Select Committee on Science and Technology First Report


CHAPTER FOUR: THE GOVERNMENT'S USE AND HANDLING OF ADVICE

How is scientific advice weighed against other factors?

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.[158] Dr Cunningham told us that "built into the system now is the provision for those issues to be considered".[159] 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".[160]

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 consumers[161]. 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.[162] Other witnesses made similar points.[163]

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. ".[164] 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".[165] 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.[166] 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.[167] 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".[168] 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.[169]

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.[170] 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, suggested.[171] 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 Committees

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.[172] 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".[173] 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?

SECRETARIATS

77. Scientific advisory committees need proper support to enable them to do their jobs properly.[174] 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.[175] Others drew attention to the overall decline in the size of the scientific civil service.[176] Professor Beringer said that insufficient resources and staff were allocated to the support of ACRE and that this was causing "serious problems".[177] 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".[178] 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.[179] 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 advisory system.


158  MAFF, The Report of the Committee on the Ethics of Genetic Modification and Food Use, 1993. Back

159  Q. 813. Back

160  Q. 728. Back

161  Ev. p. 1. Back

162  Ev. p. 54. Back

163   QQ. 719-21; Ev. p. 212; Ev. p. 223, Ev, p. 124. Back

164  Q. 552. Back

165  Ev. p. 269. Back

166  GM Plants for Food Use, p. 13. Back

167  See for example Ev. p. 249. Back

168  Ev. p. 220. See also Ev. p. 171; Ev. p. 12; Ev. p. 88. Back

169  Human Genetics Advisory Commission terms of reference, Office of Science and Technology.  Back

170  See Ev. p. 223; Ev. p. 225; Ev. p. 12. Back

171  Ev. p. 188. Back

172  Q.731. Back

173  Ev. p. 185. Back

174  See Ev. p. 253. Back

175  Ev. p. 34. Back

176  Ev. pp. 250-2  Back

177  Ev. p. 102. Back

178  Q. 542. Back

179  Ev. p. 250. Back


 
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