstacles
this
happening, notably, the diversity of social issues and the diffi-
culty of linking and quantifying them with a view to their inte-
gration into economic policy orientations.

stand in the way of

intuitively, come to the same conclusions
5.16 We could,
regarding the establishment of environmental indicators aimed

(13) As Jean-Baptiste de Foucault states in Joelle Affichard's “The relevance
of statistical
indicators in directing social policy” (Institut Paris la
Défense), “There is always a danger that the fight against unemploy-
ment will be diverted into a fight against unemployment figures”.

(14) Bernard Perret,

‘Indicateurs sociaux, état des lieux et perspectives’,

CERC Working Papers, No 2002/01,
www.cerc.gouv.fr (French only).

at re-integrating external factors into economic growth. For, ulti-
mately, a model of growth that involved the clearing of virgin
forest should be rejected, were the impact study to integrate all
the social and environmental factors which, as we now know,
more than outweigh the economic and monetary factors. On
the other hand, it is extremely difficult to put a monetary figure
on external factors, such as climate change, the loss of biodiver-
sity, the fate of people who make a living from gathering or
using medicinal plants, rapid soil exhaustion and the resulting
soil erosion. Although a short term audit might appear largely
positive,
if these external factors were brought back into the
picture, the long-term outlook might well be extremely negative,
not only for the region or the country concerned, but for the
planet as a whole.

impact, the social

5.17
The objective limits of the use of social and environ-
mental aspects in impact analyses are clearly demonstrated in
the cost-benefit approach underpinning a number of the ‘better
lawmaking’ assessments and used in EU impact studies (15).
Although a relevant indicator (such as number of job losses or
lack of opportunities for re-employment) may be used to assess
the social
impact itself is not necessarily a
determining factor in the political decision-making process. It
often comprises elements that are difficult to quantify, particu-
larly when impact studies cast their evaluations in terms of
short-term — or at best, medium-term — monetary considera-
tions. The long term situation is far more difficult to grasp: how
does one go about evaluating an aspect such as the expected
economic benefits of falling mortality connected with fuel pollu-
tion at sea? (16)

Lastly, debates around social

5.18
issues use concepts that
are sometimes only loosely defined. For example, an indicator
on flexicurity would be formulated differently in different coun-
tries, or depending on whether it is based on existing experience
or a desire to bring the concept into discussions at European (17)
or national level with reference to ‘national’ models developed
in a particular context and difficult to transpose into other
social settings. Which factors should be taken into account and,
most
importantly, what values, either positive or negative,
should be attributed to them? For, ‘the inclusion or exclusion of
particular indicators may reveal
implicit values and ideolo-
gies.’ (18) The problem is magnified still further when it comes
to the construction of composite indicators: which indicators
should be included, what coefficient should be ascribed to each
of them and what is the actual meaning of the composite indi-
cator obtained?

(15) For example, the impact study for the CAP reform of the Banana CMO
demonstrates that the equivalent of tens of thousands of full time jobs
will be irremediably lost with no alternative employment possibilities
in the EU's ultra-peripheral producer regions where unemployment
levels are already high. Despite the enormous social cost,
it was
decided to proceed with reform of the CMO, on the orders of the
WTO.

(16) See the impact study on this subject, which attempts to put a figure on
the monetary value of the lives saved and illness avoided. A more
recent impact study (for the draft ‘pesticides’ directive) makes no such
attempt.

(17) Green Paper: Modernising Labour Law.
(18) Ekos Research Associates Inc. ‘The use of social indicators as evalua-
the Canadian

tion instruments’, 1998 (report drawn up for
Government.

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5.19
Composite indicators can integrate both qualitative and
quantitative dimensions, can be disaggregated by age, gender
and other significant criteria, but must also remain easily
comprehensible. To take one example, how could we go about
designing an indicator for quality of life in Europe? We could
include aspects such as income, life expectancy, perceptions of
the efficacy of the health system, pensions, average educational
attainment and perceptions of satisfaction with work. But we
could also include the unemployment rate, underemployment or
housing conditions. And what weight should be accorded to
each factor?

5.20
As we can see, the construction of indicators is not a
purely technical question. It is closely bound up with a system
of shared values or living traditions in a given society. It requires
consultation with social organisations and ultimately reflects a
particular ideological and political standpoint. At the current
time ‘few social
indicator approaches actually include societal
goals, which are a reflection of social values and standards
against which performance may be gauged (…) A crucial
this approach is the identification and ranking,
element of
through consultation and consensus-building, of
(…) bench-
marks in a number of social areas. Outcomes and inputs, as
well as the links between them, are also decided in this process
(…). In other words, for social indicators to be policy drivers,
process must be part of the product’.
(EKOS Inc. Associates
1998: p. 18).

Another issue which arises is the choice of the subject
5.21
of statistical analysis: i.e. individuals, communities or the house-
hold, as the basic economic and social unit. Likewise, there is
the issue of gathering data on particular ethnic groups, which
poses problems with regard to the requirement for non-discri-
mination, but would also be a useful means of determining the
nature and scale of discrimination, with a view to proposing
policies for reducing and ultimately eradicating it in the longer
term.

5.22
The selection of statistics and construction of indicators
can be conducted with a view to evaluating an existing policy or
with a view to exploring the various options available at an
earlier stage. In the latter instance, a broader range of statistical
data would probably be needed in order to determine a policy's
objectives and the means of attaining them, and could then be
narrowed down, once the most relevant statistics and indicators
were identified. However,
selection is also
closely bound up with empirical issues. It is not an exact science
and the same statistical data, which include both economic and
non-economic data, can be interpreted in many different ways.

the process of

— general context indicators:

income per capita,
age-dependency ratio, fertility rates, foreigners and foreign-
born population, marriage and divorce;

i.e. national

— self-sufficiency

indicators:

employment, unemployment,
jobless households, working mothers, out-of-work benefits,
benefits of last resort, educational attainment, age at retire-
ment, youth inactivity, students with impairments;

— equity indicators: poverty, income inequality, child poverty,
income of older people, public social spending, private
spending, old-age pension
social
replacement rate, pension promise;

spending,

social

total

— health indicators: life expectancy, health-adjusted life expec-
tancy, infant mortality, total health-care expenditure, long-
term care;

— social cohesion indicators: subjective well-being, social isola-
teenage births, drug use and

tion, group membership,
related deaths, suicides.

5.24

Eurostat uses the following social indicators:

— structural indicators:

— employment: employment

rate, employment

rate of
older workers, average age when leaving the labour
market, gender pay gap, tax rate on low wage-earners,
tax wedge on labour costs, the unemployment trap, the
low pay trap, continuing education, accidents at work
(serious or mortal), unemployment rate (total or by sex);

— social cohesion:

inequality of incomes distribution, at-
risk-of-poverty rate,
at-persistent-risk-of-poverty rate,
dispersion of regional employment rates, early school-
long-term unemployment rates, population in
leavers,
jobless households;

— sustainable development:

— poverty and social exclusion: at-risk-of-poverty rate after
social transfers, monetary poverty, access to the labour
market, other aspects of social exclusion;

— ageing society, old-age dependency ratio, adequacy of
stability of public

change,

pensions, demographic
finances;

— public health: number of healthy years from birth by
gender, protection of human health and lifestyles, food
safety and quality, management of chemicals, environ-
mental health risks;

— labour market:

5.23
For example, for each of the social indicators used in
‘Society at a Glance: OECD Social Indicators — 2005 Edition’
(see short bibliography), the OECD collected raw data on:

— harmonised unemployment;

— labour costs index.

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5.25
To what extent can this (non-exhaustive) list of indica-
tors be successfully integrated into the general objectives of the
Open Method of Coordination (OMC) of March 2006:

1) It should be possible to justify each individual

indicator
through reference to an analysis of the complex phenomena
that it is supposed to summarise.

— promote social cohesion, equality between men and women
and equal opportunities for all by means of appropriate
social protection systems and social inclusion policies that
are accessible, financially viable, adaptable and effective;

— interact efficiently and mutually with the Lisbon objectives
aiming to stimulate economic growth, improve the quality
and quantity of jobs and strengthen social cohesion; and
with the European Union's sustainable development strategy;

— improve governance, transparency and stakeholder participa-
tion in policy framing, implementation and monitoring.

Furthermore,

the concepts and methods used for
5.26
In the case of
certain indicators need to be more precise.
poverty,
for Employment,
Income and Social Inclusion (Conseil de l'emploi, des revenus et de
la cohésion sociale — CERC) (19) has highlighted the ‘multidimen-
sionality’ of the concept.

the French Council

for example,

Thus, poverty comprises several dimensions:

inade-
5.26.1
quate monetary resources, poor living conditions,
inadequate
cognitive, social and cultural resources. For each of these dimen-
sions, two approaches are adopted to determine the poverty
situation:

— The first consists in defining minimum needs ‘absolutely’.
Persons whose minimum needs are not met are defined as
poor.

— The second approach defines poverty relatively. This was the
approach adopted by the European Council in 1984 when it
gave a definition of poverty for EU statistics work. People
are poor when their income and resources (material, cultural
and social) are so inadequate as to prevent
them from
enjoying living conditions that are considered acceptable in
the Member State in which they live.

In summary and in conclusion, the social

indicators
5.27
aim to draw the attention of public opinion and decision-
makers to social
issues which risk being underestimated or
poorly understood. Focusing the attention of decision-makers
on the key points is particularly important as they generally
have to deal with too much information. Herbert Simon put it
nicely when he said that
too much information kills the
information.

2) Similarly, indicators need to have ‘expressive’ qualities, i.e. be
able to cogently represent and evoke reality. In this respect,
value of
to the
some observers
indicators.

‘metaphorical’

refer

3) In view of their purpose (to draw the attention of policy-
makers and public opinion to the most important issues and
trends, with a view to influencing policies), the most useful
indicators relate to values whose variations can be given an
unequivocal value (positive or negative). This is what we
mean by ‘normative clarity’. A counterexample can be
provided by the increase in part-time work, which is not
unanimously regarded as a positive phenomenon, unless it is
chosen by the worker. This criterion of clarity can lead to a
number of indicators that are less relevant here, for example,
relating to lifestyles or to cultural trends (clothes, musical
tastes, etc.) being kept out of the scoreboards, even though
they have an impact on the organisation of work and the
economy.

the choice of

4) From a practical point of view,

indicators
should be warranted by their function. They are,
in fact,
more or less tailored to the three following types of use:
international or inter-regional comparisons;
intertemporal
comparisons; monitoring and evaluation of public interven-
tion/quality and performance of public services.

5) Finally, indicators need to be divided into categories and sub-
categories within a structured framework that can be readily
to distinguish
understood.
is particularly important
between context, method and result
indicators, objective
indicators and subjective indicators.

It

5.29

In practice, the features of an indicator are:

— Clarity: an indicator is only useful if there is no ambiguity as
to the nature of the phenomenon that it reflects (traditional
counterexample: data on crime and offences are a reflection
both of crime trends and of police force activity).

— Representativeness: an indicator is particularly useful

if it
can validly summarise a wide range of phenomena in a
single figure.

5.27.1
system of
information’.

From a functional point of view, the purpose of a
indicators is to achieve ‘optimum aggregation of

— Normative clarity (see above).

5.28

An indicator is more than a statistic:

— Reliability, regularity: the information needed for the indi-
cator must be provided regularly, by means of reliable
surveys.

A system of indicators is not a mere collection of data. It has a
number of consequences:

(19) http://www.cerc.gouv.fr.

— Comparability in time and/or in space (between countries,
regions, etc.): comparability is closely linked to clarity and
reliability.

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Official Journal of the European Union

C 175/27

5.30

Features of a parameters system:

— Completeness:

the main features of

the phenomenon

observed must be taken into account.

— Balance: the number and status of the indicators devoted to
each topic must reflect its relative importance. No single
feature can receive undue attention to the detriment of
others.

— Selectivity and/or hierarchy: indicators must be confined to

just a few or clearly arranged hierarchically.

the social

6.
The EESC calls for the evaluation of the social impact of
EU legislative and policy initiatives to be incorporated in all
policy areas. In other words, the Commission should carefully
assess
relative initiatives without
worrying about which DG is in charge of the initiative. This is
important if Europe genuinely wants to create a ‘social Europe’
and gain public support. The ‘better lawmaking’ initiative offers
a suitable springboard to push ahead in this direction.

impact of all

6.1
This assessment should examine individually specific
groups which might be affected in different ways by the new
legislation. Special attention should be paid to disadvantaged
groups such as women, disabled persons and ethnic minorities.
In some cases, depending on the subject matter of the initiative
concerned, it might even be necessary to examine specific sub-
groups individually, such as blind persons, for example.

7. Conclusion

7.1 What emerges from the above and from the public
hearing organised by the European Economic and Social
Committee on 28 March 2007, is that the multi-dimensionality
of certain concepts makes it impossible to develop a social indi-
cator based on a single criterion. By its very nature, the debate
on social
issues brings into play concepts whose edges are
blurred and necessarily vary from one country or one social
reality to another. Furthermore, the inclusion or exclusion of
particular indicators reveals implicit or explicit ideologies or
values. The selection of indicators is closely bound up with
empirical issues, and this should, in principle, stand in the way
of a rigid approach.

Although it is laudable and necessary,

7.2
if not vital, to
draw the attention of political decision- makers to the social
impact of proposed legislation,
there is a methodological
problem here, since ‘too much information kills the informa-
tion’. The European Economic and Social Committee considers
that particular emphasis should be placed on the methodology,
which has yet to be determined.

Brussels, 31 May 2007.

7.3
Therefore, the European Economic and Social Committee
considers that, at this stage of the reflection process, it is vital to
draw the attention of the Commission, and other players, to the
quality standards that must be met by all indicators, namely:

— clarity,

— representativeness,

— normative clarity

— reliability and regularity, not

forgetting comparability in
time and/or in space and not forgetting that the quality of a
system of indicators ultimately rests on a need for complete-
ness, balance and selectivity and/or hierarchy.

7.4
The European Economic and Social Committee also calls
on the Commission to incorporate the evaluation of the social
impact of EU legislative and policy initiatives in all Community
policies, without having to worry about which DG is responsible
for deciding whether a social impact analysis needs to be carried
out. This is vital if we genuinely want to create a ‘social Europe’
and gain public support.

7.5
The Committee should take full account of the road map
and impact assessment alongside the legislative proposal referred
to it for an opinion and should begin its work immediately, as
soon as
the communication accompanying the legislative
proposal has been published.

It is vital to conduct regular assessments of all legislation
7.6
for which prior impact assessments were conducted and, where
necessary, to make adjustments to the way the legislation is
implemented and to involve the social partners and, if necessary,
stakeholder NGOs in this process. This is important in order to
verify the validity of the indicators that were used, to combine
them in the social impact assessment and draw lessons or, if
need be, persuade the legislator to look into possible changes.

7.7
In certain specific and highly socially sensitive cases
(such as labour law), consultations with the social partners
should take place at a still earlier stage, so as to identify the
most appropriate indicators for conducting as comprehensive
and objective an impact analysis as possible.

There is no doubt that the ‘Better lawmaking’ initiative
7.8
offers a suitable springboard for pushing ahead in this direction,
i.e. proposing vital and effective legislation, whose consequences
are both predictable and stable for its addressees and more
closely incorporated in the impact analysis and evaluation
process conducted by the EU's consultative bodies (the EESC
and the CoR) and, depending on the nature of the legislation,
by the social partners and the relevant NGOs in the area
concerned.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS