Memorandum 44
Submission from the Royal Society of Chemistry
EXECUTIVE SUMMARY
1. The RSC would like to highlight the following
points to the Select Committee:
— The RSC believes that the formation
of a Department for Science could unintentionally damage attempts
to implement the use of scientific evidence in all Government
departments. The RSC encourages increased embedding of science
throughout departments in order to support evidence-based policy-making.— The
RSC is concerned that there is insufficient scientific capacity
within Government departments to ensure that policies are developed
on the basis of sound evidence. This could be improved by the
recruitment of more scientifically-trained civil servants.
— There is a lack of transparency in the
use of evidence in policy formulation. A summary produced for
each consultation describing how the evidence was used would make
departments more accountable for their use of evidence in policy-making.
— The RSC is concerned by recent waivers
of the Haldane principle and believes that the Haldane principle
must be preserved.
— The RSC believes that regional issues
must be served with relevant regional policy, but this must be
monitored centrally to ensure consistency and quality control.
— Mechanisms of engagement should be
implemented to ensure that public opinion is proactively sought
and that informed public opinion is gauged. Increasing transparency
within the policy-making process should make it clearer that advice
from scientists is independent from Government. This will allow
Government to capitalise on the fact that scientists are trusted
by the public and raise public confidence in policy-making.
— Evidence-based policy-making requires
a regular review of the evidence that contributed to policy formation.
— The RSC is concerned that the current
structure of House of Commons Select Committees marginalises the
scrutiny of science.
INTRODUCTION
2. The RSC is the UK Professional Body for
chemical scientists and an international Learned Society for advancing
the chemical sciences. Supported by a network of over 46,000 members
worldwide and an internationally acclaimed publishing business,
our activities span education and training, conferences and science
policy, and the promotion of the chemical sciences to the public.
3. This document represents the views of the
RSC. The RSC's Royal Charter obliges it to serve the public interest
by acting in an independent advisory capacity, and we are happy
for this submission to be put into the public domain.
4. The document has been written from the
perspective of the Royal Society of Chemistry.
Whether the Cabinet Sub-Committee on Science and
Innovation and the Council for Science and Technology put science
and engineering at the heart of policy-making and whether there
should be a Department for Science
5. Policy-making should be based on sound
evidence and science and engineering play a vital role in contributing
evidence. Although infrastructure such as the Cabinet Sub-Committee
on Science and Innovation and the Council for Science and Technology
exist to enable the use of science in policy-making, there are
cases where policy-making is still based on opinion rather than
on scientific evidence. This suggests that the current infrastructure
is not effective at integrating science and engineering into policy
making. It is difficult to gauge what weight an advisory board
such as the Council for Science and Technology actually has on
policy-making, but the RSC believes that the influence of the
Council for Science and Technology and other advisory bodies may
be restricted by the limited scientific capacity of Government
departments.
6. The RSC believes that an unintended consequence
of the formation of a Department for Science could be to damage
attempts to integrate the use of scientific evidence in all Government
departments. Formation of such a department risks marginalising
science such that other departments do not feel that it is necessary
to consider science when making policy decisions. The RSC encourages
the further embedding of science throughout departments in order
to support policy-making. DIUS already has sufficient remit to
support policy-making relating to scientific research.
How Government formulates science and engineering
policy (strengths and weaknesses of the current system)
7. With a view to the use of science in
the formulation of policy, the RSC commends the appointment of
Chief Scientific Advisers to some departments that use science-based
policy-making and we would like to see the embedding of science
extended to all Government departments. The appointment of Chief
Scientific Advisers is one example that suggests that the Government
does recognise the value of science and engineering in policy-making.
However, evidence-based policy-making is not always implemented
in practice. The RSC is concerned that there is insufficient scientific
capacity within Government departments to ensure that relevant
policies are developed on the basis of sound scientific evidence.
Although advice may often be gathered from external sources it
is necessary to have sufficient expertise within departments to
act as an "intelligent customer".[174]
Whilst the RSC supports training to raise the scientific literacy
of civil servants and MPs, we believe that this is no replacement
for the recruitment of more scientifically-trained civil servants.
This would raise the scientific capacity of departments to integrate
scientific knowledge in support of evidence-based policy-making.
8. With regard to the formulation of policy to
support research in science and engineering there is a concern
that Government is influencing research by applying pressure through
the directed distribution of the research budget. This point will
be discussed further in relation to the Haldane principle.
Whether the views of the science and engineering
community are, or should be, central to the formulation of government
policy, and how the success of any consultation is assessed
9. Science and engineering should be central
to evidence-based policy-making and although there are structures
in place to gather evidence it is not always clear whether evidence
is used appropriately. Evidence gathering for consultations is
transparent, but it is not always clear how this evidence is used
in policy formulation. This makes it difficult to assess the effectiveness
of the consultation process. The approach adopted by some Environment
Agency consultations is to produce a document that outlines the
responses received, including arguments as to why some comments
are being rejected. We would like to see this model adopted across
departments to make the decision making process more transparent.
This would make departments more accountable for their use of
evidence in policy-making.
The case for a regional science policy (versus
national science policy) and whether the Haldane principle needs
updating
10. The Government necessarily directs research
at an overarching level by setting the research budget. However,
the RSC agrees with the conclusion of the IUSS inquiry into the
Science Budget Allocations in April 2008 that the Haldane
principle has recently been compromised, for example the establishment
of numerous cross research council initiatives that dictate how
the budget is spent. The RSC is concerned by these breaches and
believes that the Haldane principle, that scientists should determine
how research funds are spent, must be preserved. In the case of
fundamental research, scientists remain in the best position to
determine the detailed research agenda through the established
method of peer review.
11. The Haldane Principle is important to protect
areas of research that are viewed to be of low strategic or economic
value at a given time. Insulating research from these pressures
will ensure that the UK retains a robust science base, which is
important when prevailing scientific priorities change. The RSC
is also aware that scientific activity is well served by diversity
throughout the "supply chain" from fundamental research
through to applied technologies. Maintaining this diversity will
ensure a continued flow of scientific knowledge that benefits
the economy. Applied areas of research must necessarily be driven
by economic factors in addition to policy. This type of research
therefore requires a different approach to fundamental research
in order to promote diversity in science, but need not compromise
the Haldane principle.
12. Evidence-based policy-making should
be applied in all cases, throughout central Government, the devolved
authorities and the Regional Development Agencies (RDAs).
13. There needs to be a balance struck between
national and regional policy, in order to utilise regional strengths
and promote development. The RSC believes that regional issues
must be served with relevant regional policy, for example to support
the needs of specific industry sectors, which tend to be regionally
focussed. The RDAs have improved the implementation of regional
policy. However, RDAs must be accountable for their policies and
regional policy should be monitored centrally to ensure consistency
and quality control. For example, currently in the South East
of England chemical-based companies are not supported by explicit
RDA science strategy, despite the fact that many of the UK's chemical-based
companies are based in this region. This contrasts strongly with
other regions, for example the Northwest, where initiatives such
as Chemicals Northwest are in place to support these companies.
Issues previously raised about scientific expertise in the civil
service are also applicable to the RDAs and we are concerned that
within the unelected RDAs there is no requirement to reach a basic
level of scientific capacity. The RSC would like to see measures
introduced to ensure a consistently high level of scientific literacy
within RDAs, for example, with the introduction of Senior Scientific
Advisers to mirror those in Government departments.
Engaging the public and increasing public confidence
in science and engineering policy
14. A balance must be achieved between the
use of evidence in policy-making and public opinion. Public opinion
must be sought, especially regarding ethical issues, but policy-making
should never be based on public opinion alone. Mechanisms of engagement
should be implemented to ensure that public opinion is proactively
sought and that informed public opinion is gauged, for example
using citizen's juries. The role of public engagement in policy
making is discussed further in the RSC response to the DIUS A
Vision for Science and Society consultation.[175]
15. A recent DIUS/RCUK report suggested that
scientists are generally trusted by the public.[176]
However, this trust is compromised if scientists are perceived
as being dependent on Government. The RSC suggests that increasing
transparency within the decision making process should make it
clearer that scientists who advise Government are acting with
integrity and remain independent of Government. This should allow
Government to capitalise on the fact that scientists are trusted
by the public, thus raising public confidence in policy-making
that involves science.
The role of GO-Science, DIUS and other Government
departments, charities, learned societies, Regional Development
Agencies, industry and other stakeholders in determining UK science
and engineering policy
16. The way in which decisions are made
is not transparent and it is difficult to establish the role of
these different stakeholders in science policy-making. It often
appears that policy-making attempts to reconcile extreme viewpoints,
whilst neglecting the more moderate ground upheld by some stakeholders,
including learned societies. The scientific capability of learned
societies should be tapped and the contacts and honest broker
status of learned societies such as the RSC should be capitalised
upon by Government, for example by reference to their publications
and for direction to experts in particular fields.
17. Improving both transparency in the decision
making process and the scientific literacy of Government departments
should enhance the contributions that various stakeholders are
able to make in advising on science and engineering policy.
How government science and engineering policy
should be scrutinised
18. Evidence-based policy-making requires
a regular review of the evidence that contributed to policy formulation.
This acknowledges the fact that scientific evidence changes over
time, for example as techniques and understanding improve, and
that policy must keep up-to-date with changes in the evidence
base. The RSC is not aware of much, if any, post hoc examination
of decisions taken. It is not practical for policy to be under
continual review, but we recommend procedures are put in place
for the regular review of all evidence-based policies, a point
discussed further in the RSC submission on Scientific Advice,
Risk and Evidence. This should not exclude the possibility
that horizon scanning activities may identify policy areas that
need to be reviewed, for example due to a rapid change in scientific
opinion.
19. The RSC is most concerned that the current
structure of House of Commons Select Committees marginalises the
scrutiny of science. By incorporating science into the remit of
the IUSS Select Committee there is a risk that scrutiny will only
be applied to policy made by DIUS. For science to be effectively
integrated throughout Government it is essential that a mechanism
exists to scrutinise all science-based policy decisions, whatever
their home department. We would prefer to see a more inclusive
scrutiny mechanism that clearly applies to all departments, for
example through the reinstatement of the House of Commons Science
and Technology Select Committee, with a remit to scrutinise science
and science-based policy across Government. This solution is probably
easier and more efficient to implement than the alternative of
scrutinising science-based policy by each of the separate committees,
since it will allow a concentration of expertise supporting the
committee. Whatever the mechanism in place for scrutiny it is
important that this task is taken seriously and with commitment.
January 2009
174 Royal Society of Chemistry submission to the House
of Commons Science and Technology Committee on Scientific Advice,
Risk and Evidence: How Government handles them. Paragraphs 7&8.
Available from
http://www.rsc.org/ScienceAndTechnology/Policy/Documents/2006/ScientificAdviceHandled.asp Back
175
Royal Society of Chemistry submission to DIUS on A vision for
Science and Society: a consultation on developing a new strategy
for the UK. Question 2: A society excited by and valuing science. Back
176
Public Attitudes to Science 2008. Sections 3.84-3.91. Back
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