APPENDIX 17
Memorandum by the Green Alliance
HANDLING SCIENTIFIC UNCERTAINTY IN ENVIRONMENTAL
DECISION-MAKING
This submission is based on ongoing Green Alliance
work examining practical ways forward for policy and regulation
on issues of scientific uncertainty, including GM, BSE and chemicals
regulation. This work has included looking at need to build public
trust in decisions involving scientific uncertainty and ways to
engage the public in decision-making through deliberative and
inclusionary processes. Green Alliance has been working with representatives
from government departments including the Cabinet Office, DETR,
DTI, Office of Science and Technology, HM Treasury; industry;
environmental NGOs and academics on this area.
Below is a brief summary of some of our interim
recommendations:
(1) The public is interested in the world
we live in, not just in the short-term sense, but in the direction
that society is taking as a result of new technologies. Post-BSE,
the public has a sophisticated understanding of issues involving
scientific uncertainty and wants to be more involved in the decision-making
processes concerning these issues. The Government should open
these issues up to broad discussion and consultation as early
as possible. It is therefore necessary to have effective early
warning systems in place to identify potential opportunities and
problems in areas involving scientific uncertainty.
The Government should consider extending the
role of the Interdepartmental Liaison Group on Risk Assessment
(ILGRA) to include an ILGRA Futures Group, in order to anticipate
issues involving scientific uncertainty well in advance. Currently
this group is a voluntary network and the advantages and disadvantages
of formalising ILGRA to expand its influence and allow members
to allocate more time to the group should be considered. It was
notable that the Office of Technology Assessment to the US failed,
because it only focused on the problems and not on the opportunities
of new technologies and innovations and how to exploit them—means
must be found to engage the wider public in decisions about both
risks and benefits before full commitment has been made to new
technologies.
(2) The Government needs to ensure that the
right mechanisms are in place for handling issues of scientific
uncertainty and involving the public in these decisions. In particular,
the process for the framing of scientific questions should be
open and iterative. The new Agriculture and Environment Biotechnology
Commission (AEBC) for example has the potential to be effective,
if it is given the opportunity to be bold and experimental and
to genuinely consult widely and act on that consultation process.
Previous foresight exercises on biotechnology
have not sought views from the public and this is a crucial area
for the AEBC to remedy. The Government must also be an "intelligent
customer" for the advice produced by the Commission.
In order to build the necessary skill base within
Government and Agencies for implementing deliberative and inclusionary
processes, training and investment will be required. A point of
entry for these processes could be the Civil Service College and
the Centre for Management and Policy Studies in the Cabinet Office
as part of the Modernising Government agenda. Some form of reward
system should also be put in place for civil servants for involving
the public and for intelligence-gathering of the values and views
of the public.
(3) The Government should acknowledge that
there may be a wide spectrum of legitimate views on many of today's
environmental problems. It should be open about dissent where
it exists, as the public will quickly pick up on any false consensus,
which will consequently foster distrust. All views should be brought
to the table and the Government must continue to broaden the disciplinary
mix in institutions and stakeholder panels, including non-experts.
Transparency is a key component in building the
trust of the public in the decision-making process and the Government
should be open about scientific uncertainty. It should avoid the
inherently erroneous language of safety and phrases such as "no
evidence of harm" and acknowledge that the absence of evidence
of risk is not the same as evidence of absence of risk.
(4) A diversity of tools and techniques for
engaging the public is required for different situations. New
methodologies are emerging such as visualising futures; storytelling;
intuitive questioning and the use of interactive IT and the internet,
which are all at an experimental stage. The challenge lies in
trying to scale up such techniques, as the cost and time involved
may be considerable. It may not always be possible to directly
transpose participatory approaches used in other countries such
as the Danish consensus conference model, as it is framed in a
very different social context, where citizens have a greater tendency
to seek consensus. There is much to be learnt on how to engage
the public in UK. It will inevitably be a fairly lengthy and costly
learning process in order to refine a participatory toolkit to
meet the particular needs of the UK. However, whenever the costs
of the toolkit are considered, the costs of inaction, in terms
of loss of public trust must also be taken into consideration,
as seen with BSE and nuclear waste. It might also be helpful to
establish some institutional base for ensuring the appropriateness
and rigour of participatory tools being applied to different policy
areas. This would also assist in maintaining an "institutional
memory", so that lessons learnt from past experiences of
policy making are not forgotten.
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