Treatment 3 of our petition procedures in the session of the European Parliament on 09.11.2021

On 9 November, the Petitions Committee of the European Parliament will meet to discuss 3 of our petitions. This concerns the EU petitions 0808/2018, 1180/2019 and 0447/2020.
Petition No. 1180/2019 is based on our Bundestag petition
Pet 2-19-18-272-008095, which was forwarded to the European Parliament as a result of the resolution recommendation by the German Bundestag.

The meeting of the Petitions Committee is expected to take place at around 5.45 p.m. and can be followed via webstream as a live broadcast at the following link:
A recording of the meeting will be available from the following day.

Thankfully accepting the short-term offer of the Committee Secretariat, we have once again commented on our 3 petitions before the meeting on 9 November.
We submitted the comments yesterday in German and English to the e-mail address of the secretariat. As an attachment, we included our guide to supporting people with artificial light intolerance entitled „This is how you can help“.
Below are the comments on the petitions.

Petition Nr. 0808/2018

Petitioner: M.B., German citizen

As already mentioned, I am extremely impaired by the flickering light from LED/OLED and fluorescent lamps as well as screen devices and everyday objects illuminated with them. In addition to massive visual impairments and the resulting orientation difficulties, I sometimes suffer violent, involuntary physical overreactions. Even so-called „flicker-free“ illuminants and screens with smoothing are not yet tolerable for me. On the other hand, I am fine with incandescent lamps and unlit e-ink screens.

In order to cope with everyday life, I am now dependent on specialist, disability-friendly support in situations where I can no longer carry out visual tasks independently or without eye pain, migraines, vegetative disorders or a risk of accident and injury.

Consequently, the intolerance to flickering electric light sources means for me:

  • a barrier in everyday life,
  • a safety as well as health risk,
  • a burden on mobility and self-determination,
  • an obstacle to the pursuit of gainful employment.

In the meantime, the new flicker limits of Regulation (EU) 2019/2020 point in a positive direction. However, the values are still far too high for my needs.
I would like to express my regret that flickering electrical light sources, such as VDUs, electrical appliances, digital displays, children’s toys, clothing, furniture, decorative items, street lamps, signal lamps, bicycle lighting or even illuminated vehicles and their trailers are excluded from the limit value regulation. Light-based transmission applications – referred to as Connected Lighting Systems (CLS) in the text of the regulation – are also exempt. However, the data transfer takes place by means of targeted light-dark changes – so by light flicker. Moreover, the increase in light flicker of electric light sources during the use phase is not mentioned in ANNEX V within the scope of the endurance test procedure.

Therefore, I ask you, Honourable Members of the Committee on Petitions, to support me in my request to label electrical light sources with regard to their visual aptitude as well as their nervous and hormonal compatibility. In addition to power consumption and luminous flux (lumens), this could be an important decision criterion for barrier-free building projects.

Petition Nr. 1180/2019

We humans can be affected in very different ways by electric light and its by-products. However, many people are not even aware of the problems that the „wrong“ light can cause in everyday life.

Since electric light based on LED and fluorescent lamps is used in almost all areas of life nowadays, the radius of action of people with artificial light intolerance is correspondingly limited.
How participation in life in society can be guaranteed despite artificial light intolerance cannot be answered at present. So far, at least, people affected by artificial light have not been taken into account in terms of accessibility. But how can those affected get to kindergarten and school, to the workplace and training centre safely and without health effects when traffic lights and street lamps as well as trams, buses, trains, cars and other vehicles are equipped with LEDs inside and out and digital advertising systems and smartphones make it even more difficult to get around? How can participation take place at the place of activity? How can these people participate unhindered in cultural and leisure events if only LED and fluorescent lamps are used for general lighting? How can people affected by artificial lighting attend further education, seminars and conferences? How do they find their way around hotels? What about visits to the doctor, hospital stays, rehabilitation measures or cures? How can they go shopping for daily necessities independently?

As if all this were not enough of a barrier, medical identification of „light-sensitive patients“ has, according to our experience, so far failed mainly due to the methods and devices required for detection, as these would first have to be developed and tested. And so there is currently a lack of knowledge about intolerances and possible risks, on the basis of which quality-of-life-enhancing assistance could be provided.

Also, according to Regulation (EU) 2019/2020 – ANNEX I, Definitions for the Annexes, (61) & ANNEX II, Ecodesign requirements, 3. information requirements, (e) – an „incandescent lamp on prescription“ for light-sensitive people is not yet available in Germany, neither in pharmacies nor in medical supply shops. According to the letter of the GKV-Spitzenverband of 15.02.2021 to us, the inclusion of corresponding lamps in the list of medical aids is necessary beforehand. For this purpose, a manufacturer would have to be found who can put the already phased-out incandescent lamps back on the market with proof of the medical benefit.
In addition, the widespread use of LED lamps has meant that commercially available luminaires now provide less electrical power (watts) than was previously generally the case. Both the lampholders themselves and the wire in the current-conducting cable are of smaller dimensions and therefore no longer suitable for all types of lamps. Consequently, if the current consumption of the „incandescent lamp on prescription“ is too high, the luminaire may be overloaded and even cause a cable fire.

Your assistance, Honourable Members of the Committee on Petitions, can help to ensure that:

  • in the design of electric light sources,
  • by making available incandescent lamps and compatible luminaires,
  • in the medical registration of artificial light incompatibilities,
  • in the creation of accessibility

the needs of sensitive groups of people are also taken into account responsibly in the future.

Petition Nr. 0447/2020

As stated in our letter of 10.04.2020, we support the reintroduction of near-infrared electric light sources in artificial lighting environments.

Although more operating current is required for near-infrared electric light sources than for short-wave HEVL light sources, this parameter could be put into perspective upon further consideration. This is because the use of HEVL light sources could lead to adverse health effects in the long term that are relevant to population medicine. This, in turn, would have to be compensated by a higher use of energy and resources.
In this context, we pointed out that near-infrared light seems to be suitable to mitigate negative effects of HEVL light sources on human health.

Since this potential risk is of important economic significance due to the widespread use of HEVL light sources, we suggest a proactive intervention. In this regard, we ask you, Honourable Members of the Committee on Petitions, for your assistance in taking appropriate precautionary measures.