It is more than 25 years since Britain joined the EEC. Tina Garrity reflects on the impact of Europe on British environment and health policy

To many, it must seem like only yesterday that the UK decided to abandon traditional methods of public health decision-making and submit to the continental mode. For younger EHOs of course, the European Union has always been there - there is now a whole generation of EHOs who were not born when Britain entered Europe. Throughout the past 26 years CIEH has endeavoured to represent the profession's interests, reporting on key issues via the monthly journal.

Early days
One of the biggest problems for the profession has been the fact that the concept of the EHO is largely unknown elsewhere. Nowhere is this problem more acute than in meat inspection, which on the continent tends to be the realm of veterinary surgeons. The first battle fought over veterinary inspection concerned poultrymeat slaughterhouses. Although a lengthy campaign was mounted to retain EHO competence, including a mass lobby of parliament in October 1976, the government insisted that in order for the UK to export poultrymeat, veterinary responsibility for its production was necessary. A prayer against the regulations in parliament was lost by 115 votes to 108. Not everyone was pessimistic, however. A.E Scott, writing in April 1977, said the new regulations contained much that was good. He urged the Association to concentrate on pushing for advances in food hygiene rather than merely protecting what existed. There were great inadequacies in UK legislation that needed addressing. Although depressed about meat inspection the Association recognised there was much to achieve in food inspection generally and set about visiting other EEC states to see how things were done.

environmental standards
Those working in environmental protection had different concerns. Common standards were inevitable but would they be sensible and achievable? When the proposal for a bathing water directive appeared, opinion was sceptical. Bathing in sewage-contaminated water was not thought particularly dangerous and the EEC idea of having bacteriological standards for every situation seemed impractical. Nevertheless, the directive also addressed oil pollution and chemical dumping, where the UK had experienced problems. Alan Kirkman, writing in July 1979, suggested that overall the directive would raise standards and he urged authorities not to shy away from being honest about bathing water quality. In June 1979 B.Manifold, writing about the first EC environmental action programme, noted the UK's concerns about rigid emission standards, but argued that they might improve life for EHOs because councils would devote greater resources to pollution control. This was echoed by David Purchon, writing about the environmental impact assessment directive in 1982. Predicting impacts and mitigating them was in the best tradition of preventive health and EHOs should be fully involved, he argued.

The Association gets active
By the late 1970s it was clear that EHOs needed to get involved with the decision-making process at an early stage. In 1980 General Council approved a budget for EEC matters and a subscription to the Official Journal was purchased. More space was devoted to the EEC in the journal. In 1982, with DoE assistance, a meeting was arranged with one of the Commission environment officials in Brussels. The visit was a success and in 1983 the Institution engaged an EEC consultant, Amanda Cleary. In 1985 the Commission published its white paper on completing the single market and there followed a tidal wave of proposals. The Institution meanwhile, set up a European subcommittee.

Foodstuffs and Food Hygiene
In 1986 the Commission proposed a directive on the official control of foodstuffs. The IEHO welcomed it, but was concerned at the lack of reference to hygiene, calling for a separate directive on the hygiene of foodstuffs. In March 1987 it visited Brussels to put its case to the Commission official responsible. The following year it wrote outlining the expertise of UK EHOs in food inspection and requesting closer input. Then, in 1988, a proposal for a food hygiene directive finally emerged - but not from Brussels. It came from the UK Co-operative Union which, along with its European counterparts, had concluded that an essential prerequisite for a successful single market in food was consumer confidence. They drafted a brief proposal and submitted it to various bodies including the IEHO which supported it and suggested additions. A copy was sent to the Commission, which took up the idea and produced a proposal in 1989 introducing the concept of Haccp. Although the IEHO had concerns about the impact of Haccp on small businesses and was disappointed that the requirement for a basic minimum of training for all food handlers had been watered down, it welcomed the directive and argued that it should become the basis for all EC food policy.

Health and safety
Before 1987, health and safety legislation was limited to a handful of specific areas. In 1987 the Single European Act extended article 118 of the Rome Treaty so that rather than just promoting close co-operation on safety issues, states were required to "pay particular attention to encouraging improvements". In 1988 the Commission published its third programme for health, hygiene and safety in the workplace. It was an ambitious programme envisaging a host of measures, including the famous "six pack" directives. The IEHO welcomed the initiative, but had reservations about the enforceability of the VDU directive and feared enforcement resources may be directed away from higher risk activities.

In 1992 the European Year of Health and Safety was marked by the IEHO and HSE obtaining EC funding to hold an international conference on health and safety enforcement in Europe. As well as promoting the role of EHOs, the conference gave the Institution an opportunity to improve its contacts with DGV in Luxembourg. The following year it worked with the HSE on a series of training seminars for EHOs on the enforcement of the "six pack" directives.

Meat hygiene
It had always been known that sooner or later veterinary supervision would be extended to domestic red meat slaughterhouses. Nevertheless, when the time came the IEHO tried to argue the EHO's case to government, pointing out that veterinary supervision would be more expensive with no real public health benefit. It was to no avail. At least EHOs managed to retain competence in the meat products and minced meat sectors. Then came the game meat proposal with its requirement that wild game be inspected within 24 hours of killing. The IEHO argued that the directive was too ambitious and that there should be separate directives for farmed and wild game. Ian Coghill from Birmingham CC, writing in January 1991, argued that the requirements, which would lead to vets across Europe being paid around £40 per hour to peer into the trachae of snipe and palpate the colons of dormice, were irrelevant to the protection of human health. Eventually the IEHO got its wish and the directive was split, with the wild game version taking a less draconian tone.

Environmental protection post 1985
In 1987 the Single European Act added a new section to the Rome Treaty giving the Community specific competence in environmental matters. It set in motion a frenzy of environmental regulation. Among the directives adopted before 1992 were those on diesel emissions, nitrogen oxide, air pollution from combustion plants and nitrates in water. One of the more controversial directives, largely because of the cost involved, was the waste water directive, which sought to raise standards of sewage treatment. Other waste directives included those on animal waste, hazardous waste, radioactive waste and a new version of the general waste directive. Freedom of access to environmental information and genetic manipulation also got legislative treatment. Work began on the European eco-management and audit scheme directive. Most importantly, from an institutional angle, the European Environment Agency was set up.

Possibly the most controversial proposal was that covering landfill waste which appeared in May 1991. At the time it was welcomed by the IEHO as a comprehensive document that would go a long way to harmonising standards across Europe. The proposal, unpopular with industry and the UK government, went through various redrafts. A new version was issued in March 1997. The Institute was less enthusiastic. A new target for a reduction in the amount of biodegradable waste going to landfill compared with 1993 would be difficult to achieve, it said. There was a danger that short-term pressure would lead to more waste incinerated rather than re-used or recycled. The IEHO was also unhappy at a proposal to ban the landfilling of tyres, saying that 100 per cent recovery was impracticable and landfilling was preferable to incineration. Nevertheless the directive has been adopted and the UK faces a struggle to get the new regime implemented.

In February 1992 the Maastricht Treaty made environmental regulation even easier and introduced the concept of sustainable development to the treaty for the first time. Almost immediately the Commission issued its fifth environmental action programme. The IEHO welcomed the programme and considered each of its target areas in the light of its Environmental Protection committee work programme. One of the first issues to be considered was bathing water. In March 1994 the Commission issued a proposal to revise the 1975 directive. Initially, it was feared that some of the standards would be weakened due to lack of scientific evidence on the health risks, but this was denied by the Commission. The IEHO's view was that the existing microbiological standards were broadly sufficient. As for the scientific basis of parameters, it took the line that in the absence of evidence the precautionary principle should apply. Any desire to concentrate on those areas of greatest risk to public health should not mean that other parameters for substances likely to present serious or even unquantified risks should be overlooked, it warned. Ultimately the proposal made little headway and was eventually was withdrawn. It is understood that a new proposal is scheduled for early 2000.

More recently the Commission has ventured into the field of noise pollution with its 1996 green paper on noise. Although disappointed at the heavy emphasis on transport noise and lack of any reference to leisure and neighbourhood noise, the CIEH has welcomed the initiative and is looking forward to commenting on the draft framework noise directive expected sometime next year. An extended version of this article is available from the author on 0171 827 5821. E-mail: t.garrity@cieh.org