CHAPTER FOUR: THE GOVERNMENT'S USE AND
HANDLING OF ADVICE
How is scientific advice weighed against other
69. Governments over the years have asked questions
of the scientific advisory system on issues raised by genetic
modification which are not scientific in nature. Lay representation
on scientific advisory committees has been increased. Specialist
studies have also been carried out, such as that conducted by
the Committee on the Ethics of Genetic Modification and Food Use
(the Polkinghorne Committee) in 1992-93.
Dr Cunningham told us that "built into the system now is
the provision for those issues to be considered".
Mr Rooker said "there are no less than 12 qualified ... ethicists,
across the Government's advisory committees in this area. In fact,
pull them altogether, and you could have a committee of ethicists".
70. Nevertheless many witnesses argued that the current
advisory system relating to GM food and crops fails to address
adequately the non-scientific aspects of regulation. Iceland told
us that the advice given to Government had "completely failed"
to address the "genuine, well understood concerns" of
Greenpeace told us that the scientific advisory system was not
sufficiently informed of widely-held public values and nor did
it operate in resonance with them.
Other witnesses made similar points.
71. We have already acknowledged the importance of
lay members on scientific advisory committees and believe that
they should be present in greater numbers. However, to argue that
the presence of lay members on committees, whose membership is
quite rightly dominated by experts in the relevant sciences, can
adequately address all other factors that need to be considered
is naive. Professor Beringer told us that the role of scientific
committees was "to provide an assessment of the risks, not
to provide Ministers with an easy political solution. ".
The Royal Commission on Environmental Pollution stated that "a
clear dividing line should be drawn between analysis of scientific
evidence and consideration of ethical and social issues which
are outside the scope of scientific assessment".
We strongly agree. ACRE and ACNFP are scientific committees;
their advice should be restricted to scientific concerns. Individuals
have a range of personal preferences and practices regarding food,
some based on ethical or religious grounds. The Government must
have a mechanism for addressing these issues; the scientific advisory
system does not do so at present nor it is appropriate to require
or expect it to.
The Organisation of the Scientific Advisory Bodies
72. The Royal Society has recommended that "an
over-arching body or 'super-regulator' should be commissioned
by the Government to span departmental responsibilities and have
an ongoing role to monitor the wider issues associated with the
development of GM plants" and suggested a range of scientific
and regulatory activities for this committee.
Other witnesses make a variety of proposals for mechanisms by
which the ethical and social considerations surrounding GMOs could
be included in the regulatory system.
Most suggestions involved the creation of a new body with a wide
remit to consider matters arising from genetic modification for
food purposes and advise Ministers accordingly. For example, the
UK Life Sciences Committee argued that such a body could serve
"to ensure that the wider issues on GM technology ... were
adequately assessed ... [and that it could] develop ways in which
public values can be taken into account".
Such bodies cannot, however, replace the responsibilities of Ministers
to take regulatory and policy decisions on behalf of the public.
The controversy over GM foods illustrates clearly that, in addition
to the scientific advice, Ministers, in deciding on policy and
regulation, must take account of the consumer, ethical, economic
and political issues associated with introducing new technology.
Ministers should obtain advice on these other, non-scientific,
issues but should not seek such advice from the scientific advisory
system. The Human Genetics Advisory Commission, charged with reporting
on "issues arising from new developments in human genetics
that can be expected to have wider social, ethical and/or economic
consequences", provides a good model.
73. We do however see benefit in rationalising the
current committee structure. Many of the issues relate very specifically
to the organisms under question: ACRE evaluates a GMO when it
is to be released to the environment and ACNFP when it is to be
used in food. Several witnesses have suggested ACRE and ACNFP
meet together formally or that their chairmen should meet regularly
to discuss concerns which cross the committees' remits.
While we recognise that occasional ad hoc meetings between
chairmen may be useful, there is scope to formalise the links
between these committees and provide a unified and coherent scientific
advisory structure relating to the production and consumption
of GM food. We recommend that ACRE and ACNFP are merged to
form an integrated committee which considers all scientific issues
relating to GM food and crops and advises Ministers, Departments,
and in the future, the Food Standards Agency. The specific functions
of ACNFP and ACRE could then be delegated to sub-committees.
74. The integrated committee should also have forward-looking
functions scanning the horizon for, and alerting Ministers
to, scientific advances that may necessitate changes to the regulatory
or advisory regimes for GM food and crops or identifying areas
where further research is required, as the MRC, among others,
The integrated committee should have a joint DETR, Office of
Science and Technology, Department of Health and MAFF secretariat
(with MAFF's role moving to the proposed Food Standards Agency
when it is established) with a joint budget and joint departmental
responsibility. Departmental Ministers should continue to be responsible
and the Minister for Science should have a coordinating role.
Process Quality Assurance for Scientific Advisory
75. As Mr Meacher said, "there is a financial
management and policy review which is carried out every five years
of these advisory committees" but there is no formal audit
procedure for providing assurances that individual scientific
advisory bodies adhere to the principles set out in The Use
of Scientific Advice in Policy Making.
Novartis suggested the development of a "process auditor
of an independent nature ... to comment and validate the rigour,
application and completeness of the committee process itself".
We agree that this proposal has merits. We therefore recommend
that the Science Minister, with support from the Chief Scientific
Adviser, bring forward proposals for a process audit procedure
monitoring the work of all the scientific advisory bodies relating
to genetic modification, not only in terms of ensuring that the
system works cohesively but also auditing the functions of particular
committees from time to time.
Role of Departmental Officials
76. The scientific advice Ministers receive from
advisory committees is normally delivered through secretariats
or other departmental officials. Thus, the expertise and integrity
of officials is as important as that of the Committee members.
There are two issues here. Firstly, are advisory committees getting
the support they need from their secretariats to do their jobs
properly and thoroughly? Secondly, are officials suitably qualified
to help ministers assimilate scientific advice into policy?
77. Scientific advisory committees need proper support
to enable them to do their jobs properly.
Both ACRE and ACNFP are currently supported by scientifically
qualified staff but the Rowett Research Institute pointed out
that there has been a reduction in the number of outstanding scientists
supporting committees in the food safety area.
Others drew attention to the overall decline in the size of the
scientific civil service.
Professor Beringer said that insufficient resources and staff
were allocated to the support of ACRE and that this was causing
He told us that "nine people ... have to deal with all the
work to do with releases in this country, all the interactions
within Europe and all the international work and it just is not
enough. It has not been enough for nearly three years now...People
are working extraordinarily long hours; they are terribly overtaxed".
We find this observation worrying, especially as Professor
Beringer's concerns on this matter had apparently not been drawn
to the Minister's attention. We recommend that the Government
looks closely at the staffing arrangements for scientific advisory
committees and commits itself to providing large enough secretariats
to ensure the efficient working of the Committees. The cost of
extra staffing will be small compared with the cost of failure
of the advisory system.
SCIENTIFIC EXPERTISE IN THE CIVIL SERVICE
78. IPMS believes that scientific expertise in the
civil service is being degraded. It argues that the separation
of the central civil service from Government laboratories and
scientific next steps agencies has reduced the natural flow of
scientists between active science and scientific policy making.
We have not looked at this issue in detail in this case study
but we recognise this as an area of concern. It is an issue to
which we intend to return in our overall inquiry into the scientific
158 MAFF, The Report of the Committee on the Ethics
of Genetic Modification and Food Use, 1993. Back
p. 1. Back
p. 54. Back
QQ. 719-21; Ev. p. 212; Ev. p. 223, Ev, p. 124. Back
p. 269. Back
Plants for Food Use,
p. 13. Back
for example Ev. p. 249. Back
p. 220. See also Ev. p. 171; Ev. p. 12; Ev. p. 88. Back
Genetics Advisory Commission terms of reference, Office of Science
and Technology. Back
Ev. p. 223; Ev. p. 225; Ev. p. 12. Back
p. 188. Back
172 Q.731. Back
p. 185. Back
Ev. p. 253. Back
p. 34. Back
pp. 250-2 Back
p. 102. Back
p. 250. Back