APPENDIX 4
Memorandum from the Institute of Electrical
Engineers (IEE)
The IEE responds to around 30 formal consultations
each year, as well as maintaining regular contacts with a number
of government departments. Much of this work is of a technical
nature (see Annex 1), and we form our views based on advice from
our panels of expert Members and Fellows. In addition, our Members
and Fellow sit on a variety of government advisory panels and
committees (for example the Council for Science and Technology),
as either individuals or representing the Institution, and are
also heavily involved with activities such as the Research Assessment
Exercise (RAE). The IEE is therefore pleased to submit evidence
to this House of Commons Science & Technology Select Committee
Inquiry.
It is rarely possible for us to establish a
direct link between evidence offered to government and its policy
decisions. This position does not seem to be unique to us, and
in our experience it is generally felt there is very little in
terms of published analysis or feedback. The exception is typically
where a summary of consultation responses is produced, yet this
is still unlikely to explain what evidence was, or was not, used
in the decision making process.
In contrast to this, there are some notable
successes. Foresight[3]
is widely perceived as a valuable exercise, which considers future
issues, and enjoys strong participation and a two way exchange,
with the wider science and technology community. Yet Foresight
is perhaps in a unique position, with different time scales, and
a focus on the issues of tomorrow, not today.
Scientific evidence is extremely important in
policy making because not everyone involved is going to have a
natural understanding of the issues. Scientific and technical
evidence needs rigorous analysis and should be subject to peer
review, although time pressures must be taken into account. Even
when timeliness is critical, the use of existing panels/committee
of experts, or looking to professional institutions or other bodies
could be a quick route to getting the necessary analysis to be
done—yet in our experience assistance is seldom requested.
Government already has guidelines produced by
the Office of Science and Technology. These guidelines are extremely
comprehensive, and provide the right framework for Government.
The one weakness, as we highlighted in August 2005 when we were
consulted, is evaluation and monitoring.
THE TECHNOLOGIES
SUPPORTING THE
GOVERNMENT'S
PROPOSALS FOR
IDENTITY CARDS
The Home Office carried out a major consultation
over an extended period, and received input from an extremely
wide group of stakeholders including the IEE. Our input was gathered
from—as it always is—a broad range of members, many
of whom are leading experts in the various sciences and technologies.
We offered this advice impartially and raised a number of important
issues, including those concerning the technical implementation
of the scheme, such as the technical aspects of biometrics, and
the more general problems encountered time and again with complex
IT systems.
The Home Office published a summary of the responses
in October 2004. Whilst this appears to be very comprehensive,
it is simply a summary. It did not detail what arguments were
accepted, or how the scheme as taken forward will address the
issues. This lack of open and informed debate continues.
There may be some value if future summary documents
included information on the response to certain evidence, what
was accepted/rejected, or how proposals have been amended. This
type of feedback would be useful both for those outside Government
to understand the decision, and the process leading to that decision,
and might also to improve the quality of future inputs. There
are examples[4]
across Government of consultation summaries that include details
of how the decision is reached and what evidence is considered.
Whilst it may pose a challenge to extend this to technical or
scientific issues, it is a challenge worth considering.
What Impact are Departmental Chief Scientific
Advisers Having on the Policy Making Process?
It is not clear what the impact across Government
has been as there does not seem to be any evaluation following
the Cross Cutting Review of Science and Research, or at least
no publicly available evaluation. Anecdotally it has been suggested
that where the post is well established, or is a senior position,
the role can be extremely beneficial and can bring impartial expert
advice directly into the department. However, whether this is
a universal experience across Government is not clear.
The Cross Cutting Review (2002)[5]
recommended:
"Every department which conducts or commissions
an appreciable amount of research, or uses science should have
a Chief Scientific Adviser, accountable to the Secretary of State
and Ministers for science procurement and advice within the department."
Whilst a number of departments in this category
would already have had Chief Scientific Advisers (CSAs), (for
instance the Ministry of Defence), is it not clear to us how many
departments have since implemented this recommendation. Again,
to our knowledge, there does not seem to be a central register
of CSAs, nor is there a robust mechanism for assessing the effectiveness
of their roles in general.
This lack of monitoring and evaluation of the
roles of CSA (and indeed scientific evidence more generally) is
a matter of concern to the IEE, and one we raised during Sir David
King's review of the Office of Science and Technology Guidelines
on Scientific Analysis in Policy making in August 2005 (our comments
on evaluation are below).
It is not clear to us how CSAs continue to maintain
their contacts and information networks. There do however seem
to be simple steps that could be taken to improve the situation.
For example, as a professional body, we would be happy to meet
with relevant CSAs on a regular basis and such meetings would
seem like a sensible method of augmenting and adding value to
existing sources.
TREATMENT OF
RISK
The issue of risk really centres how it is understood—the
problem is in part that "risk" has accepted meanings
in science and in popular usage which are significantly different.
The general public have also suffered a loss of confidence in
"experts", due amongst other things to variety of court
cases, which may also contribute to the problems.
The Science Media Centre has a very good publication[6]
aimed at scientists and engineers seeking to comment publicly
on risk—it explains the gap between the two groups' perceptions
extremely well, and offers advice that may even be applicable
to Government communications.
The treatment of risk, in a department with
a Chief Scientific Advisor, should be common place and built into
existing procedures. The communication of this risk should also
present no problems, providing advice is taken. There are clear
examples in recent history of the poor handling and communication
of risk—the examples most commonly given are BSE and GM
crops.
EVALUATION AND
FOLLOW-UP
We see evaluation as the key factor. Whilst
we support the Office of Science and Technology's guidelines,
we still believe that the one failing is that of evaluation:
"As the guidelines are largely principle
based, we would encourage departments to ensure they are woven
into departmental guidance on better policy making[7]".
It would appear possible for government departments
to ignore completely the guidelines, and furthermore, it would
appear that there is no monitoring, so this may in fact already
be occurring. If strong guidelines exist, should they not be automatically
incorporated into departmental policies, and adherence to them
monitored?
In our comments to the Office of Science and
Technology we suggested that the Consultation Code of Practice
could be expanded to include a further principle that the guidelines
are used, and that this should be monitored.
CONCLUSION
The IEE, together with many professional organisations
has a wealth of scientific and technical knowledge, and we believe
we are well engaged with a number of Government departments. Yet
we are still unable to offer any more than an educated guess as
to the basis for some decision making (this is not intended as
a criticism of all policy decisions).
It seems at odds that whilst a robust set of
guidelines already exist, processes to monitor and evaluate their
use are not in place. How evidence is used is not monitored, and
perhaps most importantly, there is no public scrutiny of the usage—expect
for that of this Committee. Nor is the information always made
available to the general public.
The treatment and use of scientific evidence
must be carefully considered, and public concerns must always
been borne in mind. Evidence presented as "scientific"
should clearly stand the test of being subject to rigorous standards
of scientific method and scrutiny. There may well be reasons that
the full decision making and analysis process cannot always be
made public, but we do not see any reasons for what we perceive
as a lack of evaluation and monitoring of the processes.
January 2006
Annex 1
Areas of scientific or technical advice covered
by The IEE
— RFID—Radio Frequency Identification
Devices.
— The possible effects on health of
mobile phones, base stations and power lines.
— Energy and Environment.
— Health and Safety issues.
— Information Technology including
Best Practice Guidelines.
— Safety Related Systems including:
— Safety Critical Systems.
— Competency Guidelines for Safety
Related Systems Practitioners.
— Electromagnetic Compatibility
and Functional Safety.
www.iee.org/policy
3 http://www.foresight.gov.uk/ Back
4
For example Defra's summary to its consultation on its aims and
objectives includes Defra's responses to concerns raised http://www.defra.gov.uk/corporate/aims/summary.htm Back
5
http://www.hm-treasury.gov.uk/spending_review/spend_ccr/spend_ccr_science.cfm Back
6
http://www.sciencemediacentre.org/risk.htm Back
7
http://www.ost.gov.uk/policy/advice/index.htm Back
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