Opinion of the Committee of the Regions on the Community strategy 2007-2012 on health and safety at work
Date: 2007-11-28
Institutions: European Committee of the Regions
Subjects: European Employment Strategy, development policy, humanisation of work, occupational health, occupational safety, productivity

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Official Journal of the European Union

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Opinion of the Committee of the Regions on the ‘Community strategy 2007-2012 on health and
safety at work’

(2008/C 53/03)

THE COMMITTEE OF THE REGIONS

— believes that Member States need this strategy paper as a core document on which to draw as they
develop their own strategic development plans to improve health and safety at work; such plans have
major implications both for local and regional authorities and for larger businesses and SMEs alike;

— stresses that regional and local authorities are major employers in all EU Member States and are
well-placed to spearhead health and safety initiatives. Therefore the European Commission should,
when carrying out the strategy, pay special attention to local and regional authorities;

— shares the Commission's view that, under the Lisbon strategy, the Member States have acknowledged
the major contribution that guaranteeing quality and productivity at work can play in promoting
economic growth and employment. Indeed, the lack of effective protection to ensure health and safety
at work can result in absenteeism, in the wake of workplace accidents and occupational illnesses, and
can lead to permanent occupational disability. This is not only a human tragedy for the people
concerned, but also has a major negative impact on the economy. The enormous economic costs of
problems associated with health and safety at work inhibits economic growth and affects the competi-
tiveness of businesses in the EU;

— considers that the Community and the Member States should, as a matter of urgency, have access to
the latest reliable statistics and to a data collection and processing system that provides a true over-
view of the extent of occupational accidents and diseases.; And, in this sense, recommends to start
working in order to harmonize statistics of labour accidents and professional illnesses in the European
Union.

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Rapporteur: Uno SILBERG (EE/UEN-EA), Chairman of Kose Municipality Council

Reference document

Communication from the Commission to the Council, the European Parliament, the European Economic
and Social Committee and the Committee of the Regions — Improving quality and productivity at work:
Community strategy 2007-2012 on health and safety at work

COM(2007) 62 final

Political recommendations

THE COMMITTEE OF THE REGIONS

General comments

1.
welcomes the European Commission's initiative to press
ahead with efforts to improve quality and productivity at work
and to devise a Community strategy on health and safety at
work for the 2007-2012 period. This initiative seeks to secure a
25 % reduction in accidents at work by 2012 in EU-27 by
improving health and safety protection for workers. It would
also make a major contribution to the success of the Growth
and Jobs strategy;

2.
believes that Member States need this strategy paper as a
core document on which to draw as they develop their own
strategic development plans to improve health and safety at
work; such plans have major implications both for local and
regional authorities and for larger businesses and SMEs alike;

stresses that

3.
regional and local authorities are major
employers in all EU Member States and are well-placed to spear-
head health and safety initiatives. Therefore the European
Commission should, when carrying out the strategy, pay special
attention to local and regional authorities;

shares the Commission's view that, under

the Lisbon
4.
the Member States have acknowledged the major
strategy,
contribution that guaranteeing quality and productivity at work
can play in promoting economic growth and employment.
Indeed, the lack of effective protection to ensure health and
safety at work can result in absenteeism, in the wake of work-
illnesses, and can lead to
place accidents and occupational
permanent occupational disability. This is not only a human
tragedy for the people concerned, but also has a major negative
impact on the economy. The enormous economic costs of
problems associated with health and safety at work inhibits
economic growth and affects the competitiveness of businesses
in the EU;

urges the Commission to pool the political synergies that
5.
exist between the individual EU institutions, the Member States
and above all the local and regional authorities in a bid to
improve health and safety at work;

6.
considers that the Community and the Member States
should, as a matter of urgency, have access to the latest reliable
statistics and to a data collection and processing system that
provides a true overview of the extent of occupational accidents
and diseases. And, in this sense, recommends to start working
in order to harmonize statistics of labour accidents and profes-
sional illnesses in the European Union;

7.
feels that Member States must draw on a national strategy,
based on the Commission strategy, to foster a safe working
environment, covering issues of employment, employment rela-
tionships and conditions at the workplace;

8.
considers that an effective insurance scheme must be avail-
able to Member States to cover workplace accidents and occupa-
tional
illnesses. This would provide an incentive not only to
increase safety at the workplace but also to keep a record of all
workplace accidents and cases of occupational illness;

would stress the need to give sufficient attention to
9.
prevention measures in the context of risk management and to
ensure that prevention is not seen as part of monitoring. Risk
management comprises both prevention (proactive risk manage-
ment) and a ‘fire brigade strategy’ (reactive risk management),
both of which must be given equal importance;

10.
takes due note of Commission's assertion that this is a
strategy for health and safety at work for the 2007 to 2012
period. The communication must therefore be deemed to be a
strategy document;

Devising a strategic development plan

is pleased that a strategic development plan (strategy

11.
document) is being drawn up in line with Community rules;

12.
notes a discrepancy in point 5 between the section on
health surveillance (using certain procedures) and that dealing
with social and demographic change (generational aspects).
Moreover, the section on the rehabilitation of workers uses very
old data (from 1999) which are hardly likely to be of any
relevance for a strategy covering the period up to 2012. The
2002-2006 strategy should — at least — be taken as a base;

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Remit, vision and underlying values

is surprised that the strategy document gives no real indi-
13.
cation of its remit and vision. In terms of targeted Community
action, therefore, the document lacks any common approach or
purpose. It also fails to state its precise objective or what kind
of action is supposed to be taken for which target group. Nor is
it wholly clear about what a resolution of the issue is meant to
achieve;

focus,

customer

orientation,
leadership and constancy of
purpose, management by processes and facts, people develop-
ment and involvement, partnership development and corporate
social responsibility — thus encouraging advances in the area of
health and safety at work and fostering progress in harmonising
the legal framework involved. The Member States should also
seek to show understanding for the aspirations of the various
interest groups within society and to respond appropriately;

considers it important

14.
to give expression to Member
States' shared values, which form the basis of joint action and
underpin moves to achieve the objectives at hand;

Appraisal of the current situation

Points of departure for the strategic development plan

notes that, according to the document,

15.
the strategic
development plan is designed to cover the period 2007-2012.
Thus there is some indication of the timeframe involved in
pursuing the objectives and measures set out in the develop-
ment plan, but this is not tied the attainment of any specific
targets;

16.
feels that the document should indicate how often —
and how thoroughly — the plans are to revised (plans left unre-
vised for, say, three years risk becoming obsolete);

17.
welcomes with satisfaction the high participation of
Member States in drawing up the strategic development plan.
However, regrets that the participation of
local and regional
authorities in drawing up the strategy has not been facilitated,
although proximity to citizens is needed in this process. In this
sense, regional and local entities are not only employers but also
they may be agents responsible for implementing these policies;

that

urges

18.
the European
Commission's 2002-2006 Community strategy on health and
safety at work continue to be pursued;

the strategic direction of

recognises the earlier strategy's success in raising public
19.
awareness of
the importance of health and safety at work,
which was highlighted as an integral part of quality manage-
ment and a critical factor in economic performance and compe-
titiveness;

20.
is surprised at the strategy paper's failure to bring quality
management into the discussion of health and safety at work, or
indeed to take up the issue at all;

notes that

21.
that many businesses in the EU Member
States, including leading European enterprises, have introduced
the EFQM system (European Foundation for Quality Manage-
ment) as a basis for their activities. All Member States should be
made aware of this system as a model for an effective strategy
that may also be used in the field of health and safety at work;

it

considers that

23.
the
is essential
current situation to have available statistical data in respect of
the individual EU Member States or general data for the EU as a
whole; such data should be time-related,
in order to make it
possible to recognise the trend;

for an appraisal of

24.
stresses that the appraisal of the current situation should
include an analysis of the available results and current problems,
possibilities and risks, broken down by area;

points out that, by their very nature, the dangers and
25.
risks have become more complex and inter-dependent.
It is
therefore essential to carry out a risk analysis in order to make
the possible dangers and to carry out risk
an appraisal of
management, taking account of the various types of risks. It is
very important to carry out a critical appraisal of the current
situation as this is the only way in which it will be possible to
set realistic targets;

takes the view that, if we are to make a realistic appraisal
26.
of conceivable damage arising from potential risks,
it is very
important not merely to bring about an awareness of sources of
danger and their overall impact; it is also essential to define the
criteria for assessing the damage. When making the assessment
of damage, distinctions should be drawn between the technolo-
gical, psychological, sociological, cultural and economic aspects
of the risks involved;

emphasises that

27.
the Member States should determine
precisely how information is to be gathered and compiled,
which parties are to be responsible for these measures and what
procedures are to be followed. These elements are frequently
not determined by declaratory legal provisions; in the absence
of a theoretical and practical basis which is readily understand-
able to all parties, no positive outcome can, however, be
expected;

28.
considers that there is an urgent need for the Member
States to have at their disposal a sound methodological basis for
risk management, which should, moreover, be drawn up in
accordance with scientific principles;

22.
urges Member States to take on board the fundamental
concepts of the EFQM quality management system — results

29.
points out that it is necessary to continually monitor
conditions and risk factors so as to keep up to date and define
any new risk factors that should emerge;

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30.
illnesses
takes the view that the issue of occupational
should be addressed in greater detail in the strategy document.
An approach based on adequate degree of flexibility and clarity
should be pursued when determining the criteria for analysing
occupational illnesses so as to enable such illnesses to be classi-
fied by taking account of their original causes;

points out that the strategic objective must be in line
40.
with the following (SMART) requirements:
it must be specific,
measurable, agreed, realistic and timed. These qualities ensure that
the task in hand is clearly formulated and numerically measur-
able, which presupposes that the scales of measurement will be
contractual obligations;

regards it as vitally important that the diagnosis of occu-
31.
pational illnesses in the Member States should not be rendered
more difficult and that the payment of compensation should
take place in the most unbureaucratic way possible;

32.
also regards it as vitally important that there should be
an effective legal and administrative system which ensures that
occupational accident and illness is recorded but should not in
particular over-burden SMEs;

33.
calls for occupational accidents and illnesses to be accu-
rately recorded in all Member States and for a strategic action
plan to be introduced to improve safety at the workplace, such
measures should not over-burden SMEs;

34.
regards as essential that the fulfilment of requirements
and rules in respect of the working environment should be
monitored in order to reveal any shortcomings and to prevent
risks;

35.
recognises that shortcomings in organising the way the
working environment is managed are one of the key causes of
occupational accidents and illnesses. Every human life which is
lost and every working day lost through sickness represents a
considerable loss for every Member State, regional or local
authority, business and small- and medium-sized enterprises
(SMEs); the overall costs to society are, however, very much
higher;

36.
regrets the absence of any explicit reference to the fact
that healthy behaviour patterns can basically only emerge where
underlying conditions at the workplace and in society are them-
selves healthy and salubrious;

37.
wishes to see standard, generally recognised methods of
analysis, such as SWOT, PEST, GAP, FFA or CAF, used when a
common strategic approach is formulated in the organisations
of the various Member States and in order to ensure objective,
adequate and comparable results;

Strategic objectives

welcomes the Commission's proposal under which the
38.
main goal of EU strategy is to continue to be the ongoing,
steady reduction in the number of industrial accidents in the
period 2007-2012; it shares the Commission's view that, during
the period
the
27 EU Member States should be to bring about a 25 % reduc-
tion in the number of industrial accidents and the incidence of
occupational illnesses, even though such a goal may appear to
be too much of a ‘eye-catching’ objective;

the overall objective of

in question,

39.
notes that there must be a clear message behind these
strategic objectives. The ultimate objective, i.e. what has to be
achieved by which date, has to be clearly spelled out;

draws attention to the fact that the strategic objective
41.
must be in line with what is required, i.e. the goals will have to
be linked to a specific timetable, so as to ensure that their
achievement can be monitored and measured. Hence the
concept of setting short- and long-term objectives which would
clearly mean that the main objective would have to be subdi-
vided into smaller intermediate objectives so that their realisa-
tion could be measured, monitored and managed more
precisely;

indicators for

considers that there is an urgent need to establish a
42.
system of
the Member States which would
provide the basis for the appraisal of the initial situation and the
target situation and the efficiency of the measures taken. The
main defining features of such indicators should be relevance,
substantiveness, quantifiability, robust nature and the efficiency
of the expenditure involved;

Measures for achieving the objectives

43.
welcomes the fact that the Commission is supporting
SMEs by making use of existing legal provisions; would like to
see the legislative framework brought into line with the develop-
ment of the labour market and simplified, above all, bearing in
mind the situation of SMEs;

stresses that instruments should be defined in support of
44.
the measures set out in the strategic development plan. Such
instruments would cover programmes, larger projects, strategic
investments and other broader fields of action, such as routine
tasks, designed to help achieve the objectives which have been
set;

notes that,

the strategy document)

45.
in contrast to the way in which the other
issues are treated, the question of the establishment of a legisla-
is
tive framework (chapter 4 of
addressed in too great detail. The various aspects of business life
should be systematically scrutinised on the basis of,
for
example, the PESTLE principle (political, economic, social, technical,
legal, environmental). The examination should be carried out not
just in the overall framework of the EU but also in the context
of the individual Member States; it should cover the fields of
politics, the economy, social questions, technological aspects,
legal aspects and protection of employees;

46.
advocates support
health promotion schemes;

for the establishment of corporate

Financial framework and timetable

47.
draws attention to the fact that it is absolutely essential
for the strategy document to include a financial framework and
a timetable, setting out the estimated overall cost of the develop-
ment plan and the allocation of costs in respect of particular
years or other periods of time;

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48.
would like to see the section dealing with the planning
and implementation of measures to reduce safety hazards and
to provide protection at the workplace, make provision for the
use of a standard form with regard to the financial framework
and the timetable,
in order to ensure that data provided by
Member States is comparable and can be analysed generally
throughout the EU;

Management structure

49.
points out that the management structure for ensuring
safety and health protection at the workplace should include a
description of the necessary coordination processes with regard
to the drawing up, completion, implementation and appraisal of
the development plan and the writing of the final report on the
plan. It is essential to indicate in this context how cooperation,
work-distribution and feedback processes involving the stake-
holders are organised;

50.
draws attention to the fact that it is essential to define
the management structure for ensuring safety and health protec-
tion at the workplace if agreement is to be reached on the coor-
dination, administration and other relevant aspects of the devel-
opment plan for the respective areas and if other interested
parties are to be kept informed;

51.
draws attention to the International Labour Organisa-
tion's global Guidelines on occupational safety and health
management systems (ILO-OSH) which, given the refusal to
accept the setting of international standards in this area, were
drawn up at the request of the International Organisation for
Standardisation (ISO) to be implemented — as has to some
extent already happened — by the relevant countries at national
level; these guidelines reflect ILO values and tools relating to
occupational health and safety management and lay down the
basic requirements of an occupational safety and health manage-
ment system designed to secure long-term improvements on
this front;

points out

52.
basic principles are set out in the following documents:

the abovementioned methodological

that

— Guidelines on occupational safety and health management systems,

ILO-OSH 2001;

53.
stresses that any long-term effective system of heath and
safety management designed to secure ongoing improvements
in health and safety at the workplace must contain the following
key elements:

— occupational safety and health policy;

— organising;

— planning and implementation;

— evaluation;

— action for improvement;

Brussels, 28 November 2007.

Implementation: report on the implementation, completion and conclu-
sion of the strategic development plan

points out that the section dealing with the structure of
54.
the strategic development plan should tie in with the goals to be
achieved and the measures to be implemented in the course of
the duration of the action plan and the explanations. The action
plan and the development plan must be comparable and have a
matching structure;

55.
recommends that the action plan be drawn up in tabular
form, indicating, in respect of each subgroup, (a) the respective
objectives, indicators and the measures which need to be taken
to achieve the targets and (b) the activities to be carried out
together with the implementing parties, the financial backers
and the funding sources and instruments;

56.
points out that supplementary measures should be intro-
duced should it become apparent, in the course of the imple-
mentation of the strategic development plan, that changes need
to be made or rules need to be laid down in respect of the
existing objectives and measures. When decisions are taken
regarding additional measures or the termination of existing
measures, account should be taken, above all, of the following:
the usefulness of the goals which have been set, the effectiveness
of the measures adopted and changes which have been carried
out or which are at the planning stage in respect of financing
and fields of action;

Appraisal of the implementation of the strategic development plan

57.
notes that when the objectives have been achieved, when
the strategic development plan reaches the end of its duration
or when it has been successfully implemented, a final report is
to be drawn up on the development plan;

points out that it

is essential to stress the following
58.
aspects in the section on the Member States dealing with the
reporting period:

— the parameters on which the indicators in respect of the
to which

strategic objectives are based,
progress has been made in achieving the objectives;

the extent

i.e.

— the direct results of the measures;

— a summary of the instruments used in connection with the
together with

the development plan,

implementation of
explanations;

— changes — either already carried out or in the planning

stage — in the respective field of activity.

The layout and structure of the report on the implementation of
the strategic development plan should match that of the devel-
opment plan and the associated action plan.

The President

of the Committee of the Regions

Michel DELEBARRE