This year the European Commission will conduct an assessment of its roadmap on “GDP and beyond: Measuring progress in a changing world.” In February 2012, EPHA undertook an assessment of progress made at an EU level since 2008, and how progress is measured as part of the Europe 2020 Strategy. A review on the implementation of the Smart Regulation Agenda is also being taken this year. This revision aims to reduce administrative burden, improve the quality of EU legislation and increase dialogue with stakeholders.

Building on the synergies of these two processes at an EU level, EPHA would like to highlight the growing body of evidence that GDP alone cannot measure all aspects of human development, human and social capital and well-being as this economic indicator does not account for social costs. EPHA advocates that these arguments should also be extended to the Impact Assessment Process.

EPHA advocates for Health Impact Assessments (HIA) to be incorporated into the integrated Impact Assessment process in a strategic and balanced fashion. Sustainability should be the overarching objective of any impact analysis. We consider that health is a way to measure sustainable development and that people’s health is a crucial element in measuring the impact of environmental, social, and economic policies.

Not only are health outcomes readily measurable - health concerns are immediate, personal and local. Therefore, the economic pillar of the Impact Assessments (IA) should be an objective only in so far as it is sustainable and responsive to these needs, improves environmental and social conditions and protects and promotes health.

The European Court of Auditors issued a report on Impact Assessments. The report found social impact assessment were assessed less often than economic costs. In this regard, the Finnish Ministry of Health and Social Affairs funded a study on how health is considered in European IA procedures and how it is reflected in the reports through studying half of the Commission IAs [1]. This study found that health was not systematically taken into consideration and points to the fact that there is a clear need for further exploration on ways in which health could be more appropriately considered when impacts of other policies are considered by the various DGs.

One possible solution could be to have health as an IA pillar in order to evaluate the social and environmental impacts and their effects on fundamental rights. EPHA strongly supports the incorporation of health impact assessment into national legislation as well.

Summary of recommendations:

- Developing more sophisticated methodologies and upgrading statistical information for health impact assessment (HIA).
- Addressing the problem of measuring what is very difficult to measure. For example, non-economic impacts such as impacts on health, safety or specific consumer rights, such as the right to information.
- Considering the costs of not addressing environmental, public health or food issues.
- Going beyond cost-benefit (i.e. savings in terms of health expenditure should be measured positively and added costs should be negative.)
- Tackling the problem of inequality of resources in terms of submitting data, research and other inputs to impact assessments between stakeholders with specific interests (economic operators) on the one hand, and those with more diffuse, general interests on the other (e.g. health and consumer organisations).
- IAs should therefore specify the costs and benefits of proposals, how they occur and who is affected.
- Preparing IA reports in a way that facilitates the comparison of alternative options in terms of their estimated impacts by improving the presentation of qualitative analysis.
- Developing a strategy to improve the quality of data available for IA by taking into account the specific situations in individual Member States.
- Putting more emphasis on implementation aspects and making more use of ex-post evaluations of implementation of EU legislation as an input for the IA process.
- Building capacity and an evidence base for HIA within the Commission through research projects, training and awareness raising.
- Distinguishing between short-term (immediate), medium-term (intermediate) and long-term (ultimate) policy objectives.
- Exploring ways in which health could be more appropriately considered when impacts of other policies are considered by the various EU Commission Directorate Generals.
- Examining the possibility to have health as its own IA pillar in order to evaluate the social and environmental impacts and the effects on fundamental rights.
- Creating a legal obligation for HIA which mirrors that for strategic environmental assessment and environmental impact assessment.
- Integrating explicit requirement for HIA in the EU Health Strategy both on health systems and public health.
- Raising awareness amongst MEPs, Committee chairs, Member States Permanent Representations, and rotating Presidencies of the Council of Ministers on the ability to request IAs on amendments.
- A representative from DG SANCO should have a seat as a member of the Commission’s Impact Assessment board.
- Ensuring more transparency with regard to sources of data, methods, selection of policy options, the selection of external expertise (with a special attention to possible conflict of interests).
- Open consultations with all relevant stakeholders in accordance with the Commission’s own minimum standards.
- A health actor should be represented in the High Level Group of Independent Stakeholders on Administrative Burdens when the mandate is renewed in 2014

The Full document is available at

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- EPHA response to the European Commission public consultation on sustainability agenda
- EPHA position on the European Commission’s 7th Environment Action Programme
- ’LiveWell for low impact food in Europe (LIFE)’ project launched in Brussels - chronic diseases and climate change in focus?
- ’Our food systems are making people sick’ states UN rapporteur
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- Commission Agenda for Change Highlights Health for Development
- MEPS call for new indicators to complement GDP


[1] Ståhl, Timo. Is health recognized in the EU’s policy process? An analysis of the European Commission’s impact assessments. Eur J Public Health (2010) 20 (2): 176-181. doi: 10.1093/eurpub/ckp082

Last modified on August 18 2014.