Supplementary memorandum submitted by
the Health Protection Agency (SAGE 28a)
ADDITIONAL WRITTEN SUBMISSION TO THE COMMONS
SCIENCE AND TECHNOLOGY COMMITTEE FROM THE HEALTH PROTECTION AGENCY
Following its oral evidence session on 20 October
the committee has asked the Health Protection Agency (HPA) to
submit written evidence in answer to the question:
"As the government plans for the Health
Protection Agency (HPA) to be abolished and its functions transferred
to the Department of Health (DH) under a new Public Health Service
(PHS), how do you see the HPA's role as a source of independent
scientific advice being preserved?"
1. The HPA has welcomed the Government's
proposal to improve the focus on public health through the creation
of an integrated national Public Health Service (PHS) and is looking
forward to playing an important role within it.
2. HPA is currently working with colleagues
in the Department of Health to advise on how the Secretary of
State's objectives can best be met while protecting the key strengths
of the HPA in respect of its independent expert advice and the
integrated delivery of its health protection functions.
3. HPA is pleased that the Government has
been explicit in its intention to incorporate all of HPA's health
protection remit within the new PHS as the benefits of an integrated
health protection service have been repeatedly demonstrated—for
example during the response to the Polonium 210 poisoning in London,
several flood events, and during the H1N1 flu pandemic.
4. It is not yet clear how independence
of expert evidence based advice will be preserved and accommodated
within the PHS. This is critical in terms of retaining credibility
and the trust and confidence of the public, health professionals
and others working in the field of health protection—locally,
nationally and internationally. Clearly if the integrity of advice
provision were to be eroded, or perceived to be so, then the impact
on our ability to influence, protect and improve public health
could be seriously affected (in the absence of a recognisably
independent expert source, the public could turn to other, potentially
poorly evidence based and unreliable sources of information).
5. Scientific advisory committees (soon
to become Expert Committees of the Department, on which devolved
Administrations may only have Observer status) can address some,
though not all, of the aspects of independence of advice. These
committees are an excellent way of ensuring that the evidence
base being used to inform policy on recognised issues is well
founded and balanced.
6. However, such committees are not an appropriate
means either of ensuring that expert professional advice is available
in real time in response to typical incidents (HPA responds to
1000s of these each year—many of which are local rather
than national), and nor are they a suitable mechanism to ensure
that the right topics are researched (eg when evidence of a new
problem starts to emerge). Their ability to respond rapidly and
flexibly is necessarily limited, and they do not have a budget
to direct research.
7. In addition to the need for independence
in formulating evidence based expert advice there is an important
need for this advice to be seen to be independent. The
catastrophic loss of public confidence and trust in the advice
of "government scientists" following the BSE incident
was partly because they were seen to be part of the establishment
and "not independent". This was one of the drivers behind
the establishment of the independent HPA, and its value has been
demonstrated for example by the public trust in the Agency's response
to the use of Polonium 210 radioactive poison in a public place
in London in 2006.
8. At local level our independence from
Government and local authorities has encouraged the public to
trust in our expertise on a range of environmental issues ranging
from power lines to contaminated land. For example, at present
HPA is providing health protection advice regarding the remediation
of a former chemical site in the constituency of the Secretary
of State for health. Regardless of the reality, it would be harder
to convince people of the independence of HPA's advice if we were
seen to be indistinguishable from his departmental policy advisors.
9. HPA's independence in the provision of
Healthcare Associated Infection (HCAI) surveillance outputs has
been critical in securing public confidence in Government claims
relating to trends in HCAIs—because they are based on our
independent evidence. We have also been advising Government on
the health impacts of the proposals for new nuclear power stations
at various sites around the country. In such circumstances the
importance of there being a clear distinction between the independent
advice given by the HPA and those responsible for developing Government
policy becomes obvious.
10. When the HPA's functions and staff are
transferred to the new PHS, within the Department of (Public)
Health, there is a risk that its advice will no longer be seen
to be independent of Government unless steps are taken to preserve
its independence.
11. To credibly fulfil the role of provision
of independent expert advice, particularly to the public, PHS
needs to be seen to have both a separate identity and an independent
voice, and to be able to initiate work in areas it deems of importance
to health protection. The high approval ratings enjoyed by the
equivalent organisation in the USA, the Centers for Disease Control
and Prevention (CDC) demonstrate how such a model can be made
to work within Government.
12. It must also be able to formulate and
disseminate advice promptly in emergencies, and its staff (including
Directors of Public Health) must be free to give the timely local
advice which is essential in the management of outbreaks and incidents
where the perception of independence is equally important.
Health Protection Agency
28 October 2010
| 
