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HEAL’s reaction to proposal for 7th EU Environment Action Programme

While HEAL welcomes that health concerns feature in the EU Commission proposal to guide EU environmental policy up to 2020, actions put forward to reduce exposure to air and noise pollution or hazardous chemicals are too superficial to bring down rates of chronic disease from environmental pollution and the associated economic health costs.

Environment Action Programmes have guided the development of EU environment policy since the early 1970s, and are instrumental in driving policy change at the EU and national level. The current proposal “Living well, within the limits of our planet” aims to provide an overarching framework for environment policy up to 2020, with nine priority objectives for the EU and its member states to attain.

Health protection is enshrined in priority goal three to safeguard EU citizens from environment-related pressures and risks to health and wellbeing. The Commission rightly stresses that water, air pollution and chemicals remain among EU citizens’ top environmental concerns. When it comes to moving from the analysis of environment-related health problems to outlining which measures can be taken to reduce the exposure of the population, the Commission’s approach simply falls short.

This relates especially to dealing with hazardous chemicals, where too much emphasis is placed in the proposal on the uncertainty around health and environment impacts of chemicals, and further strengthening the knowledge base. Yet the precautionary principle and recent EU legislation already require measures to reduce exposure to hazardous chemicals through phase out and substitution. Therefore, the main priority until 2020 is not to close the knowledge gap, but to set up a timeline and targets for things such as how many substances of very high concern under the European Community Regulation on chemicals and their safe use (REACH) should be assessed each year, and by when pesticides and biocides with endocrine disrupting properties will be assessed and substituted. HEAL would have also like to see the recognition of the important role that coordinated EU human biomonitoring plays in assessing the population’s exposure to hazardous chemicals and how it can guide policy decisions. EU Environmental Ministers had called for fostering biomonitoring in their conclusions of June 2012, and yet it is absent in the current proposal.

There is also a lack of recognition on the significant health benefits that can be reaped by increasing the EU’s climate change ambition and a faster move to a low-carbon economy. HEAL would also like to see stronger emphasis on how to reach the World Health Organisation’s (WHO) air quality guidelines. The current limit values in Europe for particulate matter offer no protection from adverse effects on public health. The limit values are far above recommendations by the WHO and also well above air quality standards in the USA and other developed countries.

The proposal will now go to the European Parliament and the EU Environment Ministers. It is one of the flagships of the Irish EU presidency which starts in January 2013.

Last updated on 13 December 2012

About HEAL

The Health and Environment Alliance (HEAL) is a leading European not-for-profit organisation addressing how the environment affects health in the European Union (EU). We demonstrate how policy changes can help protect health and enhance people’s quality of life. Read more »


HEAL has over 70 member organisations, representing health professionals, not-for-profit health insurers, doctors, nurses, cancer and asthma groups, citizens, women’s groups, youth groups, environmental NGOs, scientists and public health institutes. Members include international and Europe-wide organisations, as well as national and local groups. Read more »

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