Radioactive Waste Management: a further update - Science and Technology Committee Contents

CHAPTER 3: CORWM's working practices

The importance of evidence-based reports

33.  CoRWM described to us how its reports scrutinising the MRWS programme were produced following extensive evidence gathering and stakeholder engagement (Q 31). Lord Hunt, recognising the quality of CoRWM's reports, told us that CoRWM had to ensure its reports continued to be evidence-based if it was to "retain the respect that it has built up over the past few years" (Q 67); similarly, DECC said that the Committee needed "to analyse and assess views and bring forward advice that is clearly evidence-based if its words are to carry weight" (p 20). The NDA also noted the importance of ensuring that CoRWM's work continues to be based on comprehensive evidence gathering and stakeholder engagement (p 24). We commend CoRWM's rigorous approach to evidence gathering and stakeholder engagement in its published reports to date.

34.  Whereas CoRWM's formal reports to Government are subject to this rigorous process, the NDA suggested that when CoRWM published draft materials or working papers "there have been instances where its evidence base does not seem to have been tested with relevant stakeholders prior to publication. On occasions, unsupported assertions and a few factual errors have been presented. As well as impacting on the quality of CoRWM's deliberations this can also misinform stakeholders" (p 24). The NIA also noted that CoRWM's "operating method of producing papers—often written only by one member—for debate in plenary sessions sometimes leads to preliminary views being interpreted as formal CoRWM positions" (p 42).

35.  Professor Pickard told us: "I am very confident that our final authoritative, formal reports to Government which give recommendations to Government are solidly evidence-based" (Q 28). He conceded, however, that CoRWM expose their "preliminary thinking" and their "preliminary drafts of reports at a very early stage", since its members wanted to "give people every opportunity to see how we are developing our formal advice" (Q 28). He felt that "it is a price that we have to pay for openness and transparency that occasionally we do have to show our preliminary workings" (Q 54). He stressed that draft documents published by CoRWM have "a leading paragraph which explains quite precisely that this is a document in [the] process of development and it should not be taken to present either the views of the Committee or the views of the individual that actually wrote it" (Q 54).

36.  We believe that the same high standard which is applied in developing CoRWM's formal advice to Government should apply to all documents published by CoRWM. While we commend CoRWM's commitment to transparency, extreme caution should be taken to ensure that its working papers are not published until it is satisfied they are accurate and evidence-based.

Expertise of CoRWM members

37.  Two concerns were raised by witnesses about the range of skills possessed by the current membership of CoRWM: first, that it had insufficient geoscience expertise and, secondly, that it would benefit from additional members with practical knowledge of business, operations and engineering.

38.  The Geological Society felt that "as currently constituted, CoRWM does not have the range of geoscientific expertise required effectively to scrutinise" the geoscience that will be carried out as the MRWS programme develops (p 38). In response, Professor Pickard said that "there is adequate representation of the different disciplines" on CoRWM, and that "geological sciences are adequately represented at the moment" (Q 36), a view shared by DECC (p 21) and also by Greenpeace which stated that "CoRWM appears to have sufficient scientific and technical expertise to meet its remit" (p 40). DECC however assured us that the skill set of the Committee "will be kept under review and can be revisited in future" as the MRWS programme proceeds (p 21). CoRWM also has the power to co-opt additional members, and Professor Pickard said that he "would not hesitate" if he "felt it was necessary" (Q 36).

39.  The Environment Agency suggested that "the makeup of the Committee is largely from the academic community. Because of this, the Committee might benefit from additional membership that has an in-depth practical knowledge of operations and engineering on nuclear sites" (p 37). On the same theme, the NDA commented that although "the current membership provides for a wide range of scientific and technical expertise ... in some areas that expertise is drawn heavily from members with an academic or research background". It felt that, on occasion, this led to an "emphasis on acquisition of knowledge driven by curiosity", rather than being "driven by the needs of the [MRWS] programme" (p 24). Although Professor Pickard told us that CoRWM had sufficient "knowledge of the nuclear industry" (Q 36), we find these arguments have some weight.

40.  We believe that, at present, the membership of CoRWM includes an appropriate range of geoscience expertise to enable it to scrutinise effectively the current stage of the MRWS programme. However, we take the view that CoRWM would benefit from more members with experience of business and practical on-site operations and engineering on the main Committee, and we recommend that the Government and CoRWM arrange for this additional expertise to be recruited at an early stage. More generally, we welcome the Government's commitment to keep the Committee's skill set under review as the MRWS programme progresses.

CoRWM's work programme

41.  Each year, CoRWM agrees a three-year rolling work programme with all its sponsor ministers (p 22). Several witnesses expressed concern over the scope of CoRWM's past and proposed work programmes. The Environment Agency, for example, told us that "during the past year, the Committee's work programme may have been rather broad", and suggested it "focus on matters which are vital to the effective and safe management of the [radioactive] wastes" (p 37). Likewise, the Geological Society felt that CoRWM's "proposed [work] programme [for 2010-2013] is very broad, lacks a clear focus and runs the risk that the Committee will be too thinly spread"; the Society advised that it should focus on areas where it has "the potential to add real value" (p 38). The NIA also suggested that CoRWM "could be more effective if its work were more focused on specific topics, relevant to the stage the Government has reached with its MRWS programme" (p 42). Both the NDA and the Environmental Agency noted that CoRWM should be careful that its work did not overlap that of relevant regulatory agencies (pp 37, 25).

42.  In response, Professor Pickard explained that CoRWM starts developing its future work programme by considering a wide range of potential issues, but then it goes "through an extremely lengthy iterative process of trying to focus down on which items need to be looked at" (Q 24). He argued that this process was necessary "to be inclusive and to win the confidence of all stakeholders and the general public in particular" so that they see "that we are aware of all the different issues" (Q 25). He stressed, however, that "we are also continuously consulting with our sponsors ... they will feed in very critical information about the timeliness of that advice that they would like to see" (Q 24).

43.  There are clearly some misgivings that CoRWM's work programme may spread its scrutiny and resources too widely. We recommend that CoRWM ensures its future work programmes are focused on specific issues relevant to the current stage of the MRWS programme.


44.  CoRWM's scrutiny role is important, both in holding the Government to account and in maintaining public trust and confidence. We have noted (in paragraph 41 above) that CoRWM has to agree its work programme "with all sponsor ministers annually" (p 22). While we agree that CoRWM should work closely with Government when setting its work programme, and that the Government should be able to request advice from CoRWM where appropriate, we do not believe that the Government should be able to determine what topics an independent scrutiny body should examine. It is vital that stakeholders and the wider public can see clearly that CoRWM is independent, and we believe that this is necessary to ensure that high quality members from business and practical backgrounds, as we conclude are needed in paragraph 40, are not discouraged from joining. We recommend that CoRWM should be free to set its work programme and that it should not be subject to the agreement of sponsoring ministers, although ministers should continue to be able to request advice from CoRWM on specific topics as necessary.


45.  The NIA were concerned that CoRWM might re-scrutinise its own policy decisions, and suggested that "there is a danger in re-opening issues ... For example, we think that opening the issue of borehole disposal again is neither helpful nor productive" (p 43). CoRWM told us they felt it was necessary to encourage Government to keep different technological options open during the MRWS programme. According to Professor Pickard, "we do find that implementers tend initially to be resistant to our encouragement to keep options open ... because they themselves only have a limited resource". He continued, "the Committee is at pains constantly to encourage implementers not to burn alternative boats in terms of design and engineering solutions until they really have to" (Q 55). CoRWM clarified that its advice to "keep options open" referred to alternatives "within geological disposal, not alternatives to geological disposal" (pp 17-18).

46.  We feel it is appropriate for CoRWM to keep a watching brief on technological alternatives to design and engineering solutions within the context of a geological disposal programme, so that it can advise the Government in the event of the evidence base underlying Government policies changing.

Social and ethical expertise

47.  According to Greenpeace, "social and ethical matters will become an increasing part of the discussion on MRWS processes on legacy waste"; they suggested, therefore, that CoRWM should either recruit or co-opt members with expertise in these fields (p 40). Professor Pickard said that CoRWM would not "embark on a large philosophical study of the broader aspects of societal and ethical issues" but that it might consider such matters where "they are clearly identified to be influencing the success of the implementation process" (Q 46). However, when Lord Hunt was asked whether CoRWM should comment on social and political issues, he replied that "in the end it [CoRWM] plays a very important role in terms of technical advice as to how policy can best be carried out" (Q 109).

48.  While ministers have the ultimate responsibility for weighing the broad social issues of government policy, we recognise that there may be circumstances where such matters have a material impact on the implementation of the MRWS programme. In these situations it may be appropriate for CoRWM to comment. However, we take the view that CoRWM should primarily concentrate on providing evidence-based comment on technical issues.

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