APPENDIX 15
Memorandum from Cancer Research UK
1. INTRODUCTION
1.1 Cancer Research UK is the world's largest
independent cancer research organisation, with an annual research
spend of over £217 million. Cancer Research UK funds research
into all aspects of cancer from exploratory biology to clinical
trials of novel and existing drugs as well as population-based
studies and prevention research.
1.2 Scientific advice does not only include
the results of research studies published in scientific journals.
It also includes the opinion of experts and impact assessments
submitted to Government in response to consultations, or during
the development of legislation, public health, or health service
initiatives.
1.3 Cancer Research UK provides advice to
the Government and relevant Departments on the drafting of appropriate
legislation governing the regulation of medical research. Most
recently this has included clinical trials and human tissues.
We have also responded to consultations on Government initiatives
to promote science and innovation in the UK, and a new strategy
for Research and Development in the NHS.
1.4 Cancer Research UK also provides evidence
to Government on public health initiatives. We have provided extensive
data on the effects of smoking and second-hand smoke, the link
between cancer and obesity, and our experts have been closely
involved in shaping the Government's current national screening
programmes.
2. CANCER RESEARCH
UK'S POSITION
2.1 We believe that consistent principles
should apply when seeking advice on drafting legislation, developing
public health initiatives, and addressing service delivery issues.
2.2 We strongly endorse the current Office
of Science and Technology guidelines on Scientific Analysis in
Policy Making. Government departments and individual policy makers
should ensure:
— Adequate horizon scanning;
— Evaluation of current evidence, and
commissioning additional research;
— Involvement at an early stage of
all appropriate stakeholders; and
— Publication of all evidence, analysis
and appropriate papers.
2.3 Adequate horizon scanning
2.3.1 Horizon scanning is key to the appropriate
use of scientific advice. In two recent examples of European legislation,
the EU Directives on Clinical Trials and on Physical Agents, the
UK has been ineffective in horizon scanning. Both pieces of legislation
had the potential to make a significant impact on medical research.
The strong impression across the medical research community is
that the Government and its departments were either too late entering
the debate on this legislation or not adequately aware of the
potential impact of these Directives.
2.3.2 Cancer Research UK recommends evaluation
of how the UK Government undertakes horizon scanning at both the
UK and European levels, and how they might best involve all stakeholders
in such policy development.
2.4 Evaluation of current evidence and commissioning
of research
2.4.1 An essential next step following horizon
scanning is the identification of areas where the evidence base
is inadequate and should be strengthened. This is crucial to future
policy making and especially important in planning health care
and cancer services. Recent reports on shortages within radiotherapy
provision highlight the need to plan now and identify the areas
on which we need to focus in the future.
2.4.2 We would like to see the Committee
address the amount and focus of research that is undertaken within
Government departments to inform policy making. There is concern
that before we ask whether the Government uses scientific advice
appropriately we should first question whether the right research
is commissioned to give the answers policy makers need to make
their decisions.
2.5 Involvement of all appropriate stakeholders
at an early stage
2.5.1 It is essential that Government departments
access advice from a sufficiently wide range of experts, both
within and outside Government. It is important that the Government
receive a balanced view and hear from all those with an interest
in the issue. This can only be adequately achieved by finding
the right people to be involved in the process, and by ensuring
that the appropriate questions are being asked.
2.5.2 Seeking and understanding scientific
advice is not a passive process, and the Government should be
actively engaging with stakeholders in order to evaluate the weight
of their views in the argument. Discrepancies between scientific
advice and policy making have recently been evident in Government
decisions on public health initiatives.
2.5.3 We would like to see more emphasis
from the Government and their departments on transparency in the
process of obtaining and evaluating scientific advice and the
inclusion of all relevant stakeholders in this process.
2.5.4 We would also like to see the Government
develop a coherent strategy for engaging stakeholders in policy
development at the European level.
2.6 Publication of all evidence, analysis
and appropriate papers
2.6.1 The process of policy development
is still not transparent, the results of consultations, although
published, often do not bear much resemblance to the final policy.
2.6.2 Examples of this were seen in the
development of the Human Tissue Act and implementing legislation
for the European Clinical Trials Directive. Although there was
consultation at the drafting stage the published legislation showed
little evidence of being influence by the submission.
3. CASE STUDY—THE
USE OF
MRI EQUIPMENT: THE
EU PHYSICAL AGENTS
(ELECTROMAGNETIC FIELDS)
DIRECTIVE
3.1 Cancer Research UK shares the concern
of our colleagues in the research community that this Directive
could have an overly restrictive effect on both cancer treatment
and clinical research. We do not believe that the proposals for
new legislation make clear the hazard which this legislation is
hoping to prevent.
3.2 We believe that the limit levels proposed
by the Directive limiting staff working in the "switched
field" have little or no basis in scientific evidence. Medical
staff are required to work in the switched field both for interventional
procedures such as biopsy, intravascular procedures, or testing
new therapies, or for providing care to the patient.
January 2006
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