Industry attempts to limit human health protections must be resisted – NGOs tell health and environment commissioners

industrial factory at the night

Leading health and environmental groups have strongly condemned industry claims that human health concerns fall outside of the scope of EU‘s industrial pollution legislation.

In a letter to the Environment and Health and Food Safety Commissioners,[1] the EEB, CIEL and HEAL rejected recent claims from industry lobby groups that the EU’s industrial standards should not cover human health protections.[2]

They also call for explicit references to “preventive measures” to be retained in a standard text that will influence environmental performance guidelines for decades to come.

The EEB is Europe’s largest network of environmental citizens’ organisations with 140 members in more than 30 countries.

Commenting on the letter, EEB Industrial Production Manager Christian Schaible said:

“The resistance of industry lobby groups like CEFIC, CEWEP and EUROFER to have human health protection duly considered within these essential protections is deeply irresponsible. People in Europe expect EU industrial standards to be the best in the world, that means that all the features of the EU Eco-Management and Audit Scheme needs to be implemented and explicit references to preventive action must be included”

In the letter, EEB Secretary General Jeremy Wates writes:

“It is unreasonable and disingenuous to argue that protection of human health falls outside of the scope of the Industrial Emissions Directive, the text of which is peppered throughout with references to human health.”

The letter warns of recent industry attempt to restrict the scope of the Industrial Emissions Directive (Integrated Pollution Prevention and Control Recast), the EU’s main instrument for regulating pollution from industrial activities. The Directive sets binding standards for major industry in technical documents called ‘BREFs’.

The letter concludes:

“We strongly condemn claims that human health concerns fall outside of the scope of the BREFs and efforts to delete references to “preventive measures”, and call on the European Commission to ensure that references to human health aspects and to “preventive measures” are retained in the Environmental Management System standard text.”

‘BREFs’ refers to the ‘Best Available Technique reference documents’, which are produced for various industries by the European Commission following a consultation exercise known as the ‘Sevilla Process’.

The European Commission has recently proposed a new standard text to be used when rules are revised. While a reference to “human health” was included in this text, environmental groups are concerned that “preventive measures” has been removed despite having been explicitly mentioned in all previous BREFs.

The letter explains:

“Preventive measures” are taken to prevent pollution at source before any harm can be caused, “prevention” is the part of the core aim of the [Industrial Emissions Directive] and “preventive measures” are included in the Directive as the first general principle governing the basic obligations of plant operators

The EEB is a recognised member of the Industrial Emissions Directive Article 13 Forum, which provides oversight and guidance to the Commission and has called for all the features of the EU Eco-Management and Audit Scheme (EMAS) to be implemented.[3]

The letter was also supported by two partner organisations the Center for International Environmental Law (CIEL) and the Health and Environment Alliance (HEAL).

Letter: Human health and preventive action in BREFs


[1] See the letter: ‘Human health and preventive action in BREFs’, 29 March 2018.

[2] Chemical industry says attempts to clean up toxic textiles is “abuse” of industry regulations, META, 15 March 2018.

[3] Environmental Management Systems (EMS) are designed to encourage operators to optimize production processes in terms of environmental or wider sustainability performance. The EU established the Community’s Eco-management and audit scheme (EMAS system), which sets out the core elements on what this entails. Typically this includes sustainability and environmental performance criteria, provisions on its implementation and transparency for reporting. See:


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Anton Lazarus, Communications Officer


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