Report from the Commission to the Council, the European Parliament, the European Economic and Social Committee and the Committee of the Regions on the practical implementation of Health and Safety at Work Directives 93/103/EC (fishing vessels) and 92/29/EEC (medical treatment on board vessels)
Date: 2009-10-29
Institutions: European Commission
Subjects: application of EU law, crew, fishing vessel, labour inspectorate, occupational health, occupational safety, report, working conditions

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 29.10.2009 
COM(2009)599 final 

REPORT FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN 
PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND 
THE COMMITTEE OF THE REGIONS 

on the practical implementation of Health and Safety at Work Directives 93/103/EC 
(fishing vessels) and 92/29/EEC (medical treatment on board vessels) 

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REPORT FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN 
PARLIAMENT, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND 
THE COMMITTEE OF THE REGIONS 

on the practical implementation of Health and Safety at Work Directives 93/103/EC 
(fishing vessels) and 92/29/EEC (medical treatment on board vessels) 

1. 

INTRODUCTION 

This  Report  follows  up  a  Commission  undertaking,1  to  assess  the  implementation  of  the 
regulatory  framework  with  a  view  to  improving  it.  It  focuses  on  the  transposition  and 
application of the  two  Council Directives 93/103/EC  of 23  November  1993,  concerning  the 
minimum safety and health requirements for work on board fishing vessels,2 and 92/29/EEC 
of  31  March  1992,  on  the  minimum  safety  and  health  requirements  for  improved  medical 
treatment on board vessels3. 

This  Report  is  concerned  solely  with  those  two  Directives  and  with  the  situation  in  EU-15, 
although  the  Commission  believes  that  it  will  yield  useful  information  for  the  twelve  new 
Member States too. It does not address aspects dealt with in international instruments4.  

It  is  based  mainly  on  national  reports  supplied  by  the  Member  States5  and  a  report  by 
independent  experts  evaluating  the  practical  implementation  of  the  two  Directives  on  the 
ground, including case studies conducted in Spain, France, Italy and the UK. Other sources of 
information are European statistics on accidents at work and the Commission’s experience in 
monitoring the transposition and application of the Directives. 

2. 

LEGAL EFFECTS 

2.1. 

Directive 93/103/EC 

Prior to the adoption of the Directive, the majority of the Member States already had legislation 
in  place  specifically  governing  health  and  safety  on  board  fishing  vessels.  Certain  Member 
States have reported that the Directive did not require major changes to their legislation. Others 
take  the  view  that  the  Directive  has  enabled  them  to  introduce  a coherent body of minimum 
safety and health rules specifically applying to work on board fishing vessels.  

1 

2 
3 
4 

5 

In the Communication Improving quality and productivity at work: Community strategy 2007-2012 on 
health and safety at work, COM(2007) 62 final of 21.2.2007. 
OJ L 307, 13.12.1993, p. 1. 
OJ L 113, 30.4.1992, p. 19. 
E.g.  the  International  Convention  for  the  Safety  of  Life  at  Sea  (SOLAS),  the  Maritime  Labour 
Convention  and  the  Work  in  Fishing  Convention.  Neither  does  the  report  cover  Council  Directive 
2009/13/EC of 16 February 2009 implementing the Agreement concluded by the European Community 
Shipowners’  Associations  (ECSA)  and  the  European  Transport  Workers’  Federation  (ETF)  on  the 
Maritime Labour Convention, 2006, and amending Directive 1999/63/EC (OJ L 124, 20.5.2009, p. 30). 
Sent to the Commission under Articles 13(3) and 9(3) of the two Directives (subsequently repealed by 
Directive 2007/30/EC). 

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However, in some Member States, where the existing rules had been in force for a long time, 
the  Directive  has  had  a  considerable  impact  on  legislation,  and  new  laws  have  had  to  be 
adopted.  The transposing legislation  has also  introduced certain  new fundamental principles 
of risk prevention, such as worker information, training and consultation and risk assessment.  

2.2. 

Directive 92/29/EEC  

Most Member States with a fishing and merchant fleet already had legislation setting a high 
level of requirements regarding the availability of medical supplies and medical assistance on 
board, and therefore the transposition of the Directive required only its revision and updating. 
In some Member States6, compulsory training in health issues on board was already regulated, 
and radio-consultation services were already in existence.  

3. 

AWARENESS-RAISING  AND  FLANKING  MEASURES  FOR  DIRECTIVES  93/103/EC  AND 
92/29/EEC 

After  the  two  Directives  were  adopted,  a  number  of  information  and  awareness-raising 
measures were set in motion at EU level. Thus, the European Agency for Safety and Health at 
Work7  launched  the  fisheries  web  feature  on  good  practice  in  the  fisheries  sector  covering 
such aspects as risk assessments for small fishing vessels8. 

At national level, the authorities, employers, workers and their organisations held information 
and awareness-raising campaigns, meetings, workshops and training sessions. Some Member 
States have drafted new guidelines — or have amended existing ones — e.g., on risk assessment 
and prevention, and safe working practice. The usual range of print media was used for publicity, 
with webpages supplementing the conventional media. 

Nonetheless,  activities  to  publicise  the  new  provisions  are  judged  inadequate  by  the  social 
partners in most Member States. Workers seem to have difficulty in accessing these provisions 
via  conventional  or  new  media9,  given  the  traditions  in  the  sector,  its  fragmentation,  the 
predominance  of  small  businesses  and  high  worker  turnover.  Rather  than  organising 
unconnected  activities,  some  Member  States10  have  implemented  sector-specific  prevention 
plans with a more closely defined and fully integrated strategy. Several Member States11 have 
also established funds to finance security measures on board vessels and protection equipment 
for fishermen. To a large extent, the fishing sector’s small numerical and economic scale in 
some Member States justifies or explains the lack of attention given to developing instruments 
to publicise the provisions. In other Member States with bigger fishing sectors, the authorities 
responsible  for  publicising  the  provisions  need  to  invest  more  resources  and  show  more 
commitment. 

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10 
11 

France, Spain, Finland, the Netherlands, Germany and Ireland. 
Council Regulation (EC) No 2062/94 (OJ L 216, 20.8.1994, p. 1) 
http://osha.europa.eu/en/good_practice/sector/fisheries/risk_assesment.php. 
As  demonstrated  by  the  French  case  study.  The  Spanish case  study  notes  resistance  to  improvements 
from outside, including awareness campaigns by the authorities. 
Such as Belgium and Finland. 
Belgium, Finland and France. 

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4. 

TRANSPOSITION 

Both  Directives  were  affected  by  delays  in  transposition,  and  infringement  procedures  were 
initiated against the Member States concerned12.  

4.1. 

Directive 93/103/EC  

The  main  compliance  problems  concerned  definitions,  the  owner’s  responsibility,  regular 
checks by the authorities, and worker information, training, consultation and participation. An 
infringement procedure was initiated against one Member State with regard to the definition 
of ‘owner’,  the obligations  to  report  occurrences  at  sea, to make  regular checks and  worker 
information, and the provisions on first-aid equipment in the Annexes.  

In some Member States, however, the legislation went further than the minimum requirements 
in  the  Directive,  e.g.  by  extending  its  scope  to  vessels  under  15  m  in  length  (the  UK  and 
Ireland)  and  making  its  provisions  applicable  to  new  or  refurbished  vessels  under  12  m  in 
length (Portugal). 

4.2. 

Directive 92/29/EEC 

The  Annexes  were  transposed  almost  verbatim  in  many  Member  States,  but  shortcomings 
remain  in  some.  An  infringement  procedure  was  initiated  against  one  Member  State 
concerning the need to ensure that every vessel flying its flag or registered under its plenary 
jurisdiction  always  carries  on  board  the  appropriate  medical  supplies.  The  case  was  closed 
after  the  Member  State  brought  its  national  provisions  into  line  with  the  Directive.  Another 
infringement  procedure  was  initiated  against  a  Member  State  concerning  the  definitions  of 
‘vessel’/‘fishing vessel’ and ‘owner’ in national law. 

Other  major  problems  of  compliance  concerned  training,  radio  consultation,  and  the 
confidentiality of medical data.  

An  additional  non-binding  EU  instrument  may  help  to  address  the  extremely  high  rate  of 
accidents  in  the  fishing  sector  and  the  fact  that  many  vessels  fall  outside  the  scope  of 
Directive 93/103/EC. The Commission, in close cooperation with the Advisory Committee on 
Safety and Health at Work13 (hereinafter 'the Advisory Committee'), therefore intends to draft 
a non-binding guide covering these small vessels and focusing primarily on good practice to 
improve prevention. 

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13 

Nine procedures for non-communication were initiated as regards Directive 92/29/EEC, one of which 
resulted in a judgment by the Court of Justice (Case C-410/97 Commission v Luxemburg [1998] ECR I-
6813)  and  nine  as  regards  Directive  93/103/EC,  two  of  which  resulted  in  judgments  by  the  Court  of 
Justice  (Case  C-364/97  Commission  v  Ireland  [1998]  ECR  I-6593  and  Case  C-362/98  Commission  v 
Italy [1999] ECR I-6299). 
Council Decision of 22 July 2003 setting up an Advisory Committee on Safety and Health at Work (OJ 
C 218, 13.9.2003, p. 1). 

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5. 

ACTION  IN  THE  FIELD:  THE  PRACTICAL  IMPLEMENTATION  OF 
DIRECTIVE 93/103/EC 

5.1. 

General issues 

Although  only  a  very  small  percentage  of  the  total  fishing  fleet  falls  within  the  scope  of 
Directive  93/103/EC14,  the  'Framework  Directive'15  including,  where  relevant,  its  individual 
Directives, applies to the whole sector.  

Assessing  the  practical  implementation  of  Directive  93/103/EC  is  compounded  by  big 
geographical differences, e.g. between fleets in the Mediterranean and the Atlantic: the former 
consist of smaller vessels that generally return to land every day or every few days, while the 
latter comprise larger vessels that are more profoundly affected by the Directive.  

Meanwhile,  social  and  economic  factors,  such  as  stiffer  competition,  dwindling  fish  stocks, 
and high fuel costs, are reducing the income of ship-owners, skippers/captains and workers, 
and piling on the pressure to catch as much fish as possible in the shortest time.  

As  a  result,  crews  have  been  reduced  to  a  minimum16,  working  hours  have  increased  and 
shifts are longer, although technological improvements may eliminate much of the drudgery. 
Smaller crews are under particular pressure at times of greater activity. A study conducted in 
Spain17 shows that fishermen see their job as exhausting rather than dangerous, while in the 
Netherlands it is estimated that one quarter of accidents that take place are not reported. These 
factors make it even more difficult to assess the impact of the new measures.  

Working  conditions  on  board  (pay,  time  spent  away  from  home,  long  working  hours,  etc.) 
discourage new recruits among the younger generation, which in turn makes the changeover 
to  a  prevention  culture  difficult,  at  least  in  the  short  run.  Overfishing  and  excess  of  fishing 
capacity  result  in  poor  economic  performance,  which  prevents  adequate  vessel  maintenance 
and operation, and pushes fishermen to take higher risks. 

From  the  viewpoint  of  the  ship-owners  and  skippers/captains,  the  new  provisions  bring  no 
direct  benefits,  and  the  involvement  of  the  labour  authorities  has  been  slight.  Only  a  few 
Member  States  seem  to  have  made  provision  for  financial  support  for  investing  in  safety 
equipment and crew training.  

While  the  Directive  has  put  more  emphasis  on  safety  in  the  sector  and  there  have  been 
improvements  in  safety  requirements  and  the  safety  training  of  crews,  the  impact  has  been 
limited because it applies only to larger vessels, which are fewer in number and where safety 

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17 

According  to  the  European  Parliament  report  Fisheries:  safety  and  causes  of  accidents  (12 March 
2001), the Directive is estimated to cover only 8 % of vessels operating. 
Council  Directive  89/391/EEC  of  12  June  1989  on  the  introduction  of  measures  to  encourage 
improvements in the safety and health of workers at work (OJ L 183, 29.6.1989, p. 1) 
The  French  case  study  describes  how  crew  size  has  fallen  from  nine  to  five  workers  in  vessels 
approximately 24 m in length. 
Penosidad  y  Riesgo  en  las  actividades  pesquera.  Las  condiciones  de  trabajo  y  de  salud  de  los 
trabajadores  de  la  pesca  en  Cantabria  (Harshness  and  Risk  in  fishing  activities.  Work  and  health 
conditions  in  fisheries  workers  in  Cantabria),  Labour  Asociados,  2003.  The  causes  of  exhaustion 
mentioned  are  physical  effort,  long  working  hours  and  the  need  to  adopt  uncomfortable  positions 
frequently. 

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conditions  are  better  anyway,  and  little  attention  has  been  paid  to  working  conditions  that 
might increase the risk of occupational diseases and unhealthy lifestyles. 

The  poor  state  of  some  fish  stocks  combined  with  an  excess  of  fishing  capacity  constitute 
incentives for vessel owners to maximise catching efficiency within the limitations defined by 
EU  law  and  Member  States’  regulations;  sometimes  this  is  done  at  the  expense  of  vessel 
safety and living conditions and working conditions on board.18 

5.2. 

Risk assessment 

Under  Article  1(2)  of  Directive  93/103/EC,  the  provisions  of  the  Framework  Directive  are 
fully applicable to vessels falling within the scope of Directive 93/103/EC. Article 9(1) of the 
Framework Directive stipulates that the employer must be in possession of a risk assessment. 
Risk  assessments  may  well  be  the  most  significant  legal  innovation  under  the  safety  and 
health  Directives,  but  they  are  hardly  ever  carried  out  in  respect  of  work  on  board  vessels. 
Where they are performed, they have been reported as encouraging discussion of risks, their 
consequences  and  preventive  measures.  Small  vessel  owners  are  reported  to  be  discouraged 
by the costs. 

Another  problem  is  that  a  simple  check-list  is  often  used  to  meet  the  risk  assessment 
requirement,  and  this  has  no  effect  on  working  conditions  on  board.  As  a  result,  fishermen 
lack expert advice on how to adopt safe procedures to avoid dangerous situations arising on 
board.  

5.3. 

Enforcement 

Article 3(2) of Directive 93/103/EC requires vessels to undergo regular checks by specifically 
empowered authorities.  

The implementation of the Directive has brought no change in the type or role of inspections 
in the fisheries sector19. Almost every Member State already had specific inspection systems 
to verify conditions of flotation, seaworthiness and capacity to cope with emergencies.  

In  most  Member  States  there  are  two  types  of  inspection.  The  first  is  technical:  inspections 
generally  performed  by  maritime  authorities,  who  have  long  experience  and  adequately 
trained  staff.  They  are  carried  out  while  the  ship  is  being  built  and  thereafter  periodically 
(generally  once  a  year),  to  renew  its  licence  and  allow  it  to  continue  sailing20.  The  second 
relates  to  work  organisation,  training  and  qualifications,  working  hours,  health  and  safety 
issues, living conditions on board, etc., which are the responsibility of the labour authorities. 
In  some  Member  States  there  is  also  a  third  type,  which  is  normally  a  health  inspection  to 
check the capacity of the vessel and of those in charge to attend to any medical emergencies at 
sea.  

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19 

20 

Described in the British case study. 
A  new  public  body  responsible  for  the  safety  of  fishermen  has  been  set  up  only  in  Ireland,  while  no 
significant  changes  have  been  made  to  the  existing  institutions  in  the  other  Member  States.  The 
independent experts’ report states that many parties, not only trade unions, consider labour inspection 
systems to be inadequate and barely qualified to oversee the health and safety of fishermen. 
The most common inspection method is the preparation of control lists on the vessel’s technical aspects 
rather than its suitability as a workplace. 

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As a result, in many Member States fishing vessels undergo inspections by two or even three 
authorities, sometimes with very little coordination. In general, priority seems to be given to 
conditions  of  stability,  flotation  and  safety  of  equipment,  while  living  conditions,  comfort, 
ergonomic  aspects,  risk  prevention  and  working  hours  of  fishermen  are  often  neglected, 
although the ‘human factor’ is acknowledged as the biggest factor contributing to accidents.  

The  coexistence  of  technical  and  labour  inspections  may  cause  confusion  amongst  ship-
owners,  skippers/captains  and  workers.  The  specialised  technical  competence  of  the  labour 
inspection  is  frequently  called  into  question,  especially  in  Member  States  with  general 
inspections, while in Member States with specialised inspections, the most frequent criticism 
concerns the lack of inspectors.  

It  would  seem  that  only  workers  or  their  representatives  are  in  a  position  to  make  effective 
checks  on  board,  which  is  an  unsatisfactory  situation  since  most  Member  States  lack  trade 
union representation in fisheries. This is generally due to the frequent changes in crew and the 
presence  of  both  self-employed  and  employed  workers,  in  addition  to  the  ‘shared-wage’ 
system,21  which,  given  the  crew’s  economic  interest  in  maximising  catches,  discourages 
workers  and  their  representatives  from  taking  any  initiative  that  may  reduce  time  at  sea  or 
increase costs. Under these conditions, it is difficult to foster a deep-seated safety culture.  

As  a  result,  technical  requirements  affecting  vessel  safety  are  checked  effectively  by  the 
technical  authorities,  but  checks  by  labour  authorities  seem  to  be  inadequate.  Nonetheless, 
some  Member  States  note  that  inspections  are  being  carried  out  more  frequently,  and 
according  to  the  Netherlands,  the  falling  national  accident  rates  are  probably  due  to  its 
systematic inspection system22.  

As  the  causes  of  the  frequent  accidents  on  board  are  not  properly  checked,  the  impact  of 
injuries and diseases resulting from fishing work is underestimated.  

In  some  Member  States,  according  to  the  independent  experts’  report,  the  division  of 
responsibility  between  national  and  regional  authorities,  labour  and  maritime  authorities 
makes inspections less efficient, though the difficulty of performing inspections under actual 
working conditions is the major practical problem: these are seldom carried out at sea, when 
the fishermen are actually working23. 

5.4. 

Information and training  

Articles 8 and 9 of the Directive concern information and training. Very few data have been 
collected to date on the issue of information for workers, but this area appears to be beset by 
the same problems as training24.  

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23 

24 

The traditional system of remuneration in the fishing industry is the sharing of the catch or a share of 
income less costs, or a share-plus-wage system (source: ILO: Fishermen’s conditions of work and life, 
Geneva,  Doc.  CFI/4/1988/1).  In  order  to  maximise  their  share  of  the  proceeds,  fishermen  tend  to 
operate with as few crew members as possible.  
Inspections  appear  no  less  strict  when  a  vessel  is  close  to  the  date  of  scrapping,  though 
skippers/captains are reportedly less inclined to make investments in safety in such cases. 
Inspections  at  sea  are  only  carried  out  on  ships  over  24  m,  as  smaller  vessels  seldom  notify  their 
intention of putting out to sea. 
The  Spanish  case  study  noted  that  engaging  an  outside  firm  failed  to  make  fishermen  more  aware  of 
their responsibility for their own and other persons' safety and health. 

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As  regards  training,  the  Member  States  mention  the  difficulty  of  accessing  fishermen  as  a 
body, given the little time that they spend on land and which is meant for rest25. This problem 
is aggravated when they work in distant fishing grounds — a factor which is not always taken 
into account — and by the sector’s structural problems (which are closely linked to the precarity 
of work, especially in SMEs working in such fishing grounds). 

The ‘shared-wage’ system referred to above is another obstacle to training, which must take 
place on land and therefore is not remunerated. Despite this, the Member States consider that 
the increase in training has been one of the most outstanding outcomes of the Directive. 

6. 

ACTION  IN  THE  FIELD:  THE  PRACTICAL  IMPLEMENTATION  OF 
DIRECTIVE 92/29/EEC  

6.1. 

General issues  

In general,  the  Directive has  been implemented as required, thanks  to the  broad measure of 
acceptance  among  professionals  and  their  cooperation  with  the  authorities,  as  well  as  to 
inspections  carried  out  by  the  latter.  This  has  been  facilitated  by  the  precise  drafting  of  the 
Annex to the Directive, which leaves no room for interpretation.  

Bearing  in  mind  the  difficulty  of  separating  out  the  impact  of  the  new  provisions  and  of 
identifying and obtaining reliable statistics, the general assessment is that medical treatment 
on board vessels has improved. Stakeholders have managed to incorporate the provisions into 
their  prevention  routines,  including  training  and  provision  and  maintenance  of  medical 
supplies and the survival kit.  

However,  there  is  a  difference  between  the  merchant  navy  and  fishing  fleets.  Whereas  the 
Directive  has  been  implemented  without  problem  in  the  merchant  navy,  the  requirement  to 
carry medical supplies has been more difficult to implement in the fishing fleet, and especially 
in small businesses.  

The  introduction  of  a  better  organised  system  for  providing  medical  advice  to  vessels  has 
been claimed as the Directive’s major outcome. Radio medical centres have also proved very 
effective: data are now available on the number of calls made by vessels, the most common 
types of injuries and the action taken. 

Training  programmes  have  in  most  Member  States  generated  growing  confidence  among 
workers as regards the responsibilites for health matters on board.  

The  fact  that  captains  often  prefer  not  to  administer  the  medicines  in  the  medicine  chest 
lessens  their  impact  on  the  medical  treatment  provided  on  board.  In  most  situations  doctors 
also  appear  to  prefer  to  evacuate  patients  rather  than  to  prescribe  medicines  available  on 
board. The carriage of medicines also seems to have had no major impact on economic costs, 
even if some Member States do mention these.  

The most critical assessments of the impact of the Directive come from trade union sources 
and relate to non-compliance as regards the theoretical and practical training for first-aid kit 

25 

The Spanish case study mentioned that the fishermen had received no specific training even from their 
trade union. 

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resources and the radio-consultation service, and the lack of resources for training workers in 
their use at sea. 

Special  difficulties  in  access  to  training  are  noted  among  self-employed  workers  and 
fishermen’s cooperatives, whose remuneration is closely dependent on the daily catch.  

6.2.  Medical supplies  

Article  2  of  the  Directive  stipulates  that  every  vessel  must  always  carry  on  board  medical 
supplies  appropriate  to  the  category  of  vessel  and  the  type  of  voyage,  work,  cargo  and  the 
number  of  workers.  Larger  vessels  making  a  voyage  of  more  than  three  days  must  have  a 
sick-bay,  and  vessels  with  a  crew  of  100  or  more  on  an  international  voyage  of  more  than 
three days must carry a doctor.  

Generally  speaking,  the  legislation  is  applied  and  medical  supplies  are  carried  on  board. 
However,  some  problems  persist,  in  particular  as  regards  the  contents  of  medicine  chests, 
which do not always correspond to all of the Directive’s requirements, and the replacement of 
drugs and medical supplies that have passed their expiry date. This would seem to be due in 
some cases to the inspectors not having the necessary specific training. 

The medical supplies situation seems to be better in large companies and on merchant ships, 
whereas  the  requirement  to  check  and  replace  supplies  is  not  carried  out  strictly  in  small 
companies and on fishing vessels. 

Self-employed fishermen find it hard to understand the legislation on medical supplies. 

Some  problems  have  been  observed  as  regards  narcotic  substances,  owing  to  the  lack  of 
awareness on the part of the suppliers.  

The need to replace the contents of medicine chests that have passed their expiry date should 
be  evaluated.  A  working  group  of  the  Advisory  Committee  could  be  set  up  to  assist  the 
Commission in this task. 

6.3. 

Allocation of responsibilities 

Article  4(1)  of  the  Directive  stipulates  a  division  of  responsibilities  for  the  provision  and 
replenishment of medical supplies between the owner and the captain or the person delegated. 

This division does not seem to be a problem. Responsibility for the provision and replacement 
of  medical  supplies,  on  the  one  hand,  and  for  their  management  and  maintenance,  on  the 
other,  is  properly  apportioned.  A  lack  of  clarity  is  mentioned  by  Spain,  which  reports  that 
responsibilities  are  divided  less  clearly  in  the  fishing  fleet  —  where  the  captain  and  ship-
owner is often the same person — than in the merchant navy. 

6.4. 

Training 

The  training  requirements  set  out  in  Article  5(2)  and  5(3)  of  the  Directive  raise  two  main 
questions:  first,  whether  or  not  basic  training  on  emergency  medical  treatment  is  sufficient 
and adequate and, secondly, whether or not the captain and officials attend refresher courses 
at least every five years.  

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The  situation  varies  according  to  the  Member  State  and  the  type  of  fleet.  In  some  Member 
States, basic training in the fishing industry is considered insufficient. The situation regarding 
refresher courses at five-yearly intervals also varies. In many Member States, training every 
five years is compulsory. In Finland, such training is a prerequisite for obtaining the book of 
compliance and be able to work as a maritime professional. In Germany, proof of attendance 
is compulsory for the renewal of a captain’s/officer’s certificate.  

Some  Member  States  have  compulsory  specialist  training  in  first  aid/medical  emergency 
treatment/basic  training  in  medical  emergency  assistance  for  all  persons  who  take  a 
professional  maritime  course,  and  captains  have  special  training  in  medical  emergency 
assistance.  However,  medical  emergency  assistance  training  is  sometimes  considered 
inadequate. Specific training for captains is sometimes lacking, e.g. in the use of syringes and 
giving  injections.  In  the  fisheries  sector,  the  smaller  the  fishing  vessel,  the  less  likely  the 
captain or any other crew member is to have undergone any medical training, or any training 
at all.  

6.5. 

Radio medical centres 

The Directive’s objective in Article 6 of establishing radio consultation centres with doctors 
specialised in living conditions on board has been satisfactorily attained, although pre-existing 
structures  have  been  used  in  some  Member  States.  In  Denmark,  numbers  evacuated  from 
vessels have fallen drastically since the radio medical services and the training of navigators 
and  radio  medical  doctors  were  centralised.  In  general,  these  centres  are  considered  to  be 
functioning adequately, with some weak points. 

The independent experts’ report shows that, in some Member States, no doctors or specialist 
medical personnel are employed in the radio medical centres and calls are handled by a doctor 
on duty who is not trained in the conditions on board vessels. In others, the doctors are trained 
to give treatment via radio to persons on board vessels, and there is always at least one doctor 
on duty to assist seafarers. 

The main weak point is not having a live picture of the patient, so the doctor has to rely on the 
captain’s description of the patient’s symptoms. The reliability of this information affects the 
reliability of the advice given by the doctor, with the result that more patients than necessary 
are likely to be evacuated. 

In Denmark successful trials with visual examinations via web-camera have been conducted. 
A weakness, however, is the lack of a permanent Internet connection on some ships and the 
cost of the equipment and Internet connection.  

Special virtual centres have been set up in Sweden, with doctors who have specific training 
for and knowledge of the conditions on board.  

Ship-to-shore  communication  technology  varies  enormously  from  simple  VHF  radio  to 
satellite telephone and e-mail. 

Emergency situations are also dealt with by air transport and Spain mentions the existence of 
hospital ships. 

6.6. 

Inspections 

Article 7 of the Directive covers annual inspections of medical supplies.  

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The problems mentioned under point 5.3 (Directive 93/103/EC) are equally applicable here. 

7. 

GENERAL ASSESSMENT  

7.1. 

The main positive effects of the two Directives 

7.1.1.  Directive 93/103/EC 

The Member States’ national reports generally noted no major negative or positive effects, in 
some cases due to equally strict previous regulations. The general deterioration in fishermen’s 
socio-economic circumstances over recent years has made it difficult to assess the situation. 
Improvements  were  found  to  be  the  indirect  result  of  measures  taken  to  improve  the  fleet 
rather than the result of attempts to improve working conditions on board. 

However,  the  Member  States  have  mentioned  the  following  among  the  positive  effects  of 
Directive 93/103/EC: 

–  uniform minimum safety levels in all Member States; 

–  a  coherent  body  of  minimum  safety  and  health  rules  specific  to  work  on  board  fishing 
vessels has been introduced into national legislation and owners have to comply with it fully; 
this also makes monitoring easier for inspectors; 

–  more inspections;  

–  greater  commitment  to  complying  with  national  legislation  in  the  area  of  prevention  of 

risks at work; 

–  enhanced safety of fishing vessels and better working conditions, in particular as regards 
working-teams, workplaces, accommodation on board, and methods of handling cargo and 
fish-boxes;  

–  better  structure  and  modus  operandi  of  the  occupational  risk  prevention  system,  and  in 

particular training, information and inspection work;  

–  more training for workers and skippers/captains; 

–  some  improvement  in  living  conditions  on  board  (albeit  also  due  to  technological 

improvements); 

–  the requirements in the Directive have been useful for devising practical provisions on the 

construction and equipment of fishing vessels; 

–  intensified professional debate within the sector. 

7.1.2.  Directive 92/29/EEC 

Though the Member States have noted no major negative or positive effects of the legislation, 
some point to a generally increased awareness of health and safety. The retraining courses and 
the  inclusion  of  new  definitions  have  been  mentioned  as  positive  effects,  and  the  minimum 
requirements for medicine chests and medical treatment on board have brought some changes 
in national legislation.  

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The Member States mention other positive aspects, e.g. 

–  the need for compulsory professional medical monitoring of seafarers is recognised;  

–  improvement in medical treatment on board vessels; 

–  medical supplies are ensuring medical care on board; 

–  inclusion of additional drugs in medical supplies (antidotes); 

–  medical supplies put to better use by the person responsible for medical care and guidance; 

–  more effective checks on medical suppliers, in particular as regards psychotropic drugs; 

–  refresher training at least every five years for the captain and the workers to whom the use 
of the medical supplies is delegated, leading to an improvement in those persons' medical 
knowledge; 

–  information  campaigns  (targeted  at  the  crew,  ship-owners  and  shipping  companies)  have 

led to greater awareness. 

7.2.  Main problems of implementation 

7.2.1.  Directive 93/103/EC 

The Member States mention the following problems:  

–  the  social  partners  in  most  Member  States  thought  that  dissemination  and  information 

activities covering the new provisions were insufficient;  

–  additional support was needed in view of the Directive’s technical complexity;  

–  difficult for existing vessels of 18 m or more26 to meet the requirements of the Directive in 

view of alterations; 

–  high cost of safety equipment (for employers); 

–  owners of small vessels reluctant to carry out risk assessments owing to the costs involved;  

–  risk assessments often a matter of filling in forms, with no impact on working conditions 

on board; 

–  lack  of  an  integrated  control  and  development  plan  for  risk  prevention  policies  in  the 

maritime environment; 

–  no formal procedures for cooperation between competent authorities; 

–  lack of enforcement of provisions to prevent occupational diseases; 

26 

France referred to difficulties in meeting certain requirements in Directives 2002/44/EC (vibrations) and 
Directive 2003/10/EC (noise) on fishing vessels. 

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–  age of the fleet in some cases an obstacle to implementation; 

–  lack of strong representation of fishermen an obstacle to improving working conditions;  

–  non-smokers still subjected to tobacco smoke in the mess; 

–  lack of direct assistance for those involved in safety issues on vessels. 

The specific case of small vessels: Directive 93/103/EC 

Directive  93/103/EC  is  not  applicable  to  vessels  of  less  than  15  m  in  length,  though  the 
Framework Directive does apply to vessels which are not covered by Directive 93/103/EC. 

Almost  every  vessel  of  less  than  15  m  in  length  is  the  property  of  the  skipper/captain,  who 
often works with other members of the family. There is thus is a large percentage of SMEs in 
this sector: depending on the Member State, between 60 % and 90 % of fleets are made up of 
vessels that are less than 12 m in length. 

According  to  the  independent  experts’  report,  small  vessels  have  difficulties  in  complying 
with  the  health  and  safety  requirements,  and  the  high  cost  of  safety  equipment  discourages 
small ship-owners from acquiring it. 

Accessing  safety  information  is  more  difficult  for  skippers/captains  and  crew  members  of 
smaller  boats,  especially  when  public  information  authorities  use  new  technologies,  such  as 
the Internet.  

Family  businesses  often  operate  with  old  vessels,  and  their  workers  have  hardly  any 
qualifications.  

The practical guide for small vessels mentioned under point 4.2 should address problems in 
wooden vessels, e.g. emergency routes and exits.  

7.2.2.  Directive 92/29/EEC 

The  Member  States’  national  reports  mention  the  following  problems  with  practical 
implementation: 

–  finding a suitable place for the medicine chest27; 

–  cost of purchasing and maintaining the new medical supplies; 

–  difficulty in securing supplies of certain medicines, particularly antimalarial drugs (which 

need to be imported)28;  

–  imbalance between the size of the vessel and the medical supplies it is obliged to carry; 

–  having drugs on board that should only be administered by a qualified doctor; 

27 
28 

Denmark solved this problem by designing backpacks for the smaller medicine chests. 
Denmark  reports  that  outside  Europe  it  may  be  extremely  difficult  to  buy  medicine  due  to  restrictive 
national legislation. 

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–  in  the  fishing  industry,  the  medicine  chest  is  used  mostly  for  minor  problems,  such  as 

headaches;  

–  setting up the radio medical centres was a challenge, due to doctors being unfamiliar with 
the maritime environment, a lack of experience in radio communication technologies, and 
the infrequency of this type of emergency call; 

–  in some sectors, doctors could be replaced on board by paramedics with special training; it 

was suggested that the decision be left to the Member State. 

The specific case of SMEs: Directive 92/29/EEC 

It  was  generally  felt  that  the  Directive  had  been  designed  for  larger  vessels  and  not  for  the 
Community fleet as a whole, with its implementation by SMEs causing most problems.  

The  medicines  to  be  carried  on  board  under  the  Directive  are  considered  suitable  on  large 
vessels, but too burdensome for medium-sized ones. 

The  clauses  regarding  the  distance  from  shore  have  created  particular  difficulties  for  some 
sectors of the industry.  

8. 

SUGGESTIONS FOR IMPROVEMENT 

8.1. 

Directive 93/103/EC 

Most Member States do not consider it necessary to amend the Directive, but rather that certain 
difficulties  identified  during  implementation  could  be  resolved  by  means  other  than  legislative 
action, i.e. by inspections focusing on specific issues and additional information.  

Some Member States, however, consider that the Directive should also cover vessels less than 
15 m in length, as the bulk of the Member States’ fleets fall within this range and statistics 
show that a significant number of accidents occur on small vessels. 

The  national  reports  show  that  the  major  challenge  is  to  improve  the  safety  culture  among 
fishermen,  which  demands  information  and  training.  The  Member  States  consider  that 
information could be planned more systematically and that safety training needs to be more 
adapted  to  the  circumstances  of  fishermen  in  terms  of  level  of  education,  availability, 
traditions and culture, etc. and should include more practical exercises. 

More cooperation is also needed at EU level in terms of studying and circulating best practice, 
and the strategic objective of humanising work in the fishing sector needs to be incorporated 
into the common fisheries policy (CFP), e.g. through social dialogue.  

8.2. 

Directive 92/29/EEC 

The  Member  States  made  several  proposals  on  the  Annexes  to  the  Directive,  i.a.  that  the 
medical supplies required under Annex II be reviewed, depending on the region and category 
of  vessel,  to  ensure  that  the  list  reflected  the  needs  and  conditions  applying  on  board.  The 
Annexes need to be adapted to technological and medical developments in medical supplies. 

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Other proposals concerned information and training29 and the inspection system.  

It  was  also  suggested  that  the  Commission  should  foster  a  better  understanding  of  the 
Directives by guides covering the various operations, vessel sizes and conditions in which EU 
fleets work. 

9. 

EFFECTIVENESS 

9.1. 

Directive 93/103/EC  

9.1.1.  Effects on accidents at work and occupational diseases 

9.1.1.1.  Accidents at work 

There is a basic problem in assessing the impact of national implementing measures, as it is 
difficult  to  ascribe  effects  to  a  particular  cause.  Before  the  Directive,  there  were  already 
national  provisions.  Technological  development  is  also  a  factor  in  the  improvement  of 
working conditions30. 

Although  Eurostat  produces  statistics  at  EU  level31,  there  are  no  reliable  data  available 
specifically on the maritime sector. However, reference may be made to the most recent EU 
ad  hoc  survey  of  accidents  at  work  available  for  EU-15,  namely  the  1999  Labour  Force 
Survey32,  which  indicates  that  the  fishing  sector  had  the  highest  incidence  of  non-fatal 
occupational accidents, at 2.43 times the EU average. 

In  most  Member  States,  there  is  also  a  lack  of  reliable  data  on  the  effect  of  the  new 
legislation, even though statistics on accidents involving seafarers are normally monitored at 
national level.  

However,  many  Member  States  have  reported  that  the  number  of  accidents  at  work  has 
declined,  possibly  as  a  result  of  implementing  the  new  provisions,  training  or  information 
campaigns. With some exceptions, the number of accidents in most Member States appears to 
have  fallen  more  steeply  than  the  number  of  fishermen,  implying  that  incidence  rates  were 
falling  prior  to  the  transposition  dates.  At  all  events,  accident  statistics  are  poor  in  most 
Member  States.  One  explanation  is  that  cuts,  scratches,  injuries,  lashes  and  bruises  are 
generally not even considered as accidents, but simply as part of the job.  

While  accidents  may  have  decreased  in  number,  their  seriousness  may  have  increased,  in 
particular due to the length of time spent on board, the fall in crew sizes and the scarce time 

29 

30 

31 

32 

For  example,  the  Commission  should  propose  detailed  objectives  for  training  for  persons  providing 
medical treatment. 
A problem arises, nonetheless, when technological improvements are not followed up with the relevant 
worker training. 
ESAW-European  statistics  on  accidents  at  work,  and  EODS-European  occupational  disease  statistics. 
The data are not entirely comparable because the data-collection criteria are not completely compatible. 
The actual scope of the problem continues to be underestimated in voluntary systems for the recording 
of accidents at work. However, Regulation No 1338/08 of the European Parliament and of the Council 
of  16 December  2008  on  Community  statistics  on  public  health  and  health  and  safety  at  work  (OJ  L 
304, 31.12.2008, p. 70) is to improve the harmonisation of reporting. 
The 2007 Labour Force Survey does not cover accidents and health problems in the fishing sector as the 
reliability criteria are not met. 

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available  for  training  on  land.  In  most  cases,  safety  conditions  on  board  seem  to  have 
improved prior to the transposition date, which may explain why the incidence rate has fallen 
more steeply than the size of the work force. Nonetheless, it should be borne in mind that that 
Directive 93/103/EC applies solely to vessels making up a small percentage of the EU fishing 
fleet33.  Since  there  is  a  big  difference  in  the  risks  on  board  small  vessels  as  compared  with 
large vessels, it is logical that national reports assess the direct impact of the Directive’s new 
requirements on accident figures as low. 

9.1.1.2.  Occupational diseases 

Since  national  systems  for  recording  occupational  diseases  show  even  greater  shortcomings 
than those for accidents, establishing a link between the new provisions and the development 
of occupational diseases in the sector is even more difficult. Nevertheless, indirect data show 
that  ill  health  is  an  important  factor  in  fishermen  giving  up  the  trade.  The  ageing  factor  is 
aggravated by the fact that fewer workers are entering the occupation, mainly because of the 
harsh conditions. This affects the working population’s ability to take on a heavy workload in 
a gruelling working environment. 

The  most  important  risk  and  harshness  factors  in  fishing  stem  from  the  weather,  the  heavy 
manual work, the psychological and social problems due to prolonged isolation, the pressure 
to work fast, and the long working hours unevenly divided between periods of intense activity 
and monotonous waiting, as well as the interaction between these risks.  

Keener  competition,  due  for  instance  to  falling  catches,  is  jeopardising  the  conditions  for 
prevention measures. In particular, the ‘shared-wage’ system on most small vessels may lead 
to longer working hours, more time spent on board and greater exertion. Effective prevention 
measures are not likely to be a priority under such working conditions and this lack may lead 
to more occupational illnesses and disorders. 

Muscular problems seem to be the main source of ill health among fishermen, probably as a 
consequence of ageing and the gruelling working conditions. 

9.1.2. 

Impact on productivity, employment and competitiveness 

Generally  speaking,  Member  States  do  not  provide  information  on  the  impact  of  the  new 
legislation on productivity, employment and competitiveness. 

9.2. 

Directive 92/29/EEC  

9.2.1. 

Impact on accidents at work and occupational diseases 

Prior to the transposition of the Directive, which coincided with a reduction in fishing fleets 
and thus a decrease in the number of workers and accident rates, some Member States already 
had  national  provisions  laying  down  equivalent  or  stricter  requirements.  As  for  Directive 
93/103/EC,  measuring  the  impact  of  Directive  92/29/EEC  in  quantitative  terms  is  therefore 
extremely difficult. The Member States struggle to explain the fall in accidents and cases of 
occupational disease, and their assessments of the impact of Directive 92/29/EEC are, in some 
cases,  contradictory  and,  in  others,  only  barely  positive.  In  general,  the  Directive’s  impact 

33 

For example, vessels over 12 m in length make up no more than a quarter of the fleet in any Member 
State.  

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appears  to  have  been  slight,  even  though  the  guidelines  concerning  medical  care,  medicine 
chests and training must have improved the crew’s access to medical care. 

9.2.2. 

Impact on productivity, employment and competitiveness 

The Member States generally provide no information on the impact of the new legislation on 
productivity, employment and competitiveness. 

10. 

CONCLUSIONS 

10.1.  Directive 93/103/EC 

Though the level of risk in fishing seems to have decreased more sharply than the size of the 
labour force in most Member States, it is still one of the most dangerous occupations in the 
EU, with 80 % of accidents on vessels being due to human error.  

The  views  of  the  Member  States  and  the  social  partners  and  the  results  of  the  independent 
assessment have given rise to the following suggestions.  

10.1.1.  Better knowledge 

More information on accidents and cases of disease in fishing is vital. While it is important to 
determine  the  major  risks,  recording  less  serious  accidents  via  improved  electronic 
communication and drawing up an indicative list of frequent diseases and their causes could 
also  be  useful.  This  could  be  discussed  within  the  sectorial  social  dialogue  or  the  Advisory 
Committee. The implementation of Regulation No 1338/08 on Community statistics on public 
health and health and safety at work may improve the reporting of occupational accidents and 
cases of disease in general. 

10.1.2.  Better communication, information and training 

The fragmented structure of the fishing sector, weak trade union representation and a fatalistic 
attitude,  i.e.  acceptance  of  the  traditional  view  of  the  sea  as  a  dangerous  and  unpredictable 
place  and  of  risk  as  part  of  the  job,  make  effective  provision  of  information  difficult.  The 
distance to the workplace and the scant time that many fishermen spend on land are also real 
impediments  to  participation.  Campaigns,  seminars,  publications,  webpages  and  the  like  are 
seldom effective in this sector. This is confirmed by the Member States and the social partners 
in most countries, especially as regards smaller enterprises. 

The development of new and better systems for communicating with people in the sector is 
indispensable.  It  is  also  crucial  to  involve  the  social  partners  at  EU,  national  and,  even  more 
importantly, grassroots level, and to try to make the cultural change stick. In this area too, the 
sectorial dialogue and the Advisory Committee could play an important role. 

Greater efforts are also needed in terms of training, focusing on adapting training material and 
courses to fishermen’s profile and possibilities, and not just on how to survive in the event of 
maritime disasters.  

The  UK  highlighted  that  course  attendance  seemed  to  depend  on  courses  being  compulsory 
(or about to become so) and free of charge, and that consideration had to be given to ensuring 
that the course had been understood. 

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10.1.3.  Better inspections 

The Member States are under an obligation laid down in Article 4 of the Framework Directive 
to  ensure  that  EU  legislation  in  the  field  of  health  and  safety  at  work  takes  full  effect,  in 
particular  by  ensuring  adequate  controls  and  supervision.  The  effective  enforcement  in  all 
Member  States  of  Directive  93/103/EC  and  other  EU  directives  in  this  field  is  essential  to 
improve  compliance  with  EU  legislation  which  will  effectively  contribute  to  reduce  the 
number of accidents at work and occupational illnesses on board fishing vessels. 

Some  Member  States  want  to  encourage  more  worker  representation  and  establish 
representation systems in each dock, with a view to including smaller vessels and encouraging 
collective bargaining in the sector as a way of improving working conditions. Trade unions, 
and non-unionised workers, must be involved. 

At  the  EU  level,  practical,  realistic  ways  must  be  found  to  improve  the  situation  regarding 
inspections,  which  seem  unsatisfactory.  This  might  involve  finding  out  what  the  Member 
States are doing in terms of inspections, consultation and training, with a view to sharing best 
practice,  involving  the  Senior  Labour  Inspectors  Committee  (SLIC),34  and  encouraging 
national labour inspectorates to focus on the sector and to consider forms of cooperation with 
other inspectorates, in particular technical and health inspectorates, where applicable. 

10.1.4.  Financing 

Many  of  the  difficulties  mentioned,  especially  by  small  vessel  owners,  concern  the  cost  of 
improving equipment on board vessels. Experience in several Member States has shown that 
support  measures  to  finance  improvements  are  effective.  The  Member  States  are  therefore 
invited to exchange good practice in this field. The European Agency for Health and Safety at 
Work  could  promote  such  exchanges  of  experience.  The  UK  suggested  that  it  should  be 
ensured  that,  if  the  resources  for  improving  vessels’  equipment  come  from  a  body  with  no 
safety remit, the safety body should first approve those changes. 

10.1.5.  Common fisheries policy 

Healthy fish stocks and environmentally sustainable fishing are a pre-condition for long-term 
economic sustainability. A profitable fishing activity is the best guarantee of high standards in 
vessel safety and working conditions. 

The  current  review  of  the  CFP35  offers  an  opportunity  to  better  integrate  the  objective  of 
improving  safety  and  living  standards  on  board  for  fishermen  with  the  overall  objective  of 
sustainable fishing practice from the environmental, social and economic point of view. 

10.1.6.  The scope of Directive 93/103/EC  

Vessels  under  15  m  in  length  account  for  a  majority  of  the  fleet  and  have  higher  accident 
rates.  As  for  extending  the  scope  of  Directive  93/103/EC  to  cover  these  smaller  vessels,  so 

34 

35 

Commission Decision 95/319/EC of 12 July 1995 setting up a Committee of Senior Labour Inspectors 
(OJ L 188, 9.8.1995, p. 11). 
The  review  of  the  CFP  to  make  it  more  efficient  in  ensuring  the  economic  viability  of  the  European 
fleets, conserving fish stocks, integrating with the Maritime Policy and providing good quality food to 
consumers was launched in 2008, see http://ec.europa.eu/fisheries/cfp/review_en.htm. 

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that  a  greater  number  of  vessels  and  fishermen  are  included,  the  Framework  Directive  and 
relevant  individual  Directives  apply  in  full  to  all  vessels,  including  those  under  15  m  in 
length. The application of the Framework Directive and individual Directives should therefore 
be  improved.  Greater  economic  pressure  on  the  fishing  industry,  stemming  e.g.  from 
dwindling stocks, stricter quotas and rising fuel prices, brings a need to develop instruments 
that could help small vessels to implement the existing safety and health measures effectively 
at little extra cost. 

One  way  to  improve  the  implementation  of  these  Directives  is  to  draw  up  a  practical,  non-
binding  guide  for  vessels  under  15  m  in  length  at  EU  level  in  order  to  clarify  certain  key 
concepts and to help all players to meet their obligations under the Framework and individual 
Directives. 

In  parallel,  an  Advisory  Committee  working  party  should  be  set  up  to  provide  advice  if 
measures in addition to those to improve the application of the existing Directives with a view 
to improving health and safety protection on small fishing vessels are to be considered, and in 
particular  the  amendment  of  Directive  93/103/EC in  order  to  extend  its  scope  to  cover  also 
vessels under 15 m in length.  

To sum up, the following measures are needed at national and/or EU level: 

–  non-binding instruments (guidelines) for small fishing vessels should be formulated by the 

Commission in conjunction with the Advisory Committee;  

–  an  Advisory  Committee  working  party  should  be  set  up  to  provide  advice  if  further 
measures to improve protection on small fishing vessels, and in particular an amendment 
of Directive 93/103/EC, are to be considered; 

–  the working party could also study ways of improving communication with fishermen as 

regards information and training on health and safety at work; 

–  the  SLIC  could  consider  launching  an  EU  inspection  campaign  on  fishing  and  medical 
treatment on board vessels in all 27 Member States and exchanges of best practice between 
inspectorates;  the  campaign  could  also  contribute  to  enhanced  cooperation  between 
technical and labour inspectorates; 

–  the  European  Agency  for  Health  and  Safety  at  Work  should  consider  awareness-raising 
measures on accident and disease prevention in the fishing sector, with the focus on small 
fishing vessels; 

–  the  Member  States  should  consider  specific  information  initiatives  for  self-employed 
workers  in  the  fishing  sector  as  part  of  their  national  strategies  for  health  and  safety  at 
work. 

10.2.  Directive 92/29/EEC  

The assessment clearly shows that new e-technologies can be applied to distance consultation 
when  it  comes  to  improving  accident  and  disease  prevention  and  protection  of  workers’ 
health.  

With a view to the strictly technical adaptation of the Annexes to the Directive in the light of 
technical  progress,  the  Commission  will,  in  accordance  with  the  procedure  laid  down  in 

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Article 8 of  Directive 92/29/EEC, submit  a  draft of the  proposed  measures, in line with the 
to  a  committee  comprising 
Member  States’  suggestions 
representatives of the Member States.  

their  national  reports, 

in 

To sum up, the following action needs to be taken at national and/or EU level: 

–  development of e-technology on a voluntary basis; 

–  convening  of  the  Technical  Progress  Committee  with  a  view  to  adapting  the  Annexes  to 

Directive 92/29/EEC. 

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