REVIEW OF GUIDELINES ON THE USE OF SCIENTIFIC ADVICE IN POLICY MAKING
The Royal Society of Edinburgh is pleased to respond to Sir Robert May’s request for comments on the review of Guidelines on the use of scientific advice in policy making. The RSE is Scotland's premier learned society, comprising Fellows elected on the basis of their distinction, from the full range of academic disciplines, and from industry, commerce and the professions. The Royal Society of Edinburgh is, itself, a source of independent advice and can call upon a wide range of expertise from amongst this multi-disciplinary Fellowship. This response has been compiled with the assistance of a number of Fellows, many of whom have experience of working in a scientific advisory role.
Overall, the Society believes the Guidelines are good and admirably clear. The key point is the understanding that nothing is absolutely certain, that ‘zero risk’ can never be proven, and ministers should be conscious of the need to discuss issues of acceptable risk and balancing expected benefits against risks, with judgements made on the likelihood of a range of outcomes or possibilities.
Some of the specific questions raised in the consultation document are addressed below:
Whether the Guidelines distinguish sufficiently between the various stages in the process of formulating scientific advice, such as the collection and review of evidence, the application of expert judgement, and the imposition of value judgements.
With regard to the collection of evidence, in some circumstances it may be useful when seeking advice to specify to the advisers the format of advice sought, and wherever possible advisers should be asked to back up statements with data to be found in the scientific literature and, if not published, data which can be subjected to independent scrutiny in its full form.
The identification of advisers is also an important one and the principle that independent advice of the highest calibre should be sought is essential. However, it would also be prudent at times if advice were to be sought from identified opponents of likely government policies. This would serve to identify issues which may be overlooked by scientific advisers and which then could be met head-on, having been brought into relief by the opponents who often have different priorities and perspectives from the scientific advisers but who may, nevertheless, set the public agenda for debate of thorny issues.
The most effective advice is often that given on the basis of personal contact. Many scientists would like to do more but do not know how to go about giving unsolicited advice, which could be very important. Instead, they wait and react to government initiatives asking for comments in consultation documents. There are, however, now so many consultation documents requiring quick responses that even enthusiastic repliers are becoming disillusioned.
How the guidelines apply to the social sciences
With regard to the application of the Guidelines to the Social Sciences, the Society believes that they are broadly applicable to all forms of advice in policy making
Developments since the guidelines were published, the government's recent review of the advisory and regulatory framework for biotechnology, including any recommendations from the House of Commons ongoing inquiry into the scientific advisory system
The Society has provided responses to these reviews. In particular, the Society noted that there is a need for Government Advisory Committees to be more pro-active with advances in technology and their potential implications for people, animals, plants and the environment, in order to inform the Government of the matters on which it ought to seek advice. To a large extent, and with the notable exception of the ‘Consensus Conference’ organised by the BBSRC on GM foods, the present public alarm has arisen because of a failure to prepare the public for the new technology. In ensuring the quality and speed of advice to Government, itis equally important to ensure that the advice and available information are communicated to the public. There would be merit, therefore, in the development of public communication plans for those major areas of science that are likely to arise as areas of public concern.
The relationship between the guidelines and the Freedom of Information Act. If the Act is seen as the statutory minimum, should the guidelines go further in encouraging greater openness
The Society believes that greater freedom of information would be welcome, where this can be provided without jeopardising National Security.
With regard to other issues, as the second annual report from the Chief Scientific Advisor notes, following devolution, the Scottish Executive and the National Assembly for Wales have assumed responsibility for many aspects of science policy. It will be important that, in both Scotland and Wales, information continues to be revealed on how they are responding to the issue of scientific advice in policy making, in the future.
In responding to this review the Society would like to draw attention to the following Royal Society of Edinburgh responses which are of relevance to this subject: The Scientific Advisory System (June 1998); Review of the Framework for Overseeing Developments in Biotechnology (February 1999); The Food Standards Agency: Draft Legislation (March 1999); The Scientific Advisory System for Genetically Modified Foods (March 1999); National Scenic Areas (April 1999) and Science and Society (June 1999).
For further information, please contact the Research Officer, Dr Marc Rands