APPENDIX 5
Memorandum from The Royal Society
SUMMARY OF
KEY POINTS
— Where departmental Chief Scientific
Advisers have been appointed at a senior level from outside Government
this has led to an improvement in the use of science across Departments
and has assisted in the development of a clear strategy for science.
— We are aware that the House of Commons
Science & Technology Select Committee is seeking ideas for
case studies for the management of cross-departmental science
advice. We suggest that the Select Committee investigates the
key issues of energy supply and climate change as future case
studies.
— For nearly all the critical decisions
facing Government, the evidence base is often not as large as
one would like. In such cases a judgement has to be taken about
whether further research should be commissioned before a decision
is taken, or if decisions should be made based on the available
knowledge. As the case of climate change demonstrates, incomplete
evidence should not be used as an excuse for inaction.
1. The Royal Society welcomes the opportunity
to submit evidence to the House of Commons Science and Technology
Select Committee inquiry on scientific advice, risk and evidence.[29]
This submission has been approved by Professor David Read FRS,
Vice President and Biological Secretary, on behalf of the Council
of the Royal Society.
2. In this submission the Society responds
generally to the questions raised by the Committee, which are
used as headings throughout this document. Responses are not to
the case studies. The response draws many examples from the work
of the Department for Environment Food and Rural Affairs (Defra).
This is not necessarily because it is a poor example of the use
of science by Government but because the Society looked in detail
at this Department when producing its submission to the Office
for Science and Technology's consultation on the use of science
by Defra (Royal Society 2005a).
SOURCES AND
HANDLING OF
ADVICE
What impact are departmental Chief Scientific
Advisers having on the policy making process?
3. Where departmental Chief Scientific Advisers
(CSAs) have been appointed at a senior level from outside Government
this has led to an improvement in the use of science across Departments
and has assisted in the development of a clear strategy for science.
However, it is vital that the CSA is involved in all the key strategic
decisions within a Department.
What is the role of the Government Chief Scientific
Adviser in the policy making process and what impact has he made
to date?
4. The cross-departmental overview is a
vital aspect of Sir David King's role. His work to bring together
the departmental CSAs and raise the profile of key cross-departmental
issues (such as climate change and energy) has had positive impacts.
He also bought together key individuals from different Departments
during the 2001 foot and mouth outbreak with positive results.
5. Sir David has also made a number of positive
impacts on the policy making process to date. He instigated the
current review of the CSA's guidelines on scientific analysis
in policy making, to which the Society responded (Royal Society
2005b). The review of these guidelines aims to further enhance
the ability of Government policy makers to make better decisions.
He was also responsible for the introduction of OST's programme
of science reviews of Government Departments that was announced
in June 2003.
Are existing advisory bodies being used in a satisfactory
manner?
6. We suggest that Government Departments'
access to independent advice in science and engineering should
be based on having a panel (and in some cases panels) of independent
experts available to each Department to support their use of science.
We welcome the fact that Defra has already established a Science
Advisory Council (SAC) with a membership of highly experienced
individuals.
7. To be effective, these advisory committees
should be involved in all major policy issues involving scientific
evidence and include a number of internationally recognised scientists
(covering an appropriate range of disciplines) in addition to
other stakeholders. External advice about the membership of such
committees should be sought from learned societies and appropriate
professional bodies. The chairperson should have access to ministers
when appropriate.
8. The advisory committees can act as a
nucleus for pulling together expert ad hoc groups to address
particular issues. Their roles might involve:
— setting or advising on the scientific
questions which experts will be asked to address;
— participating in stakeholder and
public dialogue activities;
— ensuring that evidence being used
by the Department is adequately peer reviewed;
— ensuring the best advice is available
when considering breaking news and identifying appropriate reviewers;
— identifying the need to replicate
work where questions exist regarding validity of evidence;
— playing a role in evaluating departmental
use of the guidelines.
Are Government Departments establishing the right
balance between maintaining an in-house scientific capability
and accessing external advice?
9. We recognise the potentially conflicting
demands (given limited resources) of ensuring continued capacity
in particular science areas, while having the flexibility to allocate
funding to tackle urgent problems. For example, Defra has been
successful in helping to build capacity in the environmental sciences
and has created centres of excellence in universities and agencies
such as the Met Office. However in some areas Defra tends to utilise
mainly well-trusted long-established relationships with certain
research centres and research groups. A broader engagement with
the wider research community would be beneficial in terms of increasing
the number and breadth of people engaged in policy-relevant research.
Important external sources of advice include learned societies,
professional bodies, Research Councils, and universities.
10. Reciprocal exchanges between scientists
and policy makers (including those without a scientific background)
can play an important role in developing expertise within both
the Department and the wider community. Although not a reciprocal
arrangement, one of our research fellows spent time in Defra's
Europe Environment Division which was beneficial to both the Department
and the research fellow. Defra-sponsored postdoctoral fellowships
could also play a role in building capacity in key areas.
11. One of the specific situations that
has given the Royal Society, the House of Lords (House of Lords
2004) and others cause for concern in the context of ensuring
that the appropriate blend of expertise is achieved is the low
level of scientific representation on Defra's Committee on Radioactive
Waste Management (CoRWM). Defra failed to establish a committee
with adequate scientific and technical expertise to provide the
best policy advice. We welcome the fact that the CSA agreed to
examine the provision of scientific advice to CoRWM and has introduced
peer review and quality assurance into its decision making process
(Royal Society 2006).
RELATIONSHIP BETWEEN
SCIENTIFIC ADVICE
AND POLICY
DEVELOPMENT
What mechanisms are in place to ensure that policies
are based on available evidence?
12. We believe that this is an area where
improvement is required and we welcome the fact that at least
one Department has taken steps to address this. Thus Defra's new
evidence-based policy making project was initiated with the aim
of ensuring that its policies are based on a comprehensive and
foresighted understanding of the evidence (Defra 2005a).
13. The review by Godfray et al (2004)
of the randomised badger culling trial and associated epidemiological
research also raised concerns about the link between scientific
evidence and policy formulation by Defra and the scientific input
from its Independent Steering Group. The review recommended that:
— processes be put in place to ensure
that in future there is better communication between Defra policy
units and groups responsible for managing policy-relevant science
projects
— a senior figure with a scientific
background takes ownership of large science-based projects
14. In order that Departments are able to
gather all the available evidence they should access advice from
a sufficiently wide range of the best expert sources, both within
and outside Government. As indicated in the previous section important
external sources of advice include learned societies, professional
bodies, Research Councils, and universities. Departments should
also have advisory panels of independent experts. In many cases
it will be appropriate to use experts from outside the UK, not
only where there is a lack of expertise in the UK, but when an
international perspective would be beneficial. Organisations such
as the learned societies can provide a useful access to international
experts.
15. When obtaining specialist advice from
experts, it is not the diversity of opinion that should be balanced,
but the weight of opinion accorded to the various strands of scientific
advice within that diversity. 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. Departments should ensure that their selection of advisors
matches the nature of the issue and that the breadth of judgement
required is sufficiently wide to reflect the diversity of opinion
amongst experts in a balanced way.
16. An important part of ensuring quality
and relevance in their sources of advice involves making certain
that the correct terms of reference for the research are established
at the outset. This is particularly important where the outcomes
are likely to feed directly into policy decisions. The Society
was involved in the quality assurance review of a report on health
and environmental effects of waste management options commissioned
by Defra. We found that the failure to frame the study in the
context of a life cycle analysis prevented a complete comparison
of the waste management options and reduced the value of the report
to policy makers (Royal Society 2003b). Some form of expert review
of the original terms of reference might have avoided this situation.
Are Departments engaging effectively in horizon
scanning activities and how are these influencing policy?
17. For horizon-scanning exercises to be
effective it is important that the key people participate. The
key people may not always be those that traditionally engage with
Government Departments, for example the most appropriate individuals
may be international experts in a particular field but not in
receipt of research funding from the Department. Departments should
have a strategy in place to identify and engage with these people.
In terms of ensuring future participation in these types of exercises
it is important that the use made of the information received
is clearly communicated.
18. It is important to ensure that the questions
asked are not too narrow and that appropriate experts with a breadth
of judgement are selected. It is important to have mechanisms
in place for early identification of multi-disciplinary issues
which cut across Government Departments or that have an international
dimension.
19. Many Government Departments undertake
horizon scanning activities and we trust that they will evaluate
the effectiveness of these processes. We hope individual Departments'
horizon scanning will inform the work of OST's new horizon-scanning
centre. It is important that Departmental scientific advisory
committees are involved with any horizon scanning exercises that
their Departments undertake.
20. The report published by the Society
with the Royal Academy of Engineering on nanotechnology in 2004
(Royal Society-Royal Academy of Engineering 2004) highlighted
the value of identifying as early as possible new areas of science
and technology that have the potential to impact strongly on society.
We identified the need to bring together representatives of a
wide range of stakeholders to review new and emerging technologies,
to identify at the earliest possible stage areas where issues
needing Government attention may arise, and to advise on how these
might be addressed. We recommended that the work of this group
should be made public and that all stakeholders should be encouraged
to engage with the emerging issues. We hope that these recommendations
will be fully implemented by OST's new horizon scanning centre
and by the other relevant Government Departments' horizon scanning
activities.
Is Government managing scientific advice on cross-departmental
issues effectively?
21. Many issues likely to require scientific
evidence cut across Departments and will therefore require close
communication and collaboration between Departments. It is not
clear that the Government is dealing effectively with the scientific
advice on the key cross-departmental issues of energy and climate
change. We are aware that the House of Commons Science & Technology
Select Committee is seeking ideas for case studies for the management
of cross-departmental science advice. We suggest that the Select
Committee investigates the key issues of energy supply and climate
change as future case studies.
22. We recommend that OST establishes issue-based
reviews of the use of science advice in cross-departmental matters
in a similar fashion to its departmental reviews. However, we
acknowledge that resource constraints may make it difficult for
OST to conduct its ongoing programme of departmental reviews concurrently
with reviews which are issue-based.
23. Nanotechnology is a policy area in which
there has been unprecedented collaboration between Government
Departments. The Government published its response to the joint
Royal Society-Royal Academy of Engineering report Nanoscience
and nanotechnologies: opportunities and uncertainties in February
2005 (HM Government 2005a). The actions outlined in the response
are being coordinated by the Nanotechnology Issues Dialogue Group
(NIDG), which includes representatives from the Departments and
Agencies involved in implementing the response, and is chaired
by the Office of Science and Technology.
24. A number of other groups feed into the
NIDG, including the Nanotechnology Research Coordination Group
(NRCG), another cross-departmental group, chaired by Defra. The
NRCG's role is to coordinate publicly funded research into the
potential risks presented by the applications of nanotechnologies,
to provide a basis for developing an appropriate regulatory framework.
The group recently published its first research report Characterising
the potential risks posed by nanoparticles (HM Government
2005b), which describes priorities for future research based on
technical reports commissioned from external expert sources. The
report also provides information on relevant activities across
Government Departments, agencies and the research councils and
its production in itself is a valuable example of joined up thinking.
25. The Government's coordination of policy
activities surrounding nanotechnologies appears to be a good example
of the Government dealing effectively with the scientific advice
on a cross departmental issue. However, we trust that the Council
of Science and Technology's two year review of the Government
progress, to report in 2007 will evaluate the level of effectiveness
achieved in these coordinating activities in detail.
TREATMENT OF
RISK
Is risk being analysed in a consistent and appropriate
manner across Government?
26. Risk assessment is an important part
of decision making. Rapidly developing scientific knowledge should
not be confused with a corresponding increase in scientific certainty:
uncertainties in the science must be identified. There may be
some benefit from a wider adoption of some of the formalised techniques
that are available for eliciting expert opinion, especially when
dealing with issues involving quantifiable scientific evidence.
We dealt with some of these issues in our recent report on detecting
and decontaminating chemical and biological agents (Royal Society
2004). The objective of these techniques is to arrive at a "rational
consensus" given all the evidence and opinions available;
not necessarily an absolute consensus, which is likely to be impossible
to achieve in most cases.
27. For nearly all the critical decisions
facing Government, the evidence base is often not as large as
one would like. In such cases a judgement has to be taken about
whether further research should be commissioned before a decision
is taken, or if decisions should be made based on the available
knowledge. As the case of climate change demonstrates, incomplete
evidence should not be used as an excuse for inaction. Once again
independent advisory committees can provide guidance on this issue.
Has the precautionary principle been adequately
defined and is it being applied consistently and appropriately
across Government?
28. The precautionary principle has several
conflicting definitions (POST 2004), which makes it difficult
to assess whether it has been applied consistently and appropriately
across Government. The Interdepartmental Liaison Group on Risk
Assessment (ILGRA), an informal committee of senior UK policy
makers, noted that the UK Government is committed to using the
precautionary principle as it is defined in the 1992 Rio Declaration
on Environment and Development (ILGRA 2002) in preventing environmental
degradation.
29. It has been suggested that the precautionary
principle should be applied in a wide variety of situations. For
example, the Society stressed the need to act in a precautionary
manner in relation to endocrine disrupting chemicals (Royal Society
2000), marine fishery reserves (Royal Society 2003a) and in the
regulation of nanoparticles (Royal Society-Royal Academy of Engineering
2004). It is clear that the question of how and when the precautionary
principle should be applied needs to be determined on a case by
case basis.
30. For example, the Government has agreed
to help industry to reduce or remove nanoparticles and nanotubes
from waste streams and support research to overcome the technological
challenges of doing this. It has also agreed "to work with
industry to prevent the deliberate release of manufactured nanoparticles
for environmental remediation until there is sufficient evidence
that the benefits outweigh any adverse effects" (HM Government
2005a). In this case, the Government has adopted a precautionary
approach. However, since it is too soon to say whether this application
of the precautionary principle by the Government has achieved
its objectives, the Select Committee might like to revisit this
case at a later date.
How does the media treatment of risk issues impact
on the Government approach?
31. The media can have a major impact on
public reaction to risks, particularly those that are newly emerging
or newly recognised. The Government approach to risk issues needs
to take account of the importance of communication through the
media, not only to alert a large number of people quickly to new
risks, but also for the purpose of informing them of measures
to manage the risks.
32. The news media tend to give greatest
prominence to new risks, or changes in existing risk, which can
affect public perceptions and behaviour. This may make it difficult
to manage communications about larger existing threats. For instance,
evidence of a small but previously unrecognised side-effect of
a preventative medicine, such as a vaccine, may be given greater
prominence than the already known greater threat to health posed
by the disease the medicine is intended to prevent. It is important
that approaches to risk are not based solely what is given the
greatest media coverage.
33. There are numerous examples of the problems
that can occur in communication through the media. In many cases
these problems occur because only incomplete information about
a new risk can be disseminated, without supporting information
about the size of the risk or how the risk should be managed.
On the other hand, withholding information about a risk until
all associated details are available may prevent individuals affected
from taking their own steps to manage the risk.
34. Particular problems may be associated
when new risks or changes in risk are described solely in relative
terms. For instance, information that the risk of a disease occurring
is now 2 in 1,000,000 instead of 1 in 1,000,000 could be conveyed
as a 100% increase in risk. There may sometimes be a temptation
to give greater prominence to relatively large changes in risk,
rather than in terms of much smaller absolute risks, because they
are perceived to have greater "news value". This applies
to both journalists and to the "experts" who are the
source of the information. It is essential that absolute risks
are conveyed as well as relative changes in risk.
35. Problems can occur when there is a dispute
between experts over the size of a risk or of the number of people
who are exposed to it. In such cases, journalists may find it
difficult to choose between conflicting claims. Experience suggests
that in such cases, official reassurances from Government Departments
and agencies or other perceived "Establishment bodies"
may not be regarded as more reliable. In some cases, journalists
will have more faith in the opinions of individual experts, particularly
if they are perceived to be independent of any potential vested
interests, than in official statements by press officers, civil
servants or even Ministers. Further complications can occur if
a particular risk becomes the focus of a campaign.
36. "Breaking news" in the scientific
domain should also be subject to an evaluation by independent
experts. The first response to breaking news, if truly ground
breaking, should be immediate acknowledgement, accompanied by
a clear statement that a full account of the research is not available
and/or that there is no evidence of independent review, with a
commitment to rectify this situation and to seek further opinions
as soon as possible. It is important to explain the uncertainty
or lack of corroboration. In these cases it will be important
to have a mechanism for rapid peer review. Learned societies and
Research Councils can be approached as a source of peer reviewers
that can provide a rapid response. If necessary, and if of sufficient
importance, a dialogue with the authors of the breaking news and
access to the detailed evidence should be sought as part of the
evaluation by independent experts.
TRANSPARENCY, COMMUNICATION
AND PUBLIC
ENGAGEMENT
Is there sufficient transparency in the process
by which scientific advice is incorporated into policy development?
37. Publication and transparency are vital
as third parties must be able to access data and, if appropriate,
come forward with alternative interpretations. Therefore, Departments
need to have clear policies on data availability. Consequently,
we welcome the Defra accessibility commitment and the publication
scheme (Defra 2005b & c) that sets out such a policy.
38. The Freedom of Information Act 2000
coming into force on 1 January 2005 has meant that a number of
Government Departments have updated their publications schemes
(such as the Department of Trade & Industry 2002, Foreign
& Commonwealth Office 2005, and Home Office 2005), which we
also welcome. These publication schemes specify the types of information
the Department publishes, the manner in which the information
is published and whether the material is available free of charge
or on payment of a fee. However, we would recommend that Departments'
publication schemes are freely available on their websites, which
is not currently the case for all Government Departments such
as DTI.
Is publicly-funded research informing policy development
being published?
39. We note that it is important to publish
publicly-funded research that informs policy development. For
example, Defra facilitates the sharing, transfer and management
of knowledge through its open publication policy. The Defra Science
and Research Projects database lists the work it is funding and
in many cases contains links to reports or summaries of the research.
The scientific work of the five Defra science agencies is debated
in the scientific literature.
Is scientific advice being communicated effectively
to the public?
40. We acknowledge that communicating complex
scientific advice to the wider public is a difficult process,
particularly on sensitive subjects such as health-related issues.
To increase effectiveness, it is important to view communication
within the context of the broader science advice process. Three
main issues are commonly highlighted. The first concerns how the
issues that experts are asked to address are framed, particularly
to ensure they are cognisant of public concerns. The second relates
to the question of how the assessment and advice processes mutually
inform each other, particularly to ensure that debate helps to
shape the assessment and the assessment informs debate. The third
concerns uncertainty, which needs to be meaningfully represented
and communicated in the scientific advice.
41. We would welcome the Committee exploring
the extent to which these concerns are taken into account by Departments
in the development of their advice processes.
EVALUATION AND
FOLLOW-UP
Are peer review and other quality assurance mechanisms
working well?
42. The effective use of independent peer
review is a vital part of ensuring the quality of the work that
Government Departments sponsor. For example, we welcome the recent
establishment by the Defra CSA of the Science Quality and Priorities
Team, which is playing a key role in developing quality assessment
within Defra. We can find no evidence that this approach is being
taken in other Departments. Departmental scientific advisory committees
have a quality assessment role and they should ensure that the
findings of quality reviews (eg of programmes) feed into decisions
about future funding. Peer review also has an important role in
identifying gaps and opportunities for further research.
43. While it is important to include wider
stakeholder groups in establishing priorities (and in many cases
the terms of reference for research), this should not compromise
the scientific peer review, which should involve the leading experts
in the field, including international experts where appropriate.
What steps are taken to re-evaluate the evidence
base after the implementation of policy?
44. It is important to re-evaluate the evidence
base after the implementation of policy to take into account any
developments in the related science. The need for such re-evaluation
is particularly great in cases where the original decision was
based on incomplete evidence. This can be carried out as part
of a policy review undertaken (or commissioned) by the relevant
Department(s). Policy reviews should be based on, or informed
by, the most up-to-date statement of scientific opinion. External
organisations such as the learned societies can be approached
to contribute to such reviews, which will normally need to access
both national and international expertise.
January 2006
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London.
Available online at www.defra.gov.uk/science/how/evidence.htm
Defra (2005a) Access to information: Defra's accessibility
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29 The terms of reference for the Select Committee
inquiry can be found online at http://www.parliament.uk/parliamentary_committees/science_and_technology_committee/sag.cfm Back
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