With the scrapping of the position of EU chief scientific adviser, NGOs have drafted a list of principles of good scientific advice
EXCERPT: Respect the role of science in the policy process: “on tap, but not on top”. There is an important position for science in advisory processes, but science on its own may be able to do little to determine the right course of action, particularly in contentious debates where there is high scientific uncertainty and/or disagreement about desired outcomes, and where societal considerations are prominent.
1. How to improve scientific advice to the European Commission?
2. Principles for transparency, excellence, and independence in scientific advice to the European Commission
1. How to improve scientific advice to the European Commission? Principles for transparency, excellence, and independence
Corporate Europe Observatory, November 19th 2014
http://www.corporateeurope.org/power-lobbies/2014/11/how-improve-scientific-advice-european-commission
The position of Chief Scientific Adviser to the President of the European Commission has been discontinued, and the Juncker Commission says it is now reflecting on how to organise independent scientific advice. This is a crucial issue and, together with many other NGOs, we sent a list of principles to the Commission on how to, in our opinion, try to best do this.
Science is a vitally important tool in government policy. In some cases science can give very clear answers, in others there is uncertainty. Recognising the wider societal questions and context when taking decisions, policymakers need to be given clear, balanced, authoritative views on the state of the science.
Last summer, a coalition of NGOs including CEO wrote to Jean-Claude Juncker, then President-elect of the European Commission, to ask him to scrap the position of Chief Scientific Adviser to the President of the European Commission (CSA). We considered this position actually weakened rather than improved the quality and reliability of scientific advice provided to the European Commission. The position combined:
- institutional weakness - only one individual and a small team
- a strong political position - the symbolic power of the title "EU Science Chief" (the name of the CSA's twitter account) and direct access to the most senior decision-makers in the European Commission
- a gigantic mandate - "any aspect of science, technology and innovation as requested by the President of the European Commission" as well as a "science ambassador" role in the EU
Crucially, this mandate made the role overlap with all existing EU structures in place for gathering and assessing scientific evidence and producing risk assessment, risking to compete with and undermine the scientific work of the Commission's various DGs, the JRC, EU agencies etc. all the more that the coordination between these institutions and the CSA has been very poor.
In Prof Glover's words, she has been a "constant target for lobbying". For those who want to get round scientific assessment, it is much easier indeed to try to influence an individual than an institution. There are convincing examples showing such lobbying has not been fruitless, for instance on the very sensitive issue of endocrine disruptors. We do not believe it is a coincidence that big business groups are lobbying to keep the post and expanding its powers but not to expand the resources available to it.
The NGO letter was however met with very strongly worded responses particularly from UK politicians, business and science groups (the major supporter of a Chief Scientist position had been the UK government), accusing the groups of being ''anti-science'', not on the basis of the merits of different models of science advice but merely because the NGOs criticised the former CSA for her public statements on GMOs. A similarly simplistic line of thinking is now being repeated to accuse the Commission of being "anti-science" after it did not renew the position, still reflecting on the best possible institutional set-up for independent scientific advice that it had committed to.
Improving the EU's scientific advisory system is however the real issue. Not perpetuating the CSA position in its present form was a good first step but we hope the Commission follows up with positive action. We have therefore, together with several other organisations, designed a set of common principles for excellence, independence and transparency in scientific advice, which we believe could be used to improve and inform existing EU scientific advisory institutions and processes (in particular the European Commission's scientific committees and the EU's agencies) as well as any new scientific advisory structure the European Commission would want to create.
2. Principles for transparency, excellence, and independence in scientific advice to the European Commission
18 November 2014
http://corporateeurope.org/sites/default/files/attachments/principles-scientific-advice_18112014.pdf
Science is a vitally important tool in government policy. In some cases science can give very definite answers, in others there is uncertainty. Recognising the wider societal questions and context when taking decisions, policymakers need to be given clear, balanced, authoritative views on the state of the science.
General policy principles
* Involve the public and, where appropriate, policy makers in shaping the questions that scientific research might address.
* Respect the role of science in the policy process: “on tap, but not on top”. There is an important position for science in advisory processes, but science on its own may be able to do little to determine the right course of action, particularly in contentious debates where there is high scientific uncertainty and/or disagreement about desired outcomes, and where societal considerations are prominent.
* Report publicly to the decision-maker. The advice and appraisal of evidence, given directly from the advisor/advisory committee to the person or people making the decision, should be made available.
* Guarantee the independence of advice and advisers from interests affecting any decisions. Experts with interests conflicting with the public interest in the advice process at stake should remain available as hearing experts but should not actively shape the advice or opinion.
* Ensure comprehensive appraisal of all data and information relevant to the issue in question, conducted in a manner which is transparent and reproducible, with clear statement of uncertainties and knowledge gaps.
* Ensure consistency between public knowledge needs and research policy.
Practical implementation
* Explicitly delineate responsibilities, role and tasks of government science advisers in any decisions or policy process, either in their own domain or when crossing into domains of others. If taking own initiative, the relationship between potential advice and policy or political processes should be fully mapped.
* Explain publicly the reasons for policy decisions, and the role of scientific advice in the formulation of those policy decisions.
* Draw on a suitably representative and diverse range of advice sources, particularly when there is disagreement about desired outcomes and/or there is high scientific uncertainty.
* Enforce strict independence policies in EU institutions in charge of risk assessment, such as agencies.
* Publish scientific advice documents and organise an open and transparent approach to the scientific appraisal process. Publish advice, analysis/appraisal and underlying evidence immediately on delivery as well as minority opinions when they exist.
* Guarantee that there is adequate public research funding available for independent risk assessment, particularly for products where there are major gaps in available knowledge on risks.
Signatories:
Helen Lynn, Alliance for Cancer Prevention, UK
Angelo Caserta, Regional Director, BirdLife Europe
Patricia Cameron, Bund für Umwelt und Naturschutz Deutschland, Germany
Paul Whaley, Scientific Policy Adviser, Cancer Prevention and Education Society, UK
David Azoulay, Centre for International Environmental Law (CIEL)
Dr Michael Warhurst, Executive Director, CHEM Trust, UK
Martin Pigeon, Corporate Europe Observatory (CEO)
Dr Lone Mikkelsen, The Danish Ecological Council, Denmark
Claire Robinson, Earth Open Source & GM Watch, UK
Christophe Morvan, Fondation Sciences Citoyennes, France
Magda Stoczkiewicz, Director, Friends of the Earth Europe
Leonore Gewessler, Global 2000 - Friends of the Earth Austria
Dr Doug Parr, Greenpeace
Génon Jensen, Executive Director, Health & Environment Alliance (HEAL)
Martin Dermine, Pesticide Action Network - Europe
Dr Christoph Then, Testbiotech, Germany
Sascha Gabizon, Executive Director, Women in Europe for a Common Future (WECF), Germany/Netherlands/France