Memorandum submitted by the National Consumer
Council (A13)
The National Consumer Council (NCC) is an independent
consumer expert, championing the consumer interest to bring about
change for the benefit of all consumers. We do this by working
with people and organisations that can make change happengovernments,
regulators, business and people and organisations who speak on
behalf of consumers.
We are independent of government and all other
interests. We conduct rigorous research and policy analysis and
draw on the experiences of consumers and other consumer organisations.
We have linked organisations in England Scotland and Wales, and
a close relationship with colleagues in Northern Ireland. And
we work with consumer organisations in Europe and worldwide to
influence European and global governments and institutions.
We are a non-departmental body, limited by guarantee,
and funded mostly by the Department of Trade and Industry.
This memorandum responds to a request from the
Clerk of the Committee for a written submission in connection
with the Committee's Inquiry into the conduct of the GM public
debate.
1. The NCC is working on developing and
promoting models of risk governance that better reflect the consumer
interest and perspectives. Issues such as BSE, MMR vaccination,
GM crops and mobile phone safety are just some of the issues that
raise questions about how consumers respond to risk and uncertainty.
Consumers are sometimes said by policy-makers and experts to behave
irrationally in the face of risk, yet our understanding of how
consumers actually approach risk and uncertainty is limited. This
must change if the government is to assess, manage and communicate
risk more effectively.
2. The NCC has also undertaken a considerable
amount of work on consumer involvement[12].
In the NCC report involving consumers: everyone benefits, a number
of key ingredients are identified for successful public consultation.
Complete clarity about the objective for involving consumers is
essential. The aim should be to make consumer involvement second
nature. It should be built into policy-making processes as early
as possible, not added on at the end. Different purposes are better
served by different methodologies. For consumer involvement to
be meaningful, it needs to be carried out for positive reasons
based on a real need. It should encourage and enable consumers
to be effectively involved and have a real influence.
3. The NCC supported the GM Public Debate.
We believe it is very important that the public have a say in
the future of GM crops. We also very much support the work of
the AEBC in developing proposals for the public debate and for
the work of the independent steering board chaired by Prof Malcolm
Grant set up to oversee the process.
Consulting consumers/public is an important
point of principle in our model of "good" risk governance,
particularly where there are issues of scientific uncertainty
and/or controversy (both in this case). Other countries have a
stronger tradition of citizen or consumer participation in decision-making
but in the UK the Public Debate was unprecedented and so we believe
it is important to evaluate the process (as well as the outcome)
and to learn the lessons from it. This process is important not
just for the GM issue but for the future of public consultation
across government as a whole.
PURPOSE OF
THE DEBATE
4. The NCC believes that government failed
to make sufficiently clear the purpose of the debate. Was it to
simply to seek the views of the British public? Or was it to go
further and to allow the public to feel that they could participate
in debate on the issue and actually make their voices heard?
5. Secondly, the government failed to make
clear what influence the outcomes of the Public Debate would have
on its decision-making process. Indeed it sought to distance the
two and this still remains unclear. The NCC and other research,
shows that honesty about the limits for and potential for consumer/public
influence are an essential element in any successful public engagement
strategy. Without such clarity and understanding the public are
more likely to display cynicism towards the process. If people
believe the exercise to be tokenistic they will be deterred from
taking part.
6. NCC research[13]
shows that low-income consumers most strongly lack trust in the
way that government and officialdom handle matters of risk and
uncertainty such as GM, and are most likely to consider public
consultation a token gesture and therefore pointless. Consequently,
it is not surprising that levels of apathy among these consumers
are high. Overcoming such apathy was always going to be a challenge
for the public debate, particularly given the widespread public
distrust of government decision-making on GM.
NCC briefings[14]
show that only one in six people consider that the government
listens to what ordinary people think. Only 31% say they trust
the government to tell the truth on GM. Given this background,
it was extremely unfortunate that greater clarity of the relationship
between the public debate and government policy making was not
forthcoming. This, again, will have deterred some people from
participating in the debate, since they did not believe that the
government had a genuinely open mind on the issue.
RESOURCES
7. Any kind of public engagement, particularly
on the scale envisaged by GM Nation?, costs money and sufficient
resources need to be allocated. A lot of valuable time was wasted
initially trying to get more money allocated by Defra, which delayed
the whole process.
8. Equally important to successful public
involvement is allowing sufficient time for engagement. GM
Nation was launched to the public on May 6th, the deadline
for submissions was June 18th, a period of just six weeks. This
time period was woefully, and unnecessarily, inadequate to ensure
the kind of local level engagement, really reaching "ordinary"
citizens, that was originally intended. By comparison, government
good practice guidelines for public consultations is three months.
A public debate on such a scale required at least this amount
of time, if not more.
The NCC itself received complaints from local
organisations who considered they did not have time to arrange
local meetings or who heard about the debate process too late.
Others reported failures or delays in getting information via
the website address. Even local authorities struggled to put together
public meetings in this time period.
NCC research also shows that when seeking to
reach disadvantaged groups it is important to take the debate
to such communities, and to involve local, trusted groups. Again
this takes time and support.
9. The truncated timescale for the GM
Nation debate also meant that it was not possible for the
results of the science and economic reviews to be used as valuable
and up-to-date sources of information to inform the public debate.
The NCC believes this was a major shortcoming particularly given
the controversy that there was over the information that was provided
(in particular that provided by the Food Standards Agency).
ROLE OF
THE FOOD
STANDARDS AGENCY
10. The NCC would have liked to have seen
greater co-ordination and co-operation from the Food Standards
Agency with the Public Debate. The NCC, along with Consumers Association
and Sustain wrote a joint letter to the FSA on 12 March 2003,
expressing serious concern about the FSA's approach to GM, and
the way it positioned itself in the debate.
EVALUATION
11. Evaluation is crucial. It was a failing
that this was not built into the budget. The 64,000 dollar question
is, will it make a difference and has it impacted on the public's
perceptions of the issue. But this isn't just about GM, it is
also about the way in which government handles matters of risk
and uncertainty. It was an important step forwards in acknowledging
the importance of giving the public a say on controversial issues,
but valuable lessons need to be learned from the process.
12 September 2003
12 Involving consumers: everyone benefits September
2002. Back
13
Running risks October 2002. Back
14
GM Food: the consumer interest March 2003. Back
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