Select Committee on Science and Technology Seventh Report


6  Risk and public communication

Introduction

146. The perception and treatment of risk covers a wide spectrum of events and activities, from the expected and calculable, such as vehicle accidents and crime, to the uncertain and less predictable, such as natural disasters or health epidemics. In another sense, there is also risk attached to the business of government itself. Programmes and projects are subject to risks, whether technological, financial or external, which are managed and mitigated as part of the process of policy implementation. Whilst our case study on ID cards dealt with risk management in that context, in this Report we focus largely, although not exclusively, on the former, broader understanding of risks, as they apply to the public.

147. The management of risk has been subject to growing attention in Government in recent years and is now being considered at the highest levels. In December 2002, following a report from the Strategy Unit, the Prime Minister established a three year Risk Programme, based in the Treasury, to monitor progress on the Government's handling of risk. This programme has led to further cross-departmental work on risk and the production of additional guidance and performance assessments. The increasing profile in Government of risk management was illustrated in a speech by the Prime Minister in May 2005. He suggested that an increasingly risk-averse culture in Britain was having a detrimental impact on public policy.[285] The Government's management of risk has also attracted the scrutiny of Parliament. The work of the Public Accounts Committee now routinely includes an assessment of the handling of risk in the context of specific policies or projects and across the public sector more generally.[286] In June 2006 the House of Lords Select Committee on Economic Affairs published a Report on Government Policy on the Management of Risk.[287] This followed up some of the concerns identified by the Prime Minister in his speech and used some specific examples to assess the models and approaches used by Government in managing risk, although it found no significant evidence to suggest that Britain has become increasingly risk averse.

148. In view of the broad scope of our inquiry, we did not undertake a detailed analysis of the economic models adopted and applied by the Government to manage risk. Instead, we pursued some of the risk-related issues highlighted by our case studies and the other evidence we received. These include the application of the precautionary principle, the communication of risk to the public and the dissemination of best practice.

Cross-government work on risk

149. The present Government is not the first to seek ways of improving the handling of risk. An Interdepartmental Liaison Group on Risk Assessment (ILGRA) was established in 1991 with a remit to promote consistency and disseminate best practice in risk assessment in Government.[288] It produced three reports in ten years. These identified areas of weakness, highlighted how a more strategic and consistent approach to risk assessment could be pursued and spawned further inter-departmental activity on risk management. The Royal Commission on Environmental Pollution did some valuable work on risk evaluation in the environmental context in its 1998 report Environmental Standards and Public Values. Specific guidance for departments on risk management has been included in general guidance on policy making produced by the Treasury. The "Green Book" is a best practice guide for policy development and appraisal and sets out how economic, financial, social and environmental assessments of a policy or project should be combined.[289] It focuses on risks to projects and does not specifically deal with risks to the public. This is supplemented by further detailed guidance on different aspects of policy making. For risk, the "Orange Book" contains practical guidance on the development of a strategy to manage risk, including in the context of proposals which relate to public health and safety.[290] As a result of this work, the Government has established the following principles for risk management, which departments are expected to follow:

  • Openness and transparency—both about their understanding of the nature of risks to the public and about the process they are following in handling them;
  • Engagement—departments will be expected to involve a wide range of representative groups and the public from an early stage in the decision process;
  • Proportionality—action should be proportionate to the level of protection needed, consistent with other action, and targeted to the risk;
  • Evidence—departments should ensure that all relevant factors, including public concerns and values, have been taken into account; and
  • Responsibility and choice—where possible, people who willingly take risks should also accept the consequences and people who have risks imposed on them should have a say in how those risks are managed.

These broad principles are fleshed out by practical guidance and technical models for assessing and evaluating risks, notably the June 2005 guidance produced by the Treasury on Managing risks to the public: appraisal guidance.[291]

150. The Risk Programme established in 2002 built upon the work of ILGRA, which it superseded. In its third and final report, in 2002, ILGRA noted that a Cabinet Office review had established that many departments had Risk Frameworks, which were "becoming embedded in their policy work and culture". However, it identified areas where further work was required: these included tackling risks that impact upon a cross-departmental basis and improving risk communication by having a central resource to collate research and disseminate best practice.[292] The replacement of ILGRA in 2002 by a high level group based in the Treasury and reporting directly to the Prime Minister could be seen as an implicit recognition that the group's useful work had not had a sufficiently strong impact across Whitehall. The final report of the Risk Programme in June 2005 noted a measurable improvement in managing risk but also identified significant remaining challenges.[293] These are listed by the Government as follows:

  • "even better anticipation of risk, and more early action to tackle it —there are still too many major policies and projects starting before the risks have really been understood and gripped;
  • better management of risk with delivery partners —increasingly we are delivering services and projects through partnerships, either with the private sector or the wider public sector. Yet our evidence is that departments do not feel confident of successfully managing risks in this environment;
  • further embedding of risk management in the core processes of government for example in the current comprehensive Spending Review;
  • in some cases more needs to be done to understand the overall portfolio of risk a department faces and to work out how to present this information to the board in a concise fashion;
  • continuing to develop an open dialogue with the public on risk issues, to build confidence and trust; and
  • behind all of this lies an issue we have been grappling with for some time —creating a culture of leadership for delivery and reform and on managing the inevitable risks this brings."[294]

151. After over a decade of concerted action on risk, there clearly remains much to do. These challenges have been addressed primarily by a sub-Committee on risk of the Permanent Secretaries' Management Group, chaired by Sir Brian Bender. Since 2003 departments have been required to self-assess their performance against a specially developed Risk Management Assessment Framework, monitored by the Treasury. The average departmental score improved from 2.9 out of 7 to 3.1 from 2004 to 2005.[295] Our request for a breakdown by department of these figures was refused on the grounds that the scores were self-assessed and therefore comparison between departments was "not meaningful". Nonetheless, the scores indicated the "direction of travel of Whitehall at large".[296] Yet it is hard to see how an average measure can be considered useful if the individual data are considered meaningless. The other reason given—that highly sensitive decision making in key policy areas was involved—we also do not regard as valid: a departmental breakdown need not reveal the policies covered. This explanation reveals the limitations of this potentially useful exercise: a more accurate indication of progress and reliable guide to departmental performance might have been achieved by independent assessment from the outset.

152. The need to reinforce a change in culture in departments has been identified by the Government as a key priority, particularly in relation to the taking and management of risk. We were told that the sub-Committee on risk is promoting the establishment of a culture of well managed risk-taking by publishing examples of good practice across Government.[297] We have noted earlier the weak scientific culture in some departments[298] and some witnesses expressed doubts about departments' in-house capability in risk assessment. The Royal Society of Chemistry told us of "underlying problems within the UK (and EU Agencies) concerning the understanding of the conceptual basis of health and environmental risk analysis by scientists involved in regulatory risk assessments and policy advice for, in particular, chemicals, due to lack of adequate academic and training facilities in the UK (and EU)".[299] Our MRI case study identified failings in the way in which the relevant regulatory impact assessment established all the potential risks of the EU Physical Agents (Electromagnetic Fields) Directive. We gained the impression that regulatory impact assessments were not afforded a high priority and called for improvements in the way that they are conducted.[300] Similarly, our case study on illegal drugs found inconsistencies in the way in which the health risks associated with the use of different drugs were incorporated into policy on classification and then communicated. The House of Lords Economic Affairs Committee identified similar doubts over whether guidelines on risk management had been implemented in the development of policy on passive smoking.[301]

153. The Government CSA, Sir David King, acknowledged that the ability of the Government to assess risk "varied from one government department to another".[302] We note that the House of Lords Economic Affairs Committee concluded that whilst the Government has developed a "sound and potentially useful framework" for the assessment of risk, there were questions over whether this framework was being applied properly. We agree that a great deal of valuable work has been done on risk over the last ten years: departments now have a framework within which to develop their own approaches. However, a set of well crafted guidelines is not sufficient to ensure effective risk management on the ground. Whilst the Chief Social Science Researcher, Sue Duncan, asserted that the Treasury guidance on risk is used by departments,[303] we are not convinced that it is yet in routine use across Whitehall. The challenge, as has been acknowledged by Government, is to change the culture in departments. This requires not only commitment from the top—ministerial and Permanent Secretary level—but an emphasis from managers right down the line on the importance of risk assessment and management. This should involve appropriate emphasis in training and development which we discussed in the context of Professional Skills for Government (paragraphs 49-53). We recommend that departments ensure that the Professional Skills for Government programme and other training activities provide comprehensive coverage of the principles and practice of risk management.

BEST PRACTICE

154. There is a balance to be struck between ensuring consistency of practice across Government and allowing sufficient flexibility to enable individual departments to respond according to the very different situations they face. We are aware that some departments have been undertaking their own work on risk. Whilst we recognise the scope for further research by departments on specific policies or issues, there is also a danger of wheels being invented simultaneously across different parts of the civil service. DEFRA, DoH and DfES all have their own guidelines covering risk assessment and management and there is a fair degree of overlap. In the mid-1990s there was a debate in ILGRA on the merits of having one set of guidance to cover the whole of Government, and there was general agreement that each department needed to be able to produce its own.[304] The Government has taken some steps to avoid duplication of activity: the work of the sub-Committee on risk is communicated to the Cabinet Secretary and senior officials and departmental risk improvement managers meet 4-5 times a year to share good practice.[305] This is welcome, but we are not persuaded that this work goes far enough or is an adequate substitute for a continued centrally-driven risk agenda (see paragraph 174 below).

155. In view of the importance that the Government has rightly attached to risk management in recent years and the considerable remaining challenges that have been identified, we were surprised to discover that consideration is being given to scaling down cross-departmental work in this area. The sub-Committee on risk decided in July 2006 that there will be no more departmental self-assessments under the Risk Management Assessment Framework and that a decision will be taken in autumn 2006 on whether the sub-Committee should continue at all.[306] We find it surprising that, having established a useful tool for departmental performance monitoring, the Government is dropping it so soon. Without it continuing, it will be impossible to judge whether the efforts to embed risk assessment in the policy making process have had any lasting impact. We do not believe that now is the time for the sub-Committee on risk to be wound up. It would send the wrong message about the intensity of the focus on risk management. A high level group is an important symbol that risk management is not another passing trend in administrative practice, but an integral part of the policy making process. We welcome the progress the Government has made toward promoting proper risk analysis in policy making but are concerned about how this progress will be sustained. We recommend that the sub-Committee on risk continue to operate and that it ensure that the monitoring of departmental performance on risk management is maintained.

The Precautionary Principle

156. In view of the ongoing debate surrounding the use of the precautionary principle we decided to include it in our terms of reference for this inquiry. We explored its application, primarily at an EU level, in our MRI case study and undertook to consider it further in our overall inquiry.

DEFINITION

157. The precautionary principle is but one tool or approach which can be used in risk management. What it is and how it should be applied has been the subject of considerable academic debate and also exploration in policy guidelines. The first attempt at a definition was contained in the Rio declaration on climate change in 1992. It stated that "Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation."[307] However, increasingly campaigning organisations and, taking their lead, members of the public and the media are interpreting the precautionary principle as meaning "where there is potential harm from a technology, it should be restricted until and unless it is demonstrated or proved to be safe". This restrictive interpretation causes difficulty for policy-makers and those seeking to communicate policies which involve a more reasonable interpretation or application of the precautionary principle. The definition provided by the current GCSA, Sir David King, was: "When there is reasonable suspicion of harm, lack of scientific certainty or consensus must not be used to postpone preventative action".[308] However, he preferred to talk of a "precautionary approach" rather than a principle, to be applied where "the scientific evidence is incomplete or inconclusive, and there is the possibility of severe and irreversible consequences".[309] He explained the distinction: "My objection, if you like, to a precautionary principle is that it seemed to be stating something new when, in fact, I think all it was stating is 'you should be cautious' and it did not seem to me that it should be embodied in a new, big principle".[310]

158. In spite of the preference of the GCSA for a precautionary approach, it is the precautionary principle that is included in the latest Treasury guidance setting out the five guiding principles of risk management. Under the proportionality heading, the guidance states that the Government "will apply the precautionary principle where there is good reason to believe that irreversible harm may occur and where it is impossible to assess the risk with confidence, and will plan to revisit decisions as knowledge changes".[311] The definition used is the one used in the Rio Declaration on the environment, but without further elaboration.

159. The ILGRA group published a report on the precautionary principle in 2002. It took the Rio definition of the precautionary principle as a starting point but emphasised that "Policy guidelines are needed to indicate when, for example, the precautionary principle should be invoked, how a risk-based approach can continue to be followed when the scientific uncertainty is such that conventional risk assessment cannot in itself determine the level of risk, and how decisions should be made on appropriate precautionary measures."[312] No such guidelines have been produced. It also asserted that "Invoking the precautionary principle shifts the burden of proof in demonstrating presence of risk or degree of safety towards the hazard creator".[313] This explicit statement about the burden of proof goes somewhat further than other definitions or explanations, although the guidance does go on to stress that there should be flexibility in applying this approach.

160. We noted in our MRI case study Report that the precautionary principle was not clearly defined by the Commission, although it was in common use in EU institutions, including the courts,[314] and indeed different variations of its formulations have been used by different EU institutions. For example, one study has found that the precautionary principle has been mentioned or applied—often extensively—in over 60 European Court of Justice judgements but only one such judgement has attempted to define it.[315] This obviously poses difficulties for businesses and Governments introducing new technologies. Indeed, the Director of the King's Institute for Risk Management, Professor Ragnar Löfstedt, has commented that "what the precautionary principle actually means […] is difficult to pinpoint, as studies indicate up to 19 different formulations".[316] In spite of the inclusion of the precautionary principle in Government guidelines on risk management, and the identification by the ILGRA group of the need for further explanatory guidance on it, there is still no detailed definition of the precautionary principle for application by Government departments.

APPLICATION

161. A precautionary approach has been claimed to have been adopted by the Government and its agencies in respect of some recent policies where scientific uncertainty or scientific controversy has existed. For example, the GM Science Review saw itself as "part of a genuinely precautionary approach to the appraisal of GM food and crops". [317] Sir David King explained that the advice was that all GMs that could be considered for crops to grow for eating should have been through all of the scientifically regulated processes that had been specifically devised. He said that whilst this represented a "reasonably good approach to applying precautions", he was reluctant to see it established as a principle in the way that some NGOs sought, and equally reluctant to see NGOs determining whether it had been applied or not.[318] He stressed the importance of ensuring that any action should be proportionate to the risk that is being evaluated.[319] The Stewart Report on mobile phone safety also advocated a precautionary approach, explaining that this approach "requires that before accepting a new development we should have positive evidence that any risks from it are acceptably low, and not simply an absence of convincing evidence that risks are unacceptably high".[320] This approach was not considered clear or satisfactory by all interested parties. The Mobile Operators Association state that "the precautionary approach recommended by the Stewart Report has itself caused confusion within parts of the community and even Parliament itself".[321] Orange went further: "The 'precautionary principle' is interpreted very differently by the media, public and scientific community and is often interpreted by the media and public to mean that any form of unknown risk is unacceptable and must be 'regulated away'". They go on to argue that Government can serve to heighten public concern by giving credibility to unsubstantiated perceptions of risks.[322] We agree that the precautionary principle is interpreted in very different ways—it is invoked by both sides in the GM and mobile phone masts debates—and that some extreme interpretations promote a culture which tolerates no risk at all.

162. Of course, a precautionary approach does not necessarily entail regulation or bans. As the Chair of the FSA, Dame Deirdre Hutton, stressed, it can also include the provision of advice in areas of uncertainty.[323] We sought to find out how a precautionary approach is applied to food safety in practice. Dame Deirdre cited the example of dioxin emissions from funeral pyres during the foot and mouth epidemic, when the FSA advised those who consumed milk from their own farms that they may wish to vary their diet whilst further research was undertaken to confirm safety.[324] The FSA states that this advice was precautionary, in line with its policy to take a precautionary approach when risk is uncertain. This was indeed precautionary, but another, also precautionary, approach would have been simply to ban such consumption of milk pending the further tests. In fact the FSA took this more restrictive approach of a full recall of product in the case of Sudan I dye contamination of foodstuffs, where the risk of harm to consumers was probably lower than in the dioxin case. The FSA told us that they took this approach in the Sudan I case not on the basis of the risk but because such contamination was illegal.[325] This example illustrates that the precautionary approach, even when applied with the benefit of experience, can not provide a definitive guide for action in every case. Its use will always involve subjectivity and judgment to a greater or lesser extent. We note that the House of Lords Economic Affairs Committee concluded that the precautionary principle was one of a few risk-related terms which should be more clearly defined or replaced with less ambiguous concepts.[326] We also note the view of the Head of the Government Economic Service, Sir Nicholas Stern, that risk analysis cannot be reduced to one principle.[327]

163. The ILGRA report on the precautionary principle states that: "Applying the precautionary principle is essentially a matter of making assumptions about consequences and likelihoods to establish credible scenarios, and then using standard procedures of risk assessment and management to inform decisions on how to address the hazard or threat."[328] The Royal Society acknowledged the different interpretations of the principle in use and told us that "the question of how and when the precautionary principle should be applied needs to be determined on a case by case basis".[329] The Royal Society of Chemistry expressed concern at the "tendency (as with all regulators) to adopt a 'gate-keeping' approach and a disproportionately 'hard' precautionary approach when it is possible to pass the costs of implementation to others". It argued that the principle does not mean "better safe than sorry" and noted the "directly adverse effects" that its application can have.[330] A good example of this we found in our MRI case study, where new health and safety regulations governing the use of MRI scanners threaten to inhibit both future research and diagnostics to an extent that appears disproportionate to the risks involved.

HARMONISATION WITH THE EU

164. Any attempt to further define a precautionary approach or principle would need to take into account the need for harmonisation with existing EU applications. In our MRI case study Report we found that the guidance produced by the EU Commission in 2000 was a helpful, if limited in terms of practical use, "check-list of issues to be considered in situations of scientific uncertainty within an overall approach to risk management".[331] On the development of the policy of the Directive itself, we could find no adequate explanation of how the precautionary principle was applied in practice.[332] We asked Sir David King whether he thought there was any clash between the UK and EU approaches to the precautionary principle, in terms of definition and implementation. He did not believe that, in terms of output at least, there was a clash between the UK and the EU: "there is nothing that we are doing in the British Government, based on my precautionary approach, if you like, that would lead to a different outcome from other European countries operating what you might call a precautionary principle."[333] We are not persuaded that this is the case. The fact that the UK Government saw no need at all for a new Directive on Electromagnetic Fields indicated to us that the prevailing view in the EU was evidently "more precautionary" or more cautious than the UK stance, irrespective of the definitions used. A noticeably different attitude to risk among EU countries is widely acknowledged, and highlighted in research on the subject in relation to food.[334] It would be surprising if such different approaches did not produce differences of interpretation over the application of the precautionary principle and the management of risk in general. Sir Brian Bender, the DTI Permanent Secretary, in his evidence to the Lords Economic Affairs Committee, acknowledged as much. He said, in an exchange on efforts to counter a more risk averse attitude in Brussels, "I do think, however, that we have made some progress in trying to get a more risk-based approach to EU measures and a more risk-based approach to EU regulations, but we still have a long way to go."[335] This certainly accords with our impressions on a visit to Brussels to discuss our MRI case study, where we found less willingness to recognise the administrative burdens and adverse effects of health and safety regulations than tends to be the case in the UK. The tension between a more stringent precautionary approach and a desire for lighter regulation was also very evident in Brussels during the negotiations over the REACH proposals for the regulation of chemicals.[336]

CONCLUSIONS ON PRECAUTIONARY PRINCIPLE
"One cannot change all this in a moment […] but from time to time one can even, if one jeers loudly enough, send some worn-out and useless phrase into the dustbin, where it belongs." - George Orwell

165. The Government CSA was not convinced of the chances or even the desirability of undertaking further work to define a precautionary principle for use in policy making and, as necessary, by the courts. Such an exercise would be "seeking clarity where clarity may be very difficult to give", in view of the scope for subjective interpretation of the precautionary principle. He said that "I think the only answer to this is to look at the detailed scientific analysis".[337] These views go some way to explaining why the work undertaken by ILGRA on the precautionary principle has not been followed up. In our MRI case study Report, we recommended that, pending further work on its definition and application, the term precautionary principle should not be used in order to explain policy decisions or judgments.[338] In its Reply, the Government maintained that the precautionary principle "is valuable in dealing with uncertainty", although it went on to make clear that, in practice, the principle is "interpreted as a flexible precautionary approach" which should be adopted alongside other research and monitoring and that "highly restrictive or expensive precautionary interventions should be reviewed on a regular basis in the light of research findings and new data."[339] This approach to practical application appears wholly sensible, but does not support the case for the retention of a precautionary principle.

166. On the basis of the evidence we have received, and not least the implications of the views from the GCSA and the Head of the Government Economic Service, we can confirm our initial view that the term "precautionary principle" should not be used, and recommend that it cease to be included in policy guidance. However, we do see value in further work which seeks to clarify the terms and correct application of a precautionary approach as set out helpfully by the GCSA. In our view, the terms "precautionary principle" and "precautionary approach" in isolation from any such clarification have been the subject of such confusion and different interpretations as to be devalued and of little practical help, particularly in public debate. Indeed, without such clarification and explanation, to elevate the precautionary approach or principle to a scientific methodology, which can be proved or disproved to have been applied in any particular case, is both unrealistic and impractical. It also provides ammunition for those seeking to promote an overly cautious approach to innovation or exposure to any risk at all. We believe that it is best to use the term precautionary approach, but with a consistent explanation of the degree and nature of the risks, benefits and uncertainty and an explanation of the concept of proportionality. It should never be considered a substitute for thorough risk analysis which is always required when the science is uncertain and the risks are serious. It should not be used, in itself, to explain a decision or course of action. The key point is that any action is proportionate, and this requires judgment based on the best available scientific evidence. Decision makers have to make such judgments on a case by case basis and they should communicate effectively the rationale for their decisions. We believe that further work should also focus on the practical application of risk management theories in circumstances of scientific uncertainty and the effective communication of the decision making process.

167. The term precautionary principle is in current use in other jurisdictions, including the EU, so it can not simply be wished away. However, both the Government's current use of the term precautionary approach rather than principle and the further work we are recommending to properly clarify, constrain and apply a precautionary approach is something that we recommend the Government invite the EU and other countries to consider and adopt.

Risk and communication

168. A series of recent major controversies, including BSE, foot and mouth disease and GM crops, has helped focus attention in Government on the importance of public communication of risk. Other drivers that have been identified include: the pace of scientific change, which has presented uncertainties (e.g. nanotechnology); growing distrust by some of the public of some institutions; easier access to a wide range of information sources; and, not least, the Government's discussion of evidence based policy making.[340] The Government has also established the need for more openness about the nature of risks, greater transparency in the decision-making process and the greater engagement of the public in risk management.[341] All these factors have a bearing on the way in which the Government communicates about risks.

CURRENT PRACTICE

169. Current Government work on risk communication builds on the studies undertaken under the auspices of ILGRA in the 1990s. It commissioned research on the nature of risk communication in Government and identified some of the pitfalls of public communication. The Health and Safety Executive (HSE) combined with a number of departments in 1997 to develop a set of generic principles for Government risk communications as guidance for officials. These were further refined and published by the Cabinet Office's Better Regulation Unit in 1998.[342] Since then some departments have developed their own guidelines on risk communication. The Department of Health guidance, Communicating about risks to public health: pointers to good practice, published in 1998 is probably the most comprehensive departmental guidance and is widely referred to in other Government material on risk. Much of this guidance has been brought together by the Cabinet Office in its comprehensive set of guidance, Communicating risk, available on the UK resilience website.[343] These guidelines reflect a general move in communication strategy from a top-down information dissemination model to a more two-way participatory approach which seeks to engage stakeholders and the public at an early stage. The guidelines are intended to be a toolkit to use in developing a communication strategy, providing advice on handling the media and engaging the public. They do not set out to provide detailed guidance to cover every aspect of risk communication, but are a source of information on best practice, drawing on experience, for use by those engaged in policy making and communication.

170. The guidelines build upon the five principles of risk management, listed in paragraph 149. Openness and transparency are key messages:

"Government will make available its assessments of risks that affect the public, how it has reached its decisions, and how it will handle the risk. It will also do so where the development of new policies poses a potential risk to the public. When information has to be kept private, or where the approach departs from existing practice, it will explain why. Where facts are uncertain or unknown, Government will seek to make clear what the gaps in its knowledge are. It will be open about where it has made mistakes, and what it is doing to rectify them." [344]

Detailed guidance is given on understanding public reactions to risk, handling the media, presenting statistics and many other aspects of risk communication.

171. In evidence to us, Government witnesses stressed the importance of making information about risks widely available to the public. The Secretary of State for Trade and Industry told us that "We can do better but the best way of communicating to the public is to put as many facts as we can in the public domain."[345] Other Government witnesses acknowledged the scope for improving performance on the communication of risk. The Chief Government Social Researcher told us that "we are still learning how to communicate risk" and that "It is an area that we need to do more work on and I think that is recognised".[346] The GCSA, Sir David King, cited the example of the impact of some of the media coverage of the MMR vaccine and the subsequent outbreaks of measles: "Clearly, communication breakdown occurred".[347] The Home Office DCSA, Professor Wiles, talked of the "constant struggle" to try to improve understanding of risk and probability, particularly against a background of what he identified as "a weak scientific and numeracy culture in this country".[348] We welcome the public commitment to transparency in the handling of risk in policy guidance and the recognition by Chief Scientific Advisers of the need to improve public communication on risk.

172. We have been generally impressed by the approach to communication adopted by the FSA. It has made clear and open communication a feature of delivering its aim to restore confidence in the way decisions on food safety are handled. It has been open and consultative in its communications. Its website provides a huge amount of information for the interested consumer to help take decisions on the basis of available scientific evidence. Its innovative approach to transparency has included open board meetings and extensive public engagement activities. The 2005 Dean Review of the FSA was a thorough assessment of its performance since its establishment in 1999 and concluded that stakeholders were generally of the view that the organisation had delivered on its aims to be open, transparent, put the consumer first, and to be independent.[349] The current Chair, Dame Deirdre Hutton, put the Agency's good reputation down to "a combination of good science and absolute transparency".[350] However, it remains to be seen whether there will be a conflict between sound science and a wish to put the opinion or the confidence of "the consumer first".

173. An example of the Agency's innovative approach to communication is its promotion of a voluntary traffic light system of food labelling for processed food. This is a commendable attempt to help those who wish to do so to choose a healthier diet. It has been criticised for being a fairly blunt instrument, in that it makes no distinction between, for example, different types of fats.[351] The National Consumer Council expressed concern that a range of different styles of label might confuse shoppers[352] and others, such as Associated British Foods, have made the point that it gives the impression that there are bad foods, to be avoided, rather than bad diets.[353] Of course labels may have only limited impact: Professor Ragnar Löfstedt states that "Approximately 5 per cent of the general public read warning labels, be they on pharmaceutical products or foods"[354] although there is also some evidence that the introduction of the scheme had a significant impact of sales in certain cases.[355] It is perhaps too early to judge the full impact of the introduction of what is still only a voluntary scheme and we have not focussed in detail on it.

LEADERSHIP

174. There has undoubtedly been some valuable work carried out in Government on risk communication that draws upon the lessons of the 1990s. Government and its agencies have sponsored academic research and carried out analyses of communication on specific issues, such as foot and mouth.[356] Some useful guidance has been produced and made widely available. However, risk communication is still very much for each department to take forward as it sees fit, hopefully in accordance with existing best practice. Whilst we recognise that departments will need to adapt guidelines according to the individual circumstances, this approach has potential weaknesses. It may lead to messages from different Government departments lacking consistency, and we explore below how this might be addressed. Also, the absence of true ownership of risk communication as a cross-departmental activity may hinder efforts to drive further research, evaluation and monitoring of existing practice. The current approach is one of circulating examples of best practice and encouraging departments to make use of existing research and other material. Whilst this is welcome, so far as it goes, this approach is not necessarily the best way of ensuring co-ordination and use of best practice on a practical basis. The Cabinet Office, as we have noted, has published useful guidance, but it does not seem to adopt the role of leadership on risk communication. This point echoes our concerns over the leadership of the risk programme as a whole, as outlined in paragraph 155. The Treasury has led on risk, but its focus is very much on the management of risk in Government programmes and projects rather than on risks to the public, where individual departments take the lead, supported by Cabinet Office guidance on best practice. We recommend that the Cabinet Office assume greater responsibility as the centre of excellence on risk communication within Government. It should have a leading role in collating and disseminating best practice on risk communication, commissioning further research as appropriate, in conjunction with other departments, and for monitoring performance in implementing guidelines.

THE ROLE OF DEPARTMENTAL CHIEF SCIENTIFIC ADVISERS

175. It is well established that the messenger is vital in ensuring that scientific advice is conveyed authoritatively and is believed. The GCSA's Guidelines advise that in public presentations, departments should "wherever possible consider giving experts (internal or external) a leading role in explaining their advice on a particular issue, with ministers or policy officials describing how the government's policies have been framed in the light of the advice received".[357] The Department of Health guidance notes that messages are judged first and foremost not by content but by whether the messenger is trusted.[358] The Cabinet Office guidance on Communicating Risk explores how to identify who is placed to deliver messages. This will depend upon the nature of the message and the role the Government is taking: for example, whether it is seeking to provide accurate information on which people can make a judgment or seeking to reassure the public that steps are being taken to mitigate risks. It states that:

"where the need is for information to help people make their own decisions, ministers may not be best placed to give it, because public attitude research shows that they are not always trusted. In these circumstances it may be better to use a respected independent source to give that information".[359]

The guidance recommends that a cadre of suitable people is developed and trained and that to deliver these messages:

"Full use should be made of trusted, independent parties—leading academics, NGOs, subject experts, industry bodies, doctors, professional bodies such as the Engineering Institutions and accounting and actuarial bodies …".[360]

We strongly endorse the development of alternative voices for the provision of information and advice of a technical nature. Given the issues of trust identified by research, the often instinctive reaction of departments to field a minister should be resisted.

Conveying uncertainty
"Doubt is not a pleasant condition, but certainty is absurd." - Voltaire

176. There is a strong case for using different types of spokespeople when communicating levels of scientific certainty to the public. In a weak numeracy culture, as Professor Wiles identified, and with the inevitable demands of the media and the public for clear and unequivocal judgments and advice, the communication of uncertainty in relation to scientific advice to the public represents a difficult challenge. In the MMR debate, it was the Government's failure to get across convincingly the real balance of scientific opinion on the issue which contributed to public confusion.

177. The same concerns apply to the provision of expert advice to ministers. The Environment Research Funders' Forum argued that "a particular challenge relates to the need to reflect uncertainty and differences of opinion in advice to policy [makers]".[361] The GSCA's Guidelines state that "Departments should ensure that levels of uncertainty are explicitly identified and communicated directly in plain language to decision makers".[362] The 2002 review of the FSA's scientific advisory bodies recommended that "When offering advice, committees should highlight any uncertainties, and explain how these uncertainties have been handled in reaching their final conclusions".[363] This is sound guidance for scientific advice to ministers, but also to the public. Here, existing guidance is light on how degrees of certainty should be made public. To an extent this is a matter for ministers' judgment, but further guidance on the language to be used might assist in what can be very sensitive policy areas. The dangers in conveying or implying a level of certainty that is not scientifically justified, as in the BSE crisis, can be just as damaging as allowing a very small risk to be magnified by repeated warnings and alarmist press coverage. It may be relevant to introduce the concept of peer review (as we discuss in chapter 4) in order to comment on the validity of research underpinning advice. In our view, there would be merit in the development of some common language which could be used consistently across departments to indicate the degree of certainty in advice, when there is doubt involved. In view of the research referred to below (paragraph 178), the difficulty of conveying levels of certainty accurately and convincingly, and the pressure that ministers are placed under by the media, we believe scientists, including departmental CSAs, should play a leading role in communicating to the public levels of scientific agreement, where necessary, and the degree of certainty in the scientific advice being offered. We recommend that common terminology be developed to be used consistently across Government in order to communicate these uncertainties.

178. The Cabinet Office guidelines on Communicating Risks are sensible as far as they go, although rather general. They could go further in terms of setting out in greater detail the circumstances in which the minister, DCSA or external experts should take the lead in communication. As indicated above, we would support a wider general role in public communication for the DCSAs, who are conspicuously absent in the guidance. We welcome the highly visible role GCSAs have increasingly taken in contributing to debates on scientific issues such as climate change. Overall, our impression has been that their contributions have been positive: public understanding is assisted by a well-respected scientist speaking independently and authoritatively on complex scientific issues.

179. Research on communication would support the case for greater use of independent scientific voices in public communication.[364] Opinion polls have indicated that doctors and scientists score much better than politicians and the media in terms of public trust. On scientific issues, scientists are more trusted than campaign groups, newspapers and politicians and media. Deeper questioning reveals that levels of trust vary according to the perceived source of funding for academics, with those sponsored by medical charities proving more trusted than those funded by Government and by industry.[365] We would like to see the DCSAs develop their roles to assume greater responsibility for commenting on science-related issues in public. For example, the often highly politicised debates surrounding crime statistics might benefit from the public explanation of a Government statistician or DCSA. Sir David King indicated that he and other CSAs would be happy to play a more prominent role if this would help the delivery of messages.[366] Such a development would require some public education on the role of DSCAs and the GSCA. Opinions polls indicate that Government-employed scientists are trusted less than those in universities.[367] We agree with Sir David that it is important that CSAs are not seen "(by Government or the media) as a channel for promoting Government policy".[368] We suspect that such perceptions are widespread at present and it will take some time and effort to alter them. Nonetheless, in the light of Sir David's commendable efforts in seeking to assert his independent role, we believe that the attempt is worthwhile. The need to have GCSAs, DCSAs and Government Scientific Advisory Committees perceived as independent and authoritative to aid the communication of risk and other scientific matters to the public is another reason why the steps we identify earlier in our Report to assert the independence of Government scientific advisors will pay dividends.

180. Given greater exposure, well-established independence and good performance, there is no reason why DCSAs should not be able, in time, become the trusted public voices of scientific advice and information for each department. Outside scientists could be engaged as necessary on an ad hoc basis to speak authoritatively on specific issues. Lines of responsibility would need to be drawn in order to avoid duplication or mixed messages: the GSCA might wish to focus on the many cross-departmental issues with scientific input, for example. Some media training would also need to be provided where necessary. We believe that the Government's communication strategy would benefit from the adoption of a higher public profile by departmental CSAs on policies with a strong evidence or science base. We recommend that the Government CSA explore with ministers and departmental CSAs how this might be best achieved and that the impact of this enhanced role be monitored.

ROLE OF THE MEDIA

181. The media is the main channel for communicating scientific advice and information on risk to the public. Given the very different objectives and approaches of the media and of Government, and the independence of the former, all Governments have to work very hard in most cases to ensure that they gets their message across in a manner which promotes understanding rather than confusion or even fear. It is therefore essential for there to be consistent, constructive and high level engagement.

182. In some circles the media is seen as part of the problem rather than the solution to improving public understanding of risk and scientific advice. For example, the Royal Society asserted that "the news media tend to give greatest prominence to new risks, or changes in existing risk, which can affect public perceptions and behaviour", citing the example of a "small but previously unrecognised side-effect of a preventative medicine" which is given greater coverage "than the already known greater threat to health posed by the disease the medicine is intended to prevent".[369] The Royal Society also expressed concern that in the name of balance, "the media invariably present opposing views on each side of an argument, regardless of the relative weight of support for those opinions".[370] This pattern was particularly evident in the coverage of the MMR vaccine. The general point about media interest was supported by an academic study which found that unusual hazards which pose relatively little danger occupy a disproportionate amount of media attention, whilst proven and extensive health risks, such as smoking, alcohol and obesity are not so extensively covered.[371] The risk-related stories which tend to attract media attention are well-established (see box 5) and of course reflect what is interesting or unusual more than the actual level of risk to the public involved. Box 5: Media triggers
A possible risk to public health is more likely to become a major story if the following are prominent or can readily be made to become so:
  •   Questions of blame
  •   Alleged secrets and attempted "cover-ups"
  •   "Human interest" through identifiable heroes, villains, dupes, etc. (as well
  •   as victims)
  •   Links with existing high-profile issues or personalities
  •   Conflict
  •   Signal value: the story as a portent of further ills ("What next?")
  •   Many people exposed to the risk, even if at low levels ("It could be
  •   you!")
  •   Strong visual impact (e.g. pictures of suffering)
  •   Links to sex and/or crime

Source: Communicating about risks to public health: pointers to good practice, DH, 1998

183. Food scares are particularly prone to media exaggeration, with obvious adverse commercial consequences. The approach of the FSA to managing the media is to have a "constant background briefing with them, so that when it comes to the point at which you have a real message to get out you are in a much better position to do it".[372] Similarly, the Home Office DSCA, Professor Wiles, told us of his persistent efforts to engage with crime correspondents in order to ensure that they reported crime statistics accurately and in an overall context. Whilst he had achieved some success, he told us that he had not managed to persuade the press in its coverage to reflect the socially and geographically skewed nature of crime to avoid the effect of over-estimating the risks for the majority of people.[373] The Government Response to the ID cards Report noted that the Home Office is attempting to apply what it has learnt through the communication of crime statistics to other areas such as identity card technologies. Such attempts are welcome, and are essential if a more mature public debate on risk is to be realized. Another important player in promoting well informed debate is the Science Media Centre, based in London. It performs a useful role for the media by assembling appropriate scientists to provide selected correspondents with detailed technical briefing on a whole range of topical issues with a strong scientific content. Again, there is more that it can help achieve in terms of improving media coverage. We would like to see DSCAs develop their links with the Science Media Centre and participate in appropriate briefings, as part of a drive to raise their profile, as long as political neutrality is given appropriate consideration.

184. Of course, there are limits to the influence of Government and other bodies on the nature of media coverage of science-related issues. The House of Lords Economic Affairs Committee concluded that Government could do little to change media treatment of risk-related stories, other than encouraging proportionality in the reporting of statistics and research.[374] It also criticised the Government for placing too great an emphasis at times on unsubstantiated media stories at the expense of available evidence.[375] It recommended that greater use be made, by Government and others, of the Press Complaints Commission in responding to instances in which risks to the public have been mis-represented. Furthermore, the Research Defence Society have successfully used the Advertising Standards Agency on a number of occasions to challenge scientific claims published by anti-vivisectionist organisations.[376] We agree that there is scope for a more aggressive response in these situations, but we would prefer to emphasise the importance of pro-active, long term engagement.

185. The Government has recognised the importance of engaging with the media in order to seek to promote responsible coverage of issues concerning risk. Following the 2005 General Election, the Prime Minister charged John Hutton, then a Cabinet Office Minister, with trying "to persuade the media to adopt a more balanced approach to the potential risks from scientific and technological advances". He enlisted the GSCA and the Chief Medical Officer to discuss risk analysis with the major media organisations.[377] We were concerned that following Mr Hutton's move from the Cabinet Office 2005, this initiative had lost its momentum. The Government told us that this work had been continued by the Permanent Secretary for Government Communications, Howell James, and others, who had met television news organisations to discuss risk, and other media representatives to discuss specific issues, such as avian flu.[378] Sir David King told us that he personally had continued this work and commented that following his meeting with the editorial board of the The Guardian, its coverage of science advice had improved. However, he observed that the real challenge was to see a change in the way the Daily Mail handles risk: "quite a tall call" in his words.[379] He made a distinction between his efforts to improve media coverage of risk and the more specific responses to inaccuracies or misinterpretations in Parliament and in the media. He referred to the work of the Parliamentary Office of Science and Technology (POST) in providing authoritative information to Parliament on scientific issues.[380] We would agree that POST fulfils a valuable role in informing Parliament and others but it has no responsibility for correcting misconceptions or mis-interpretations, in and outside Parliament. However, organisations like the Royal Society, other learned societies, Sense about Science and the Progress Education Trust are becoming more active in this area.

186. There is nothing in Cabinet Office or Treasury guidance on responding to inaccuracies in media coverage, nor is there a central point in Government for responding directly on scientific issues. It is up to departments to judge how to respond on a case by case basis. We do not underestimate the considerable challenge of promoting balanced and accurate coverage in the media, particularly the newspapers, of stories involving risk. The BBC has developed some guidelines on risk for reporters, but these are very much the exception rather than the rule. We welcome the Government's attempts to liaise with the media on risk communication and its recognition that there is more work to be done on this front. We recommend that the Government continue to develop a strategic and pro-active approach to engagement with the media. The work started under John Hutton should be part of a structured programme, with attention being given to learning from recent examples of coverage as well as informing coverage of current risk-related issues. Newspaper representatives should be a priority for engagement. Government guidance should encourage a more aggressive approach to correcting inaccuracies or mis-interpretations in media coverage of risk, with departmental Chief Scientific Advisers playing a leading role when appropriate (see paragraph 180).

A SCALE OF RISKS

187. In looking at the communication of risk, we explored what use could be derived from an agreed scale of risks, linking the language used by those providing information on risk to actual probabilities and to other, well understood risks. Current Government guidance provides no help on the words that might be used to communicate different levels of risk to the public. There is no process in place to ensure that if one department describes the risk of an event happening as "very small", the probability involved is broadly similar to that of a different risk described as "very small" by another department. Nor is there any explanation or guidance available for the public on what a "very small" risk actually means—one in a thousand or one in a million?—or what sort of other known risks might be similarly described.

188. The failure to provide a proper context for risks can allow a misleading impression to gain hold. A media report that the risk of something has "doubled" might lead to change in perception of risk when the risk concerned may be so minute that its doubling is not in fact of real significance. Without context, any risk at all may be seen by some as a cause for concern. In evidence, the Crop Protection Association said that "the lack of ability to say that anything is '100% without risk' is increasingly being exploited by pressure groups and campaigners".[381] Sir David King's reluctance to rely on the reference to a precautionary principle was in part due to the fear that "if we claim that we understand a principle, then we could always say that there are enough unknown unknowns to prevent us ever from doing anything new from science and technology."[382] We also note that there were calls from contributors to the Dean Review of the FSA for information to be presented in a way which makes clearer the relative risk of the issue concerned.[383]

189. We believe that there is merit in a common language of risk being developed for use in communicating risks to the public. This would help serve a move toward a more mature and informed attitude to risk where it is generally recognised that most activities have some degree of risk attached to them—however minuscule—and individuals are left, wherever practicable, to make decisions for themselves about how much risk they are willing to tolerate. Debate should focus on degrees of safety rather than on the black and white view sometimes implied that something is either safe or not safe. A published scale of risks may be of considerable help to the media in reporting any new risks. For example, instead of wholesale withdrawals of food products which may be thought to present some small risk to the consumer, regulators would ensure that information on the potential risks was provided to everyone in a clear and understandable manner, and people could make up their minds whether or not to purchase.

190. The idea of a scale of risks has been circulating in academic circles for some time and indeed, there has been some support in Government for the greater use of comparisons. As long ago as 1996, the then Science Minister, Ian Taylor MP, proposed a scale of risks which would provide "a series of common situations of varying risk to which people can relate".[384] The 1998 Department of Health guidance suggests that "Given a general tendency to exaggerate the risk of rare events, comparisons may help provide a sense of perspective", although it stresses that comparisons between different types of risks need to be treated with caution.[385] The guidance includes a table providing some context for figures—for example, one in a thousand equates to one in a small town—but the model was then new and appears more illustrative than prescriptive.[386] Various models for a scale of risks have been put forward, including one cited by a previous Chief Medical Officer (see Table 1 below). Table 1 Risk of an individual dying (D) in any one year or developing an adverse response (A)
Term used Risk estimate Example
HighGreater than 1:100 A.

A.

A.

Transmission to susceptible household contacts of measles and chickenpox

Transmission of HIV from Mother to child (Europe)

Gastro-intestinal effects of antibiotics


1:1-1:2

1:6

1:10-1:20

ModerateBetween 1:100-1:1000 D.

D.

Smoking 10 cigarettes per day

All natural causes, age 40 years

1:200

1:850

LowBetween 1:1000-1:10000 D.

D.

D.

All kinds of violence and poisoning

Influenza

Accident on road

1:3300

1:5000

1:8000

Very lowBetween 1:10000-1:100000 D.

D.

D.

D.

D.

Leukaemia

Playing soccer

Accident at home

Accident at work

Homicide

1:12000

1:25000

1:26000

1:43000

1:100000

MinimalBetween 1:100000-1:1000000 D

A.

Accident on railway

Vaccination-associated polio

1:500000

1:1000000

NegligibleLess than 1:10000000 D.

D.

Hit by lightning

Release of radiation by nuclear power station

1:10000000

1:10000000

Source: On the State of the Public Health: the Annual Report of the Chief Medical Officer of the Department of Health for the Year 1995, London, HMSO, 1996, p.13

191. The accuracy and usefulness of tables like the one above is disputed. When ILGRA considered the introduction of a scale of risks it found that "ranking risks is not without pitfalls and cannot be done in an objective fashion where each risk is expressed as a single number and ranked according to its magnitude". It gives as reasons the difficulties in estimating risks accurately, accounting for public perceptions of risk and objections to comparing "apples with pears", citing the ethical issues in comparing the risks of death by sudden accident with death caused by long term exposure to asbestos. It also questions how totally different risks can be ranked—is the risk of global warming over the next fifty years worse than the loss of a number of rare species of plants?—and the difficulty in comparing voluntary risks with involuntary ones. [387]

192. Although ILGRA continued to examine the role that the subjective ranking of risks can play in this and the communication of risks, it seems that none of the work going on in Government on this has borne fruit. The Government told us that it had not developed a standardised table of risks on the grounds that "risk means different things to different people". It argued that individual risks may be taken to differ from the aggregate level of risk—for example, a driver who drives with great caution, only in daylight—and also that "people do not tend to have a very analytical approach to personal risk but rather make judgments based on the way they feel."[388] Dame Deirdre Hutton similarly argued that it was difficult to standardise risks into different categories because what is a level one risk for one person might be level three for another.[389] Research indicates that appetite for risk varies substantially from person to person, for a host of complex cultural, personal and social reasons. There are models, included in Government guidance, which categorise people into four groups for the purposes of analysing their attitudes to risk. These models help predict how the public will respond to different risks, but also emphasise the difficulty for policy makers in defining a level of risk that all will find acceptable.

193. Questions have been raised about the way in which people make decisions about risk. Dr Wadge of the FSA said that "I do not think that most of the public think in terms of ten to the minus nine or ten to the minus seven".[390] This is a valid point and serves to highlight the need to translate statistical probability into a language that is readily understandable. Another objection is that people do not base decisions on a mathematical calculation of risks: perceptions of risks are governed by a number of factors, including whether they are voluntary or involuntary, whether they are new and whether they are man-made. Research has established a number of so-called "fright factors", which cause some risks to be viewed with more alarm than others. These are summarised in box 6. These factors help explain why public responses to individual risks do not reflect a theoretical evaluation of likelihood or impact. Individual responses will also depend upon personal values, attitude to risk aversion, and of course the perceived benefit or lack of benefit entailed. The example frequently cited is that people are prepared to accept the potential risk of using mobile phones, but are much less tolerant of the lower risks presented by mobile phone masts.Box 6: "Fright Factors"
Risks are generally more worrying (and less acceptable) if perceived:
  •   to be involuntary (e.g. exposure to pollution) rather than voluntary (e.g. dangerous sports or smoking)
  •   as inequitably distributed (some benefit while others suffer the consequences)
  •   as inescapable by taking personal precautions
  •   to arise from an unfamiliar or novel source
  •   to result from man-made, rather than natural sources
  •   to cause hidden and irreversible damage, e.g. through onset of illness many years after exposure
  •   to pose some particular danger to small children or pregnant women or more generally to future generations
  •   to threaten a form of death (or illness/injury) arousing particular dread
  •   to damage identifiable rather than anonymous victims
  •   to be poorly understood by science
  •   as subject to contradictory statements from responsible sources (or, even worse, from the same source).

Source: Communicating about risks to public health: pointers to good practice, DH, 1998, p 5

194. The variation in people's appetite for or aversion to risk is well established, but the fact that people have different levels of aversion to the same risks should not be used as an argument against giving people objective information quantifying individual risks. Any scale of risks should be used for information only, not for telling people how they should respond to particular risks. Equally, the ability of people to make judgment about relative risks should not be underestimated. Most people are used to making decisions involving sometimes complex calculations of risk, whether it is deciding which shares to buy, which horse to back, which pension or mortgage to pursue or whether to travel by train or by plane. Such decisions are made using information provided combined with personal preference and judgment. More information about relative risks can only serve to improve decision making ability. A scientifically-based, indicative scale of risks has a role to play here in providing a context to assist in government communication and media liaison on risk. For example, a spokesperson could relate any new risk to the established scale, as well as providing information on how to mitigate the risk and further information about how the risk may vary among different sections of the population. This may not be possible in all circumstances: there are variables and assumptions which make precision and comparison very difficult. But, on balance, we believe that the advantages of such a scale are sufficient to outweigh the limitations. We recommend that the Government build on existing work to develop, subject to academic peer review, a scale of risks for use by all departments, as appropriate, when communicating levels of risks to the public.

CONCLUSIONS ON RISK AND PUBLIC COMMUNICATION

195. We have found that the Government has overseen some valuable work on risk in recent years and has raised the profile of risk management across departments. Our concern is that this momentum may stall as attention moves to other priorities, and we have recommended some measures to ensure that this does not happen. In particular, we believe that the Cabinet Office and departmental Chief Scientific Advisers have a greater role to play in promoting best practice in risk management and monitoring performance across departments. Communicating information on risk via the media will always be problematic, but there is scope for the Government to build on the efforts it has made so far, specifically by using departmental CSAs and outside experts where appropriate to bring a more independent flavour to public communications on risk. Finally, in view of the lack of consensus over its meaning and application, we have found little practical use for the precautionary principle. We would rather attention was focussed on delivering risk management in practice and communicating uncertainty. We have recommended that work is undertaken on promoting consistency in the use of terminology across Government, particularly when communicating to the public.


285   Speech by the Prime Minister, the Rt Hon Tony Blair, at the Institute of Public Policy Research, 26 May 2005  Back

286   Public Accounts Committee, Fifteenth Report of Session 2004-05, Managing risks to improve public services, HC 444 Back

287   Economic Affairs Committee, Fifth Report of Session 2005-06, Government Policy on the Management of Risk, HL 183-1 Back

288   http://www.hse.gov.uk/aboutus/meetings/ilgra/ Back

289   HM Treasury, The Green Book, Appraisal and Evaluation in Central Government, April 2003 Back

290   HM Treasury, The Orange Book, Management of Risk-Principles and Concepts, October 2004 Back

291   HM Treasury, Managing risks to the public: appraisal guidance, June 2005 Back

292   ILGRA, Third report, 2002, pp 4-5 Back

293   Ev 200 Back

294   Ev 201  Back

295   As above Back

296   Ev 203-4 Back

297   Ev 202; HM Treasury, Risk: good practice in government, March 2006 Back

298   See para 44 Back

299   Ev 123 Back

300   HC (2005-06) 1030, para 32 Back

301   HL (2005-06) 183-I, para 84 Back

302   Q 76 Back

303   As above Back

304   UK Interdepartmental Liaison Group on Risk Assessment, 1996 Report, http://www.hse.gov.uk/aboutus/meetings/ilgra/ Back

305   Ev 202 Back

306   As above Back

307   UNCED, 1992, http://www.unep.org/Documents.multilingual/Default.asp?DocumentID=78&ArticleID=1163 Back

308   Q 84 Back

309   Ev 139 Back

310   Q 1382 Back

311   HMT, Appraisal guidance, Annex B, http://www.hm-treasury.gov.uk/media/8AB/54/Managing_risks_to_the_public.pdf Back

312   ILGRA, The precautionary principle: policy and application, 2002 Back

313   As above Back

314   HC (2005-06) 1030, chapter 4 Back

315   Gary E Marchant and Kenneth L Mossman, Arbitrary & Capricious: The Precautionary Principle in the European Union Courts, International Policy Press, 2005, p 30 Back

316   Ragnar E. Löfstedt, Risk Communication and Management in the Twenty-First Century, International Public Management Journal, 7 (3), pp 335-346, 2004 Back

317   GM Science Review, July 2003, p 46 Back

318   Q 88 Back

319   Q 1384 Back

320   Stewart Report, para 6.16, http://www.iegmp.org.uk/documents/iegmp_6.pdf Back

321   Ev 133 Back

322   Ev 94 Back

323   Q 652 Back

324   Q 646 Back

325   Q 658 Back

326   HL (2005-06) 183-I, para 73 Back

327   Q 1054 Back

328   ILGRA, The precautionary principle: policy and application, p 2 Back

329   Ev 105 Back

330   Ev 126 Back

331   HC (2005-06) 1030, para 44 Back

332   HC (2005-06) 1030, para 49 Back

333   Q 1382 Back

334   See, for example, European Commission, Eurobarometer, Risk Issues, February 2006  Back

335   HL (2005-06) 183-II, p 25, Q 73 Back

336   Science and Technology Committee, Sixth Report of Session 2003-04, Within REACH: The EU's new chemicals strategy, HC 172-I Back

337   Q 88 Back

338   HC (2005-06) 1030, para 51 Back

339   Science and Technology Committee, Sixth Special Report of Session 2005-06, Watching the Directives: Scientific Advice on the EU Physical Agents (Electromagnetic Fields) Directive: Responses to the Committee's Fourth Report of Session 2005-06, HC 1654, p 4 Back

340   Cabinet Office, Communicating Risk, http://www.ukresilience.info/preparedness/risk/communicatingrisk.pdf, pp 8-9 Back

341   As above, p 9 Back

342   HC (2000-01) 257, Written evidence from ILGRA Risk Communication Sub-Group, section 3  Back

343   Cabinet Office, Communicating Risk, http://www.ukresilience.info/preparedness/risk/communicatingrisk.pdf Back

344   Cabinet Office, Communicating Risk, http://www.ukresilience.info/preparedness/risk/communicatingrisk.pdf, p 70 Back

345   Q 1388 Back

346   Q 80; see also Qq 1387-8 Back

347   Q 1387 Back

348   Q 1118 [Professor Wiles] Back

349   Dean Review, chapter 1, http://www.food.gov.uk/multimedia/pdfs/deanreviewfinalreport.pdf Back

350   Q 575 Back

351   "IoD urged to counter 'negative' media", The Daily Telegraph, 27 April 2006 Back

352   "Food giants dismiss official drive for traffic light warning labels", The Daily Telegraph, 10 March 2006  Back

353   "New labels send 'unhealthy' food into sales dive", Sunday Times, 23 April 2006  Back

354   "We're tangled up in warning labels", The Independent on Sunday, 22 February 2004 Back

355   "New labels send 'unhealthy' food into sales dive", Sunday Times, 23 April 2006 Back

356   See, for example, http://www.hse.gov.uk/research/crr_pdf/2001/crr01332.pdf. Further examples of research and guidelines are included at annex E of Communicating Risk, Cabinet Office Back

357   GCSA guidelines, para 24 Back

358   See, for example, DH guidance, p 3 Back

359   Communicating Risk, p 52 Back

360   As above Back

361   Ev 99 Back

362   GCSA's guidelines, para21 Back

363   http://www.food.gov.uk/multimedia/pdfs/fsa02_03_04rep.pdf Back

364   Communicating Risk, p 52 Back

365   MORI/OST; taken from speech by Sir Robert Worcester, founder of MORI, at the RAE, 26 June 2006 Back

366   Ev 203 Back

367   MORI/OST; taken from speech by Sir Robert Worcester, founder of MORI, at the RAE, 26 June 2006 Back

368   Ev 203 Back

369   Ev 106 Back

370   Ev 104 Back

371   Roger Harrabin, Anna Coote and Jessica Allen, Health in the news : Risk, reporting and media influcence, King Fund, September 2003 Back

372   Q 663 Back

373   Q 1118 [Professor Wiles] Back

374   HL (2005-05) 183-I, para 34 Back

375   HL (2005-06) 183-I, para 35 Back

376   Eg ASA, Complaints against Europeans for Medical Advancement, 7 December 2005 Back

377   Qq 81, 1387; The Monday Interview: John Hutton; Cabinet Office Minister-"The media are entitled to be sceptical but the scientific context is important", The Independent, 8 August 2005 Back

378   Ev 203 Back

379   Q 81 Back

380   Q 83 Back

381   Not published Back

382   Q 88 Back

383   Dean Review, para 3.2.3, http://www.food.gov.uk/multimedia/pdfs/deanreviewfinalreport.pdf Back

384   DTI, Press notice P96/686, 11 September 1996 Back

385   DH, Communicating about risks to public health: pointers to good practice, 1998, p 10 Back

386   As above, p 10-11 Back

387   http://www.hse.gov.uk/aboutus/meetings/ilgra/minrpt2c.htm#9, chapter 3 Back

388   Ev 139 Back

389   Q 665 Back

390   Q 663 Back


 
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