Select Committee on Environment, Food and Rural Affairs Written Evidence


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 happen—governments, 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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