Memorandum by European Public Health Alliance
(EPHA)
1. The European Public Health Alliance welcomes
the adoption of the Green Paper on Mental Health, and especially
the approach of the European Commission in its consultation, which
goes beyond the borders of health actors and aims to involve other
relevant stakeholders. The Green Paper constitutes an important
step towards a strategy to tackle mental health issues in a comprehensive,
sustainable and harmonised way across the EU.
2. Addressing mental health and well-being
requires therefore a multi-faceted public policy approach, which
is what EPHA advocates for. As EPHA focuses on activities at EU
level, our response aims to highlight Community activities and
actions that could feed into an EU strategy on mental health and
well-being.[19]
I. THE RELEVANCE
OF GOOD
MENTAL HEALTH
OF THE
POPULATION FOR
THE EU'S
STRATEGIC POLICY
OBJECTIVES
3. One in four Europeans experience a significant
episode of mental illness during their lifetime, according to
the World Health Organisation (WHO). Mental health problems hamper
all aspects of EU's social, economic, educational, justice and
health care systems. They are also wide-ranging, long-lasting
and usually source of discrimination, challenging European values
at their core. Mental health and well-being depends on various
factors ranging from poverty, unemployment, housing, physical
environment, social networks, social capita, stigma, discrimination,
and opportunities. Therefore, EPHA strongly recommends to promote
good mental health for the EU population as to allow the EU to
comply with its core values and goals: achieving a sustainable
knowledge-based growth without ignoring its commitment to protect
Human Rights and strengthening social inclusion (EU Treaty article
13). An EU strategy will be key to underpin the EU's wider commitment
to solidarity, community and social justice.
II. THE ADDED
VALUE OF
AN EU-STRATEGY
ON MENTAL
HEALTH AND
ITS COMPONENTS
4. An EU Strategy on mental health and well-being
would add value by creating a framework for exchange between Member
States, increase the coherence between policies at European level,
and between the European, national and regional level, as well
as improve communication between the different actors.
5. EPHA calls for a EU strategy that allows
an horizontal approach to mental health, extend its scope beyond
the health sector and impact on other EU public policies. In EPHA's
view, the EU strategy should put more emphasis on the promotion
and prevention of mental health, as required by the article 152
of the Treaty Establishing the European Community, which states:
"a high level of human health protection shall be ensured
in the definition and implementation of all Community policies
and activities".
III. MAINSTREAMING
MENTAL HEALTH
INTO OTHER
EUROPEAN POLICY
SECTORS
6. The Green Paper reviews the effects of
mental health on the European society and it aims to broaden the
perspective from an healthcare point of view to a wider public
health approach, especially focusing on prevention and promotion
of mental health in various settings (poverty, violation of human
rights, stigma and discrimination, and the workplace). EPHA welcomes
the approach chosen by the European Commission and would like
to add some Community policy areas where mental health and well-being
should be mainstreamed.
3.1 Promoting mental health and addressing
mental ill health through preventive action
7. Access to healthy diets and the practice
of regular physical activity shall be highlighted in the Green
Paper. EPHA believes that our agri-food system holds a key to
the growing burden of mental and physical ill health in the recent
decades. Agriculture policy development (namely the Common Agriculture
Policy—CAP) should be reformed to take into account its
tremendous impact on health.
8. EPHA welcomes the intention outlined
in the Green Paper of drawing together work that has already been
undertaken at EU level on drugs, alcohol and substance abuse disorders.
We also welcome the will to examine the use and application of
harm-reduction strategies in this domain, in particular with relation
to the situation of homelessness. We would like to point out that
a strategy on drug and alcohol shall NOT focus only on children
and young people but must target the environment and conditions
which are associated with drinking.
9. As such, the future EU Strategy on mental
health could draw on the coming Strategy on alcohol. In addition,
we would recommend the EU strategy to build on the existing international
alcohol policy initiatives. In addition, the use of health or
nutrition claims on alcoholic products should not be allowed:
Europe's consumption of alcohol is already high and causing considerable
health damage.
10. With regard to vulnerable groups as
mentioned in the Green Paper, EPHA believes that it may be appropriate
to call for "individuals in community and settings",
rather than targeting vulnerable groups. A setting-based approach
(eg family life, school life, work life, housing conditions) could
be more flexible and prevent from further stigmatising vulnerable
groups.
11. Furthermore, EPHA calls for the emergence
of a consistent and coherent approach to children's heath across
EU policies and programmes. Evidence shows that targeted interventions
in school and community settings should be supported. The role
of the European Commission has to be to coordinate efforts and
to promote exchange of best practice between Member States.
12. Gender is a missing issue from the Green
Paper, although this determinant should be taken into account
when designing and reforming mental health services, which should
be gender-sensitive.
13. The workplace is of particular importance
in order to improve good mental health and prevent mental ill
health. The Green Paper mentions changes to work patterns such
as sensible working hours. It is important to mention here the
EU Working Time Directive as a tool towards the mental well-being
of the European workforce. Similarly, the elimination of stigma
and discrimination associated with mental health problems in employment
practices could fall under the European Employment Strategy.
14. The European Agency for Health and Safety
at Work (OSHA) could help incorporating mental health in occupational
health and safety (eg dedicating a year to good mental health
promotion at the workplace, developing guidelines to improve the
monitoring of work-related mental health through appropriate indicators
and instruments).
15. A better social inclusion of people
living with Mental Health disorders can also draw on the European
Directive of Equal Opportunities which sets out conditions for
employment and the obligation for Member States to provide an
independent financial support for everyone who needs it.
3.2 Promoting the social inclusion of
mentally ill or disabled people
16. Education is key to alleviate the burden
of Mental health on children and young people. EU programmes for
Education and Culture can further encourage the integration of
children and young people with mental health problems and disabilities
in the regular education and vocational training schemes.
17. The EU strategy could as well use resources
available in sport programmes in order to encourage initiatives
to include children living with mental disorders in regular school
programmes and activities. This would hinder stigma at an early
age.
18. The EU Social Inclusion strategy should
include provisions to facilitate the access to social housing
of people with mental health problems. The same does apply to
homeless people whose mental health conditions prevent them from
social reinsertion. A strong framework for exchange and learning
in the area of mental health will certainly feed into the Open
Method of Coordination's objectives such as objectives on the
eradication of poverty and social exclusion, as well as objectives
on ensuring accessible, high-quality and sustainable healthcare
and long-term care.
19. Structural Funds could be used to plan
and fund pilot programmes, develop guidelines for good practice
and monitor their implementation, establishing partnership across
sectors. Structural Funds are all the more important as regional
and local levels play an increasing role in the provision of health
and social care. They could also fund the establishment of community
based services rather than the building of closed door institutions.
3.3 Protecting fundamental rights, dignity
and combating stigma
20. A right-based approach can be used to
combat discrimination (art 13 of the EU Treaty), although its
limitations shall be acknowledged: people that are treated for
mental health problems have a right to health and are protected
by human rights conventions. However, the enactment of those rights
requires an active participation of a provider.
21. The future European Agency on Fundamental
Rights could play an active role in promoting rights of people
with mental conditions. However, this would imply an extension
of its remit towards the inclusion of human rights abuses occurring
under national laws. In this line, the European Council could
adopt a Council Recommendation on civil detention to provide clear
guidelines on compulsory treatment. The Recommendation, based
on current Human Right instruments, could clarify the definition
of compulsory treatment, as well as the criteria used for civil
detention. It could provide guidelines on the definition and training
of experts for assessment and decision making, on the timeframe
for emergency detention, health reporting standards, the inclusion
of patient counselling.
22. As mentioned in the Green Paper and
in the WHO Action Plan, it is of critical importance to scrutinise
disability rights legislation to ensure that it covers mental
health equitably.
23. Another policy area which can play a
significant and powerful role in promoting mental health and reducing
stigma is audio-visual policy. The current revision of the Television
without Frontiers Directive could provide a momentum to include
mentally healthy programmes.
3.4 Improving information and knowledge
on mental health in the EU
24. The implementation of efficient and
outcome-driven policies will depend on the availability of data
and useful indicators. The current status of mental health indicators
is fragmented and incomplete: it is covered by several Directorate
General of the European Commission, pan-European survey, local
and regional data, national indicators, World Health Organisation
initiatives.
25. There is agreement that we have already
important amount of information about the state of mental health
of the EU. However, there are still some information needs/gaps
more specifically on the effectiveness of measures to promote
good mental health that could be addressed by the European Union
7th Research Framework Programme: Information needs also target
mental health in children, mental health in the elderly, longitudinal
mental health, health determinants, geographical, economic and
social differences, vulnerable groups. There is a need to collect
data on positive mental health, as well as on protective factors.
19 A complete version of EPHA response can be downloaded
at:http://www.epha.org/IMG/pdf/EPHA_response_Green_Paper_mental_health.pdf Back
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