Appendix
Introduction
1. The Government welcomes the Committee's important
and thoughtful Report. It is pleased by the Committee's endorsement
of the work of the Office of Science and Innovation (OSI) and
of the Government Chief Scientific Adviser (GCSA), Sir David King,
since the Committee's predecessor reported in March 2002 on scientific
evidence and policy-making. In particular, the Government endorses
the Committee's positive comments on:
- progress in building a community
of Departmental Chief Scientific Advisers (DCSAs) and embedding
them more firmly in the policy-making process;
- improvements delivered for
example through Departments' Science and Innovation Strategies,
the GCSA's Science Reviews of departments and the Government's
new Horizon Scanning Centre (HSC);
- the development of the role
of Head of Scientific and Engineering Profession in Government
(working with other analytical heads of profession and promoting
Professional Skills for Government[1]
(PSG)); and
- the role of the GCSA in promoting
best practice through Codes, Guidance and the use of OSI resources
to support DCSAs.
2. At the same time, the Government agrees with the
Committee that there is much further still to go in ensuring that
science is managed and used by Government to best effect. It agrees
largely with the analysis in the Committee's Report, though in
some cases it differs on the proposed course of action. The Government
is committed to continuing to improve its use of scientific advice,
its management of risk, and its use of evidence to support policy.
3. This response contains an overview followed by
responses to the detailed recommendations. The response is structured
under themes and makes clear which of the Committee's individual
points are being responded to in each case.
4. The Government believes that many ambitions in
the report can be met through judicious revision and extension
of existing policy initiatives. Some recommendations require further
research. At the time of HM Treasury's annual report on the Science
and Innovation Investment Framework 2004-2014[2],
the Government will report on progress to the Chairman
of the Committee.
Overview
(A) IMPROVING THE IMPACT AND QUALITY OF SCIENTIFIC
ADVICE ALONGSIDE OTHER ANALYTICAL INPUTS TO EVIDENCE-BASED POLICY-MAKING
5. As the Report sets out, the Government is now
supported by a community of DCSAs that did not exist in 2002.
Their principal role is to:
- support the use of scientific
evidence in policy-making;
- ensure that their departments
are intelligent customers for science;
- promote and support the interests
of scientists and engineers in their departments;
- ensure the quality of the science
used in their departments; and
- explain science inside government
and engage with public opinion.
6. The Government welcomes the Report's recommendations
for raising further the profile and impact of DCSAs. The Government
further believes that more can be done to raise the profile and
engagement of Chairs to Scientific Advisory Committees (SACs)
in departmental policy-making processes. It also welcomes the
recommendations that contribute to improved public understanding
of the Government's use of scientific evidence. The proposed revision
of the Code of Practice for Scientific Advisory Committees[3]
(CoPSAC) will take forward many of the Report's recommendations
in this area.
7. The appointments of DCSAs have been spread over
the period since 2002, so the maturity and development of the
role differs in each department. Consequently, under the guidance
and leadership of the GCSA, good practice from the more established
DCSAs is being shared for example through networking and workshops.
This includes support for:
- closer and more integrated
working with other analytical disciplines;
- building a strong Head of Science
and Engineering Profession (HoSEP) function in the main departments
and agencies alongside the GCSA's Government HoSEP role;
- improving communication of
evidence and risk in policy making;
- embedding the use of the Government
Chief Scientific Adviser's Guidelines on Scientific Analysis
in Policy Making (2005) (GCSA Guidelines)[4];
and
- improved working with SAC secretariats.
8. OSI has run several networking events, and further
events are planned in 2007 on the use of horizon scanning in government,
scientific peer review and how to engage the scientific community
(both internal and external). OSI has also worked closely with
the National School of Government to develop the scientific element
of the 'Analysis and Use of Evidence' core skill from PSG. By
continuing this process, the Government will address many of the
Report's recommendations. The Government will also review the
induction material, the CoPSAC3 and GCSA Guidelines4
provided for DCSAs in the light of the Committee's recommendations.
9. The Government agrees with the Committee that
the work of DCSAs should be further embedded in departments in
order to ensure the good use of scientific methods at every level
of Government. There will however be differences in the position
of DCSAs in departments according to their size and responsibilities
[Recs 6, 7, 9 and 10].
10. The Government recognises the need to create
an effective structure to support the development and integration
of scientists in Government. It is seeking to deliver this through
the PSG agenda and HoSEP roles. It is not convinced that formalising
a single system across Government through a Government Scientific
Service is the right action to take now [Recs 17, 18, 19,
20, 30 and to some extent 21].
(B) MACHINERY OF GOVERNMENT
11. The location and responsibilities of the GCSA
and the Minister responsible for the management and use of science
in Government [Recs 2, 3 and 4] are a matter for
the Prime Minister and will be kept under review.
(C) THE STANDING OF SCIENCE AND SCIENTISTS IN GOVERNMENT
AND THE ROLE OF THE 'INTELLIGENT CUSTOMER' FOR R&D
12. The Report expresses concern about the status
of science and its practitioners in Government [Recs 12-21].
The Government shares some, but not all, of the Committee's concerns.
Many of the Committee's concerns are being addressed through HoSEP
and PSG. The enhanced HoSEP role for the GCSA supports greater
visibility and opportunity for scientists and engineers across
Government. The use of science and a better understanding of risk
have been built into the PSG core skills for civil servants [Rec
58].
13. Making the voice of scientific evidence heard
in a balanced way alongside other professional analytical streams
remains a challenge that is addressed through the GCSA's Guidelines
on Scientific Analysis in Policy Making (2005)4.
14. DCSAs must ensure that departments retain sufficient
scientific or analytical competence to act as 'intelligent customers',
able to know when to seek and how to use expert advice from a
variety of sources. The Government does not agree that its handling
of Public Sector Research Establishments (PSREs) need result in
a diminished 'intelligent customer' capability [Rec 13].
The current improvements in professionalism across the civil service
will complement the identification of relevant experts through
trusted sources including PSREs, Learned Societies, Research Councils,
SACs, the Council for Science and Technology and others. The contribution,
if any, of each organisation will differ with each issue, but
in every case it will be important to embed the analysis and use
of evidence skills that make it possible to ask the right questions
and translate the answers into policies [Recs 31 and
32].
15. As part of its 2007 revision of the CoPSAC, the
Government will look at how SAC secretariats obtain scientific,
legal and administrative expertise [Rec 23]—secondments
may provide part of the answer.
16. The appointment of DCSAs marks a major step towards
the better management and use of science in Government [Recs 611].
The Government welcomes the importance attached by the Committee
to the use of external expertise [Recs 2233]
to inform and challenge policies and inform the public on the
balance of evidence.
(D) ADVISORY STRUCTURES AND QUALITY ASSURANCE
17. The Government agrees that DCSAs must be actively
engaged with departmental policy-making. This will be considered
further in the 2007 review of the CoPSAC (Q1350),
which will also consider lay membership, chairmanship and scientists
operating outside their specialism. While DCSAs may not always
directly monitor advisory bodies, they should ensure that effective
monitoring happens and that appropriate changes are made in response
to monitoring [Rec 52].
18. Maintaining high standards of research is important
for all departments [Recs 26-32 and 46-49].
19. The Government agrees it is essential that there
is early engagement of DCSAs in policy development [Rec 9].
The Government believes that departmental Boards should include
the most senior departmental analyst, and that the DCSA should
have the right to advise Ministers directly on matters relating
to his or her professional judgement whether or not he or she
is on the Board.
20. The GCSA will continue to build capacity, leadership,
and quality assurance—the reviews of departments' management
and use of science provide an opportunity for more detailed intervention
where necessary [Rec 39]. The annual reviews of
departmental performance following up the Science and Innovation
Investment Framework 2004-20142 also help promote
improved quality. The GCSA regularly meets departmental Ministers
and Permanent Secretaries when issues relating to the use of scientific
evidence are raised.
21. The Government believes that the Prime Minister's
Strategy Unit's recently announced policy reviews (Pathways
to the future)[5],
the Strategy Unit's ongoing work, the newly established Civil
Service Steering Board (which supersedes the Permanent Secretary
Management Group) and the OSI's HSC are well placed to achieve
the objectives identified by the Committee on the pilot use of
peer reviews [Rec 48] and peer review of cross-government
policies [Rec 49], as well as extending good practice
across all analytical disciplines.
22. The Government agrees that it is important to
assess trials objectively. But decisions are for Ministers who
will take account of all relevant factors, not just of scientific
evidence [Rec 42].
(E) BALANCED CONVERSATIONS WITH THE PUBLIC ON THE
GOVERNMENT'S USE OF SCIENCE, RISK AND UNCERTAINTY
23. The importance of balanced conversations with
the public, identified by the Committee [Recs 37, 38,
50 and 51], extends to the treatment of 'risk' [Recs
6369]. The Government agrees that clarity is needed
in communication on risk and the balance of evidence, and that
this will sometimes point to using a chief adviser rather than
a Minister to communicate [Rec 65]. Further discussion
with the media to try to maximise public understanding is in hand
[Rec 68].
24. The Government shares the Committee's presumption
in favour of transparency of scientific evidence, including the
remaining uncertainties. The Government seeks to be as open as
possible when publishing the evidence base, particularly in explaining
policies and the balance of argument to the public, subject to
the law and necessary confidentiality recognised in the Freedom
of Information[6] (FoI)
and Data Protection[7]
(DPA) Acts (Q13881400).
25. Inputs other than evidence—for example
political judgement—will influence policy outcomes [Rec
35], this is acknowledged in the Cabinet Office publications
Modernising Government[8]
and Professional Policy Making for the 21st Century[9]
as well as in academic literature. Nevertheless, where possible,
the Government agrees that processes should be transparent and
the balance of evidence exposed. Transparency may not be possible
in reserved areas. Examples of reserved areas include advice that
precedes a final policy outcome, information accessible by other
means, information intended for future publication, security matters
and defence6.
26. The Government draws the Committee's attention
to a new work-stream led by the Cabinet Office on a Code of
Practice on Consultation[10]
that will address many of the issues raised by the Report [Recs
5457].
27. The Government welcomes the Committee's support
for the language and analysis underpinning a precautionary approach
in the business of government [Recs 6062].
However, it would be impractical and unnecessary to avoid all
use of the term 'precautionary principle' since the term is embedded
in many international agreements. In practice, the precautionary
principle is interpreted in Government as a flexible precautionary
approach, which enables innovation and learning in circumstances
of significant uncertainty, while not putting the public at unacceptable
risk.
(F) PLANNING FOR THE FUTURE
28. The Government has seen significant benefits
to policy-making arising from the OSI HSC across a range of issues
[Recs 43-45]. A valuable lesson learned as the HSC
has evolved is the importance of balance between all evidential
streams as they affect and are affected by science, technology,
economics, society, and politics. The HSC made an important contribution
to the Treasury document—Long-term opportunities and
challenges for the UK: analysis for the 2007 Comprehensive Spending
Review (November 2006).[11]
While it does not provide certainties, horizon scanning helps
policy-makers test their assumptions and identify emerging issues
that need further examination.
29. The work of the HSC will contribute to many of
the areas of risk and communication identified by the Committee's
Report [Recs 58-69].
30. The Government will continue to review as a matter
of importance whether further steps are needed to overcome barriers
to evidence-based cross-departmental working, and in doing so
will take account of the Committee's proposal for a centrally
held budget [Rec 40].
Responses to the Committee's Recommendations
Sources of advice and expertise
1. (Recommendation 1) We support the current arrangement
whereby the Government Chief Scientific Adviser's remit encompasses
the natural, physical and social sciences, as well as engineering
and technology, but we note that it is a challenge for one individual
to cover such a disparate range of subject areas and disciplines.
It is therefore vital that the Government Chief Scientific Adviser
works closely with the Government Chiefs of Profession in the
social sciences, including economics, to establish higher profiles
for these disciplines. (Paragraph 16)
Agreed. The Government Chief Scientific Adviser (GCSA)
works closely with other Heads of Profession including through
groups such as the Chief Scientific Advisers' Committee (CSAC),
the Permanent Secretary Management Group's Strategy Sub-Group
(PSMG-SSG) (whose functions will be superseded by the newly established
Civil Service Steering Board that is currently considering how
the strategy work can best inform its decision-making), and the
Analysis & Use of Evidence Working Group. In addition the
GCSA has bilateral meetings with other heads of profession.
Recommendations 2, 3, 4 and 5—Embedding
and enhancing the role of Departmental Chief Scientific Advisers
2. (Recommendation 2) We recommend that the posts
of Government Chief Scientific Adviser and Head of the Office
of Science and Innovation be separated. The Director General of
Science and Innovation at the DTI should become the new Head of
OSI. (Paragraph 18)
3. (Recommendation 3) In view of the cross-cutting
nature of science and the cross-departmental responsibilities
of the Government CSA, it would make sense for the post to be
based in a department with a similarly cross-cutting remit. (Paragraph
19)
4. (Recommendation 4) A long term solution is
required for the post of Government Chief Scientific Adviser,
not just one which happens to suit the strengths of present incumbent.
On balance, we recommend the relocation of the GCSA's office to
the Cabinet Office. In addition, the GCSA should be given a seat
on the board of the Treasury to ensure that the crucial work of
this department benefits from a scientific perspective at the
highest level. The changes we have recommended seek to strengthen
the influence and effectiveness of the GCSA. It is therefore essential
that the resources available to the GCSA to support his work do
not diminish as a result of these changes. (Paragraph 25)
5. (Recommendation 5) We are of the view that
clear leadership can be valuable for improving accountability
and providing a driver for implementation of good practice across
departments. We recommend the Government clarify the lines of
ministerial responsibility for the scientific advisory system.
For example, whilst ultimate responsibility must rest with the
Prime Minister, day-to-day responsibility might best be assumed
by the Cabinet Office led by the Government Chief Scientific Adviser.
(Paragraph 26)
The location and responsibilities of Ministerial
and GCSA posts [Recs 2, 3 and 4] are a matter
for the Prime Minister and will be kept under review.
Wherever the GCSA post is located, the Government
is committed to further embedding and enhancing its role and impact.
Recommendations 6, 7 and 8—Appointment of
DCSAs
6. (Recommendation 6) We recommend that the presumption
should be that all future departmental Chief Scientific Advisers
should be external appointments who have occupied senior positions
in their scientific community and command the respect of their
peers. (Paragraph 31)
7. (Recommendation 7) We support the use of part-time
and fixed-term contracts for departmental CSAs with the caveat
that departments must provide adequate support and resources for
these appointments. We recognise that appropriate staffing levels
will vary between departments but it seems unlikely that a DCSA
can operate effectively with just one or two officials. (Paragraph 34)
8. (Recommendation 8) We commend to other departments
the Department for Transport's model whereby an externally appointed
DCSA is supported by a senior scientist, drawn from the civil
service, who acts as both deputy CSA and Head of Profession for
Scientists and Engineers in the department. (Paragraph 35)
Departmental Chief
Scientific Advisers (DCSAs) are likely to be external appointments.
The Government agrees that DCSAs should be experienced and highly
reputable scientists who command the respect of their peers through
their scientific contributions [Rec 6]. However
it would be wrong, and could be unlawful, to rule out the possibility
that in some cases the best qualified candidate might be working,
within the civil service. The Government also agrees that it is
usually desirable that the deputy to a DCSA should have prior
experience of working in, or closely with, Government [Rec
8]. This is likely to mean that the field for Deputy DCSAs
will, in some cases, be confined to serving civil servants. The
question of who is best suited to fill the role of Head of Profession
within each department should be considered on its merits and
is likely to vary.
The Government agrees that in many cases part-time
and/or fixed term contracts will be appropriate for DCSAs. It
also accepts the importance of providing adequate resource to
support DCSAs; this will differ depending on the size, structure
and circumstances of the department [Rec 7].
Recommendations 9, 10 and 14—DCSA contributions
to policy formation
9. (Recommendation 9) The introduction of departmental
CSAs has been most welcome but they must be able to contribute
fully to strategic decision making and high level policy development
within the department if their contribution is to be maximised.
Departmental CSAs must be given the opportunity to play a full
and active and yet independent role at board level, and be in
a position to identify where their involvement is required, rather
than being brought in where others have decided that there is
a need for their input. DCSAs must be in the stream of policy
development, not watching from the bank. The misconception that
scientists in the civil service should be 'on tap, not on top'
must be laid to rest once and for all. (Paragraph 39)
10. (Recommendation 10) We acknowledge the potential
difficulty facing departmental CSAs in balancing the demands and
expectations of their permanent secretary, minister and the Government
CSA. DCSAs should report to the Secretary of State but retain
the independence necessary not to restrict their freedom to speak
out internally or publicly when required and to avoid any politicisation
of their advice. (Paragraph 40)
11. (Recommendation 14) It seems to us necessary
that all senior officials and policy makers should have a basic
understanding of the scientific method, the role and importance
of peer review, the relevance of different types of evidence,
and the way to evaluate it. (Paragraph 48)
The Government accepts the main thrust of the Committee's
analysis on these points. DCSAs should be fully and effectively
engaged in the policy-making process at all levels, and be able
to put their advice directly to departmental Boards and Ministers.
Equally, senior civil servants and policy makers need to understand
the input science can make to policy, and how that can most effectively
be achieved.
| The Forestry Commission has, since 2002, brought departmental specialists in social science, natural sciences, economics and statistics into a single Division (Corporate and Forestry Support) to improve delivery of analytical advice into policy. The same Division also deals directly with legal advisors in the Department for Environment, Food and Rural Affairs (Defra) and contains specialist advisors with direct experience of forest management.
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| MoD is a major investor in R&D in support of policy; consequently, its Chief Scientific Adviser sits on the Defence Council (chaired by the Secretary of State) and the Defence Management Board (the Executive Board of the Defence Council). They also chair the Investment Approvals Board, MoD's senior Approving Authority for investment in new defence capability, and the Defence Science and Technology Board, which directs the MoD's Research Programme.
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The Government's position is that each departmental Board should
include the department's senior analyst. That may be the DCSA
or another analyst. The senior analyst should represent all analytical
disciplines at Board level, without prejudice to the right of
other departmental Chief Advisers to put advice directly to the
Board or Ministers when they think necessary [Rec 9].
In relation to Recommendation 10, the DCSA should
normally report through the Permanent Head of Department, but
should have the right of direct access to Ministers on matters
subject to his/her professional advice.
The right of DCSAs to speak publicly and independently on matters
involving professional judgement is important, but should be exercised
carefully if the DCSA is to be a full and trusted participant
in internal policy discussions.
The Government accepts Recommendation 14, and is
asking Government-wide Heads of Profession to work with the Cabinet
Office and the National School of Government to ensure that it
is fully reflected in the development of Professional Skills for
Government (PSG)1.
12. (Recommendation 11) It is good that the Government CSA
is able to go directly to senior officials and ministers in departments
in cases where he believes his intervention is essential. In so
doing he must be careful not to undermine the position of the
relevant departmental CSA and recognise those areas in which their
expertise should hold sway. He should, wherever possible, include
the departmental CSA in his discussions with ministers and senior
officials. By the same token, we believe that departmental CSAs
should be free to publicly disagree with the Government CSA in
instances where there is, for example, a difference in their interpretation
of scientific evidence, but urge departmental CSAs and the Government
CSA to co-operate closely to deliver an active network of scientific
support and advice to every department. The scientific advisory
system will be most effective when the departmental and Government
CSAs work together collaboratively. (Paragraph 41)
Agreed in principle. The Government has asked the GCSA to lead
further discussion through CSAC of the role of DCSAs, how they
work together and, if necessary, to amend the GCSA's Guidelines
on Scientific Analysis in Policy Making4 in
the light of that discussion.
Recommendations 12, 15, 16 and 20—Development
and support for scientists within government
13. (Recommendation 12) It is worrying and regrettable
that there is a perception that not only has there been a decline
in scientific expertise within the civil service, but civil servants
perceive specialist skills to be a hindrance to career progression.
We recommend that the Government implement the 2002 recommendation
of the Cross-Cutting Review of Science and Research to maintain
records on specialist staff in order to identify their qualities
and experience and to investigate, and if necessary tackle, negative
attitudes towards scientific qualifications. (Paragraph 45)
14. (Recommendation 15) We are encouraged by the
emphasis in the Professional Skills for Government framework on
the use and analysis of evidence. A basic understanding of the
scientific method and the interpretation of different types of
evidence, together with the development of an informed demand
for scientific input and analysis amongst generalist civil servants,
particularly those at senior levels, are important prerequisites
for effective policy making. We recommend that the Government
put in place the necessary reward systems and incentives to support
its ambitions in this area. (Paragraph 51)
15. (Recommendation 16) In policy-making, scientific
literacy must be given equal value to economic knowledge and drafting
ability, while further reform of the civil service is essential
to bring about a cultural shift: specialist skills must be given
equal value to generalist skills and this should be reflected
in rewards structures. It is also essential that more opportunities
are created for scientists to progress to the most senior positions
without being required to sideline their specialist skills. (Paragraph
53)
16. (Recommendation 20) Departments must collect
comprehensive data, in a manner which is consistent and comparable
between departments, regarding the numbers of scientists and engineers
which they employ. (Paragraph 61)
The Government believes that the position of scientists
and engineers along with other professional groupings in departments
has been significantly enhanced since 2002 through the development
of the DCSA and Head of Science and Engineering Profession (HoSEP)
communities as well as through PSG. PSG will help civil service
specialists develop other relevant professional skills to progress
their careers. There is no reason why specialists should not reach
the highest levels of the service, recognising that for most senior
posts a range of non-specialist skills will also be needed [Recs
12 and 16]. There is no bias against specialists in the
reward structure.
Future work to develop the science and engineering
profession within government will promote a positive set of expectations
for scientists and engineers and build their awareness of policy
issues. This will contribute to enhancing the status and prospects
of specialists.
The use of science has been included in the PSG1
core skills of 'Analysis and Use of Evidence' and 'Policy Delivery'.
Periodic research by Government Skills[12]
(the Sector Skills Council for central Government, the Armed Forces
and Non-Departmental Public Bodies) will provide information (at
Civil Service aggregate levels) on numbers of scientists and levels
of qualifications. Government Skills also holds individual data
on science and engineering staff at Senior Civil Service (SCS)
level, but not on all civil servants [Recs 12 and 20].
From 2007, the Common Employee Record (CER) is likely
to provide data on professional categories and PSG career grouping.
At present plans for rollout of the CER does not include collecting
data on qualifications but this might be added once the CER has
been successfully implemented. This data should help achieve parity
and comparability between different departments and their scientists
and engineers in delivering wider PSG ambitions.
Departmental Heads of Profession are looking at the
most useful ways to collect and use information on the specialists
they lead, to help ensure their professional development.
17. (Recommendation 13) The Government's failure
to do enough to address the implications of the privatisation
of Public Sector Research Establishments for the scientific capacity
of the civil service has been damaging. Remedial action is now
required to redress the effect of the loss of, and restriction
of access to, expertise in establishments such as the Laboratory
of the Government Chemist, Forensic Science Service and QinetiQ.
Future plans for changing the status of such Establishments must
also take greater account of the potential detrimental impact
of these changes on the scientific advisory system supporting
Government policy making. (Paragraph 46)
The Government agrees that the implications of changes
in the status of Public Sector Research Establishments (PSREs)
for the scientific advisory system in Government need to be taken
into account, but it does not accept that these implications have
generally been ignored in the past. For example, the division
of the Defence, Evaluation and Research Agency (DERA) into QinetiQ
and the Defence Science and Technology Laboratory (DSTL) reflected
such considerations amongst others. The important factors under
any arrangements are that departments should have the capabilities
to identify, commission and use the advice they need, and that
their sources of relevant advice should be available, whether
in the public or private sector. In many cases, privatisation
has actually helped broaden the range of advice sought and used
by Government. But we fully accept that Government must be an
intelligent customer for scientific advice.
The Science and Innovation Investment Framework
2004-20142, published in July 2004, sets out the
Government's continued commitment to the sustainability of the
UK research base, including both universities and PSREs. The report
on the Government's first annual monitoring exercise on PSRE long-term
sustainability was published earlier in 2006. This report noted
that maintaining appropriate levels of staffing and skills were
an element of PSREs' long-term sustainability. PSREs will be regularly
monitored on all elements of their sustainability, including staffing,
with the results of this monitoring being reviewed by a forum
bringing together PSRE parent departments to discuss policy on
sustainability.
Recommendations 17, 18, 19, 20, 21 and 30—Creation
of and functions for a Government Scientific Service
18. (Recommendation 17) We recommend the establishment
of a Government Scientific Service. This would provide a stronger
professional identity and a focal point for specialists from across
the physical and natural sciences and engineering working within
Government. (Paragraph 56)
19. (Recommendation 18) The proposed Government
Scientific Service should take the lead in identifying good practice
in professional development for scientists and engineers, including
the use of secondments, and promoting its adoption across Government
(Paragraph 59)
20. (Recommendation 19) Determining which expertise
should be retained in-house and which sought externally is of
critical importance (Paragraph 60)
21. (Recommendation 20) Departments must collect
comprehensive data, in a manner which is consistent and comparable
between departments, regarding the numbers of scientists and engineers
which they employ. (Paragraph 61). [see paragraphs 42-47
for earlier comments on Recs 12, 16 and 20].
22. (Recommendation 21) We recommend that the
Government Chief Scientific Adviser commission a study of the
way in which departments should assess their need for scientific
skills and determine whether these needs are being met. (Paragraph
61)
23. (Recommendation 30) The efficiency measures
taken as a result of the Gershon Review have increased the Government's
dependence on consultants as sources of scientific and technical
advice. This gives cause for concern. The Government must have
sufficient expertise to ensure that it both asks the right questions
and does not become an uncritical, unquestioning consumer of the
advice it receives. We believe that improved auditing of skills
within the Government and a strong Government Scientific Service
would enable the Government to make more efficient use of the
existing expertise within the civil service and, ultimately, to
obtain better scientific advice. (Paragraph 79)
The Government recognises the issues raised in this
group of recommendations and is seeking to address them in particular
through PSG and HoSEP. It is not persuaded that a Government Scientific
Service needs to be established in order to address the Committee's
concerns, but will keep this under review [Rec 17].
Examples of relevant good practice are OSI's support
for the GCSA's HoSEP role through hosting workshops and seminars
on communication of evidence and the use of the Guidelines on
Scientific Analysis in Policy Making. OSI has also hosted networking
events on evidence and risk in policy-making and to bring together
Science Advisory Committee (SAC) Secretariats. Further events
are planned in 2007 on the use of horizon scanning in Government,
scientific peer review and how to engage the scientific community
(both internal and external). OSI has worked closely with the
National School of Government to develop the scientific element
of the 'Analysis and Use of Evidence' PSG core skill. OSI also
publishes a newsletter in support of the science and engineering
community in Government.
The Government recognises the importance of sourcing
professional expertise appropriately [Rec 19]. PSG
and the Gershon Review form integral parts of the Public Sector
reform programme [Rec 30]. The Leitch Review
of Skills[13] provides
an opportunity to refocus recruitment to ensure the Government
maintains the scientific and technical capability it needs. Government
Skills12 is about to conduct a Sector Needs Analysis
that will provide the evidence needed to develop and implement
the skills strategy for the wider civil service. This will address
any skills gaps in science and engineering, taking account of
comments from the OSI and relevant Heads of Profession.
Within that, each department will remain responsible
for determining its own preferred skills mix and ensuring it is
achieved [Rec 21].
24. (Recommendation 22) DEFRA's decision to introduce
an independent Scientific Advisory Council to support the work
of the departmental CSA is sensible and should be emulated by
other departments. It is critical that these Advisory Councils
are independent and are seen to be so. (Paragraph 68)
Accept in principle. This is a matter for individual
departments and their DCSAs in the light of their particular situations.
However the use of independent, high quality scientific advice
and challenge to departments through SACs, both in specific areas
and department-wide, are in many cases important means of helping
the DCSA carry out his or her role effectively. CSAC will review
and discuss the use of SACs across Government during 2007, to
promote best practice.
| The recent selection of eleven National Institute for Health Research (NIHR) Biomedical Research Centres demonstrates the Department of Health's ability to obtain and use high quality, external advice. An independent international Selection Panel selected the Centres through open competition, in a two-stage process. The Panel comprised internationally renowned experts in relevant research fields, with substantial experience in translational clinical research. To ensure independence, and to provide the necessary international perspective on the standing of the partnerships and their proposals, none of the members of the Selection Panel work in England. The Panel also included observers from HEFCE and MRC to ensure that the perspectives of two of its key funding partners were taken into account.
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| The Forestry Commission, since 2002, has brought policy end-users directly into the setting of strategic priorities for research. It set up a Research Strategy Management Board of policy leads from the Forestry Commission in England, Scotland and Wales and the Northern Ireland Forest Service. The Board is supported by the Research Director from their Research Agency and the Head of the Specialist Advisors Unit, responsible for commissioning research.
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25. (Recommendation 23) Wherever possible, the secretariat
of scientific advisory committees should include secondees from
appropriate scientific establishments, to both enhance the specialist
knowledge within the secretariat and safeguard its independence.
(Paragraph 69)
The Government welcomes secondments to SAC secretariats to provide
specialist knowledge. OSI recently hosted a workshop for secretariats
of SACs, aimed at networking and sharing best practice. The Spongiform
Encephalopathy Advisory Committee (SEAC) Secretariat has set up
a cross-departmental networking group for SAC secretariats. The
membership of this group has doubled in two years.
26. (Recommendation 24) We urge the Government to update the
Code of Practice for Scientific Advisory Committees and the list
of code committees as a matter of urgency. (Paragraph 70)
Accepted. The GCSA told the Committee (Q1350) that
the Code of Practice for Scientific Advisory Committees3
(CoPSAC) would be reviewed and updated during 2007. The review
will take into account the Committee's Recommendations 25 to 33.
The Government would welcome any further proposals from the Committee
for changes to the CoPSAC. The list of code committees will also
be updated during 2007.
Recommendations 25-29, 31-32, and 48—Updating the Code
of Practice for Scientific Advisory Committees
27. (Recommendation 25) We recommend that the revised Code
of Practice for Scientific Advisory Committees provide explicit
guidance on how the performance of these committees should be
monitored. It should give departmental CSAs clear responsibility
for overseeing the performance of scientific advisory committees
sponsored by their Department and advise them to commission light-touch
independent reviews every five years to ensure that committees
are functioning as required and to identify innovations in working
practices that could usefully be applied by other committees.
(Paragraph 72)
28. (Recommendation 26) We recommend that committees not designated
as 'scientific advisory committees' but which play a significant
role in the provision of scientific advice, or whose advice to
Government relies heavily on scientific input, be required to
comply with the Code of Practice for Scientific Advisory Committees.
(Paragraph 73)
29. (Recommendation 27) Industry members of scientific advisory
committees can be important sources of expertise and experience
but are frequently perceived to be less trustworthy than NGO representatives.
This is unfair and illogical: the same standards and expectations
should be applied to both categories of representative. (Paragraph
74)
30. (Recommendation 28) It is important not to allow the 'double
counting' of non-scientific opinion or advice. (Paragraph 75)
31. (Recommendation 29) There is an urgent need for greater
clarity regarding the role of lay members on scientific advisory
committees and the status of their contribution. Clearly, where
a committee has been tasked with providing purely technical advice,
it would inappropriate to give the views of lay members equal
weight to advice from experts: scientific advice must be based
on science. In view of the many potential problems identified
in having lay membership of scientific advisory committees (as
opposed to policy commissions where they play a vital role), we
recommend that scientific advisory committees dealing with technical
advice to Government should not routinely have lay membership.
(Paragraph 76)
32. (Recommendation 31) We find the institutional structure
of the scientific advisory system in the US attractive and encourage
the Government to discuss with the learned societies the extent
to which similar arrangements could be adopted in the UK and the
changes that this would necessitate. (Paragraph 81)
33. (Recommendation 32) There is ample room for greater involvement
of the learned societies and professional bodies in the UK scientific
advisory system. We recommend that the Government take up the
offer by the Science Council to coordinate a scientific advisory
network comprising all the professional bodies. (Paragraph 82)
34. (Recommendation 48) Peer review of the extent to which
Government policies are evidence-based by learned societies, professional
bodies and researchers can play a useful role in stimulating debate
and refining policy makers' thinking and should, therefore, be
welcomed by the Government. We recommend that the Government commission
such reviews, on a trial basis, of selected key policies after
a reasonable period of time as part of the policy review process.
(Paragraph 120)
Subject to the consultation on revisions to the CoPSAC3,
the Government's provisional views are:
- The CoPSAC should propose light-touch reviews of SAC performance.
We agree with the Committee that such reviews should identify
best practice that can be shared with other SACs [Rec 25].
- Departments will be encouraged to apply the CoPSAC to non-code
Committees as far as relevant. The fact that they are non-Code
Committees may be because application of the CoPSAC is inappropriate
in some respects [Rec 26]. This would however need
proper justification in each case.
- SAC Chairs should remain vigilant for any evidence of bias,
whether from industrial advisers, advisers from NGOs, or elsewhere
[Rec 27].
- The issue of 'double counting' will be addressed in the updating
of the CoPSAC [Rec 28].
- The question of lay membership of SACs will also be addressed
in the updating of the CoPSAC. The Government is not inclined
to introduce a general presumption against lay membership. Lay
membership can bring important skills and experience including
legal and communication skills. There are many examples where
the presence of lay members has worked well: the alternate vice-Chair
of the Gene Therapy Advisory Committee is a barrister; all nine
independent SACs for the Food Standards Agency have lay membership.
In each case, it is important that the role of the lay membership
is clearly defined and understood; for example to ensure the right
questions are asked, or that the wider context is taken properly
into account. Where detailed technical or scientific advice is
needed, this should come from appropriately qualified scientists
and/or engineers [Rec 29].
The Government will reflect further on Recommendation
31. It believes however that Recommendation
32 is too prescriptive. The Government consults many organisations
such as PSREs, Learned Societies, Research Councils, SACs, the
Council for Science and Technology, and Foresight programmes when
it needs advice. It may seek advice from such an organisation
directly or seek guidance on who the best experts to consult are.
The Government does not believe that any of these organisations
should be routinely involved in decision-making or peer review,
though they might be in specific cases [Rec 48].
The recent establishment of the Civil Service Steering Board
will contribute an important check on the quality of evidence-based
policy making.
| As part of its review of the governance of science, the Food Standards Agency Board identified an enhanced role for the Chairs of the SACs that advise it. The Chairs can now brief the Board in writing or in person before decisions are taken. There are benefits to both the Board and the SACs in this process: the Board has extra assurance about the quality of the science presented to it and the use to which it is put; the SACs gain a better understanding of how their advice is used and the issues that the Board takes into account.
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35. (Recommendation 33) The situation, where the RAE acts as
a disincentive to engagement by the scientific community with
policy, must be rectified in the successor to the RAE. (Paragraph
83)
Following consultation, the Government announced in the 6 December
pre-Budget report[14]
that a new, more metrics-based, research assessment process would
be introduced after the 2008 Research Assessment Exercise (RAE).
For science, engineering, technology and medicine subjects (SET
subjects), an assessment exercise using income, student number,
and bibliometric indicators would run in 2009, and begin to inform
funding in the 2010-11 academic year. This new approach will keep
research quality at the heart of the assessment process, and will
help in particular to ensure recognition of excellence in user-led
research. It will also increase transparency and reduce the administrative
burden of the RAE on universities and researchers, allowing them
to focus on their core activities, including engagement with policy.
The need for additional credit to be given for engagement with
the policy process will be kept under active review.
Recommendations 34, 35, 37, 50 and 51—Public engagement
and publication policy
36. (Recommendation 34) We applaud Sir David King's efforts
to integrate fully science into an evidence based approach. Government
should also be clear when policy is not evidence-based, or when
evidence represents only a weak consideration in the process,
relative to other factors. Where there is an absence of evidence,
or even when the Government is knowingly contradicting the evidence—maybe
for very good reason—this should be openly acknowledged.
(Paragraph 89)
37. (Recommendation 35) We agree that ministerial decisions
need to take into account factors other than evidence, but this
is not reflected in the Government's oft-repeated assertion that
it is committed to pursuing an evidence based approach to policy
making. We have detected little evidence of an appetite for open
departure from the mantra of evidence-based policy making. It
would be more honest and accurate to acknowledge the fact that
while evidence plays a key role in informing policy, decisions
are ultimately based on a number of factors—including political
expediency. Where policy decisions are based on other such factors
and do not flow from the evidence or scientific advice, this should
be made clear. (Paragraph 90)
38. (Recommendation 37) Commissioned systematic reviews of
the evidence base should usually be considered as research for
the purposes of publication policy. (Paragraph 94)
39. (Recommendation 50) A strong emphasis on the publication
of all evidence used in policy making, along with a clear explanation
as to how it is used, should be one of the guiding principles
of transparent policy making. (Paragraph 126)
40. (Recommendation 51) We recommend that departments make
it a presumption that significant scientific advice from departmental
CSAs as well as scientific advisory committees is published. (Paragraph
129)
Subject to necessary confidentiality, for example as provided
for in the Freedom of Information6 (FoI) and Data Protection
Acts7 (DPA), the Government is committed to publishing
evidence and the reasoning behind decisions. These principles
are reflected in departmental Science and Innovation Strategies
[Rec 34].
| The Department for Environment, Food and Rural Affairs' (Defra) Evidence and Innovation Strategy provides for the integration of all evidential streams into a published framework which is mapped onto major policy drivers for that Department. The Government encourages all departments to consider how they can improve their own integration and transparency across evidential streams.
|
The Government agrees that some of its decisions will properly
take account of factors other than evidence. See, for example,
the Cabinet Office publications Modernising Government8
and Professional Policy Making in the 21st Century9
[Rec 35].
The GCSA's Guidelines on Scientific Analysis in Policy Making
(2005)4, (paragraphs 25 and 26), address
the importance of publication within the guidance offered by the
FoI Act. The CoPSAC also addresses (paragraphs 65 onwards)
the principles governing publication. The issues raised by the
S&T Select Committee will be included in the 2007 update of
the CoPSAC, which will embed FoI guidance, including the treatment
of 'advice' and 'evidence', and draw on existing guidance which
applies to social research used by the Government.
The Freedom of Information Act governs the release of information
to the public. It makes a distinction between factual information
and research-based advice. Section 35 of the Act recognises that
there is a public interest in ensuring that there is a space within
which Ministers and officials can formulate and develop policy
options freely and frankly and that some information and advice
generated in this space should therefore be exempt from release
(subject to the public interest test). Once the Government has
taken a decision, the Act requires that particular consideration
be given to the public interest in subsequently disclosing factual
information [Recs 50 and 51].
Existing guidance on implementing the FoI in government statistics
and social research makes the presumption that research and statistics
should be published, and that their quality should be subject
to independent scrutiny. The Government agrees that systematic
reviews of scientific literature should be considered research
and that therefore the assumption should be to publish such reviews
subject to the caveats above [Rec 37].
The Cabinet Secretary has formed a working group of Permanent
Secretaries to discuss further the issues associated with the
publication of social research. The Government will ensure that
any read-across to other research is acted on.
Recommendations 36 and 49—Effective responses to cross-cutting
issues
41. (Recommendation 36) Departments need to evolve more effective
mechanisms for identifying gaps in the evidence base for policy
development which are capable of responding to new and emerging
political priorities. (Paragraph 91)
42. (Recommendation 49) We recommend that issue-based reviews
be introduced as a means of auditing cross-departmental policies.
These could be incorporated into the Science Review of the department
which has been designated as lead department for the relevant
policy. (Paragraph 123)
The Government recognises the need to ensure that cross-cutting
and long-term challenges are identified and tackled in a coordinated
way. It already undertakes issue-based reviews, many of which
synthesise existing evidence and identify evidence gaps. For example:
- a number of such reviews have been commissioned as part of
the current Comprehensive Spending Review;
- the Prime Minister's Strategy Unit undertakes strategy and
policy reviews. The Unit has also undertaken occasional Strategic
Audits of the challenges facing the UK[15];
- the recently announced policy review, Pathways to the Future5,
will address long term strategic priorities for the UK.
To complement these reviews, the newly established Civil Service
Steering Board (which supersedes the Permanent Secretary Management
Group) will be well placed to identify and manage strategic and
operational challenges and risks.
Science Reviews have a departmental focus and would not provide
an appropriate additional mechanism. However horizon scanning,
which is led for the Government by the OSI, is an important means
of ensuring that strategic decisions are informed and challenged
by the analysis of possible futures.
| The Department for Work and Pensions (DWP) leads cross-government work on demographic change. For example it has led discussions with other government departments, including HM Treasury, HM Revenue and Customs and DTI, to develop the new Wealth and Assets Survey, which the Office for National Statistics is now conducting. Fieldwork for this longitudinal survey started this summer following a successful pilot. The DWP is a major funder for the survey and hopes to use the data to help pensions policy development.
|
| Foreign and Commonwealth Office (FCO) research analysts look forward systematically at political developments in different parts of the world, and at thematic developments matching the government's international priorities. In doing so they draw on analysis from elsewhere in Government, for example the OSI's Horizon Scanning Centre.
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43. (Recommendation 38) We urge the Government CSA to
investigate proactively any allegations of malpractice in the
commissioning, publication and use of research by departments
and to ensure that opportunities to learn lessons are fully taken
advantage of. We would expect the results of any such investigations
to be made public. (Paragraph 96)
The Government agrees that credible allegations of malpractice
should be investigated. Depending on the circumstances it may
be appropriate for the GCSA or for another person or organisation
to carry out such an investigation. Publication is in general
desirable but is subject to the qualifications such as those set
out in response to Recommendations 34, 35, 37, 50 and 51.
44. (Recommendation 39) We recommend that the Government Chief
Scientific Adviser ensures that the publication of research underpinning
policy development and evidence cited in support of policies is
monitored as part of the departmental science reviews. (Paragraph
97)
Agreed. Departmental Science Review assessment criteria include
assessment of the sharing, transfer and management of knowledge
as well as evidence of publication policy. Assessment criteria
also include departmental implementation of the GCSA's Guidelines
on Scientific Analysis in Policy Making4 and CoPSAC3.
45. (Recommendation 40) Research must, so far as is achievable,
be independent and be seen to be so. We are not convinced that
the current mechanisms for commissioning research deliver this
objective. We have also made the case for greater investment in
research to underpin policy development. We recommend the creation
of a cross-departmental fund for policy related research to be
held by the Government CSA in order to meet these dual aims (Paragraph
98)
The Government has improved the ways it develops evidence-based
cross-government policies, for example through the community of
DCSAs and departmental Science and Innovation (S&I) Strategies.
Departments work together in a number of other ways, for example
through horizon scanning and 'Grand Challenges'[16].
The Government will continue to review as a matter of importance
whether further steps are needed to overcome barriers to evidence-based
cross-departmental working, and in doing so will take account
of the Committee's proposal for a centrally held budget.
On a subsidiary point, research must be impartial and objective.
That will not always mean that it is conducted externally (which
might be implied by the word 'independent').
46. (Recommendation 41) We recommend that where the Government
describes a policy as evidence-based, it should make a statement
on the department's view of the strength and nature of the evidence
relied upon, and that such statements be subject to quality assurance.
(Paragraph 101)
This recommendation will be considered during the 2007 update
of the CoPSAC to see to what extent and if so how it might be
made workable, taking account of the volume of work implied and
the value it would add.
47. (Recommendation 42) Pilots and trials can make a valuable
contribution to policy making but there is no point the Government
initiating them if it is not going to use the output properly.
In order to protect them from political pressures, pilots and
trials should be carried out at arm's length from Government or
at least be independently overseen. (Paragraph 104)
As the Committee sets out, a review of government pilots and trials
was commissioned by the Government Social Research Unit and published
by the Cabinet Office in December 2003[17].
The report made recommendations on the role and properties of
pilots, pre-conditions for success, methods and practices, and
the use of results. One of the preconditions specified was that
'A pilot should be undertaken in a spirit of experimentation.
So, if it is clear at the outset that a new policy and its delivery
mechanisms are effectively already cast in stone, a pilot is redundant
and ought not to be undertaken.'[18]
The report also highlights the importance of independence. That
does not have to mean that pilots and trials are carried out at
arm's length—although in practice many of them are—but
that 'Ministers and Civil Servants most closely involved with
the policy should consider distancing themselves from decisions
about pilot methods and the dissemination of findings'. It is
common practice for the results of pilot evaluations to be peer
reviewed before publication, which provides an additional independent
assessment of their quality. The Government remains committed
to implementing the recommendations of the review, recognising,
as stated earlier and as made clear in oral evidence by the Secretary
of State, that evidence is only one factor taken into account
in Ministers' decisions.
Recommendations 43, 44, and 45—Longer term policy planning
48. (Recommendation 43) We commend the Government CSA and the
Office of Science and Innovation on their work aimed at strengthening
horizon scanning in relation to science and technology across
Government. (Paragraph 106)
49. (Recommendation 44) In the context of the electoral cycle
and an era of 24 hour news coverage, it is not hard to see
why politicians prioritise actions that can deliver short term
benefits over those not likely to yield dividends until they have
long departed from the Government. It is a major challenge for
the Government to ensure that the results of horizon scanning
are being used properly. The Government needs to put in place
incentives to encourage departments to take a more long term view
in developing policy. We recommend that it be a requirement for
departments to demonstrate in all major strategic planning documents
that they are using the results of—not just conducting—horizon
scanning and research. (Paragraph 110)
50. (Recommendation 45) The Government's current approach to
policy making is not sufficiently responsive to changing evidence,
making it hard to feed in results from activities such as trials,
research and horizon scanning. We urge the Government, as well
as the opposition parties, to move towards a situation where a
decision to revise a policy in the light of new evidence is welcomed,
rather than being perceived as a policy failure. (Paragraph 111)
The Government is pleased by the Committee's recognition of the
value of the work of the Government's Horizon Scanning Centre
(HSC), which brings long term strategic perspectives into Government
business [Rec 43].
| Horizon scanning is used widely in MoD, for example by defence policy staff to set the UK policy framework for the next 10-20 years, and by intelligence analysts using it to understand future threats and the security environment.
The MoD Development, Concepts and Doctrine Centre (DCDC) undertakes a strategic analysis programme that uses horizon scanning to feed into policy and the development of military operational concepts. This includes 'Strategic Trends', an analysis of future trends, drivers and shocks that the UK's Armed Forces might face, which is published on the web and on which comments and feedback are welcomed.
|
The Government recognises the importance of proper analysis and
use of evidence (from research, horizon scanning, and other sources)
in strategic planning. The expectation that departments should
adopt a strategic approach is set out in a number of documents
including the GCSA's Guidelines on Scientific Analysis in Policy
Making (2005)4. The Government is seeking to develop
further the capability of departments to use this information
through the HSC and the National School of Government's training
programme on analysis, use of evidence and strategic planning.
The Government requires departments to take a long-term perspective
in the current Comprehensive Spending Review, for example through,
demonstrating that they have responded to HM Treasury's Long
Term Opportunities and Challenges publication11.
The OSI's Foresight programme injects long term planning into
cross-departmental challenges faced by the UK. Foresight projects
require the publication of an action plan, which ensures that
long-term strategic issues are addressed [Rec 44].
Subject to the points made earlier about factors other than evidence
(for example, political philosophy) which properly influence policy,
the Government agrees in principle with the Committee and with
the late Lord Keynes that 'When the facts change, I change my
mind—what do you do, sir?' The Government intends to do
more in particular to engage 'upstream' with the public's views
on science and to improve the Government's public dialogue capability.
Improving dialogue and debate will help to gain acceptance that
policy reactions to new evidence are expected and welcome, rather
than a failure. To this end, the Government is establishing an
Expert Resource Centre for Public Dialogue on Science and Innovation
to help all parts of government enable public debate on science
and technology-related topics. The Centre will develop and disseminate
good practice on public dialogue across government and its non-departmental
public bodies, resulting in a culture where public dialogue is
seen as a fundamental part of science and technology policy development
[Rec 45].
Recommendations 46 and 47—Monitoring the quality of scientific
advice and evidence
51. (Recommendation 46) It is useful that the Government CSA
has issued guidance on the use of scientific analysis in policy
making but it is disappointing that there has been so little monitoring
of its implementation. Departmental CSAs should, in future, be
more proactive in ensuring that the principles defined in the
Guidelines on Scientific Analysis in Policy-making are adhered
to within their departments. (Paragraph 114)
52. (Recommendation 47) To increase public and scientific confidence
in the way that the Government uses scientific advice and evidence,
it is necessary for there to be a more formal and accountable
system of monitoring the quality of the scientific advice provided
and the validity of statements by departments of the evidence-based
nature of policies. (Paragraph 115)
The Government agrees that monitoring of the use of the Guidelines
in these respects needs further development. This is being addressed
through the OSI's Science Reviews, through SACs, and through annual
monitoring by DCSAs of the eight attributes for the management
and use of science and research in Government set out in Chapter
8 of the Science and Innovation Investment Framework 2004-20142.
The overall results of the annual monitoring will be reflected
in HM Treasury's annual report on the Investment Framework.
53. (Recommendation 52) We recommend that departmental
Chief Scientific Advisers monitor the extent to which their departments
and associated advisory bodies are adopting best practice in terms
of openness and transparency and seek to ensure that any deficiencies
are addressed. (Paragraph 130)
The Government agrees this recommendation as part of its overall
aim to enhance and support the role of DCSAs alongside SAC Chairs
in promoting the health of science in Government. OSI and the
Secretariat to SEAC are supporting workshops, seminars and other
networking opportunities for SAC Secretariats and DCSAs, in order
to spread best practice.
While it will not always be appropriate, there are some good examples
(e.g. SEAC) where reviews and the day to day business of
SACs is conducted using open sessions, webcasts, and web summaries
of open and closed sessions. The Government commends the example
set by SEAC. The Select Committee's recommendation and the importance
of the spread of good practice will inform the update of the CoPSAC
in 2007.
Monitoring and evaluation will be reinforced through the annual
report on the Science and Innovation Investment Framework 2004-20142.
The emerging findings of the first departmental Science Reviews
have already identified common issues and concerns across departments;
OSI is helping departments to address these.
| Through OSI, DTI's 'Science and Society' activity addresses issues ranging from science communication to the public's support, interest, engagement, and dialogue about science and the issues that it raises for society.
|
54. (Recommendation 53) We recommend that Government guidelines
be amended to ensure that, as a matter of good practice, some
high level information about the progress of major projects through
Gateway reviews is made public. (Paragraph 131)
Since April 2003 the Chief Executive of the Office of Government
Commerce (OGC) has written to the responsible Permanent Secretary
to notify him or her of successive red Gateway reviews[19].
The letter highlights the importance of identifying and addressing
risks to successful delivery at the earliest possible stage. Since
October 2005 the National Audit Office (NAO) has been sent copies
of the letters, and these may now be passed to the Chair of the
Public Accounts Committee.
Gateway reviews are conducted on a confidential basis for the
Senior Responsible Owners (SROs) of projects and programmes within
departments. While OGC owns the Gateway process, departments own
the reports and are responsible for implementing the recommended
actions.
Consequently OGC does not publish information on Gateway reviews
as a matter of course. However, in line with the FoI legislation,
it considers all requests for such information on a case-by-case
basis, taking account of the exemptions in the Act, and the public
interest test.
Some summary information on Gateway reviews has been published
in NAO Reports including Improving IT procurement[20]
(November 2004) and Delivering successful IT-enabled business
change[21] (November
2006).
Recommendations 54, 55 and 57—Public consultations
55. (Recommendation 54) We recommend that, as a matter of good
practice, each policy statement or legislative proposal which
follows a public consultation make explicit reference to how the
consultation influenced the policy, including an explanation,
where necessary, as to why any views or proposals widely supported
by contributors were rejected. (Paragraph 138).
56. (Recommendation 55) Whilst we accept that there can be
legislative and political uncertainties which affect the policy
making process, we recommend that public consultations generally
be accompanied by an indicative timescale of resulting decisions.
(Paragraph 140)
57. (Recommendation 57) We recommend that the Cabinet Office
monitor whether departments are following best practice on consultations
and act where repeated breaches of the code of practice for consultations
occur. (Paragraph 145)
The Government agrees with the Committee's views on public consultation
set out in these recommendations.
In line with Criterion 4 of the Code of Practice on Consultation10,
within three months of the close of a formal, written public consultation,
the relevant Government Department should 'give feedback regarding
the responses received and how the consultation process influenced
the policy'. The consultation document should state when and how
(e.g. the website address) this response document will be made
available [Rec 54].
This same information should then feed into the Impact Assessment
work that departments carry out during policy development. Any
changes to a department's options that are made as a result of
consultation must be recorded and explained in the full Impact
Assessment and the Impact Assessment should accompany all legislative
proposals laid before Parliament.
In part, the Cabinet Office's Code of Practice on Consultation
already covers Recommendation 55. The Code says that departments
should, as far as is possible, state in their consultation documents
when and where a summary of responses will be published and that
this summary should also summarise the next steps for the policy
(see also response to Recommendation 54, above). This should,
wherever possible, include an indicative timetable [Rec
55].
The Cabinet Office plans to review consultation policy this year
in order to improve the way Government engages with stakeholders
on policy development. The Committee's recommendation will be
considered as part of that review.
The Government agrees with the need to ensure that consultations
comply with the Code of Practice on Consultation and the
Better Regulation Executive (BRE) already takes action to achieve
this. In addition to working day-to-day with departments on all
aspects of Better Regulation, including consultation, the BRE,
as the Committee acknowledges, reports annually on departments'
compliance with the Code of Practice on Consultation. These
annual reports have focussed on the most quantifiable element
of the Code of Practice on Consultation, namely Criterion
1 ('Consult widely throughout the process, allowing a minimum
of 12 weeks for written consultation at least once during the
development of the policy'). In 2005, 97% of consultations lasted
at least 12 weeks or had Ministerial clearance to last for a shorter
period due to exceptional circumstances. Moreover, each government
department has its own Consultation Coordinator who promotes compliance
with the Code of Practice on Consultation within his or
her department [Rec 57].
Qualitative monitoring of Government's consultations will be considered
as part of the Cabinet Office's review of consultation policy.
58. (Recommendation 56) We recommend that scientific advice
be routinely used in drawing up the terms of consultations, in
order to ensure the right questions are asked and to avoid any
subsequent criticism of its terms. (Paragraph 143)
Agreed. The input of DCSAs should be sought in the design, approval
and implementation of departmental consultations alongside inputs
from other analytical and professional groups. This will be helped
by the implementation of the 'Analysis and Use of Evidence' PSG
core skill across all professional groupings.
59. (Recommendation 58) We recommend that departments ensure
that the Professional Skills for Government programme and other
training activities provide comprehensive coverage of the principles
and practice of risk management. (Paragraph 153)
The Government agrees, and has identified risk management as a
prominent feature throughout the PSG framework. It provides a
range of learning and development opportunities that address risk
management.
60. (Recommendation 59) We welcome the progress the Government
has made toward promoting proper risk analysis in policy making
but are concerned about how this progress will be sustained. We
recommend that the sub-Committee on risk continue to operate and
that it ensure that the monitoring of departmental performance
on risk management is maintained. (Paragraph 155)
Following the two-year risk improvement programme led by HM Treasury
from 2002-2004 further work has been done over the last two years
to encourage and monitor the continuing development of risk management
and to report progress to the PSMG sub group on risk. In 2006,
two volumes of good practice examples of risk management were
published; guidance on risk appetite[22]
was published with the second set of examples. Annual reports
over the last four years have demonstrated sustained improvements
in risk management.
Given the progress which has been made, the Government has decided
that the sub group is no longer the best vehicle to achieve further
progress. The main priorities are now:
- to focus on culture change to ensure that the right behaviours
for well managed risk taking are supported; and
- to continue to encourage a culture of learning.
Permanent Secretaries will pursue these issues within their Departments
and will, periodically, take stock collectively. In addition,
there is a network of Risk Improvement Managers in departments
which will continue to meet on a regular basis; furthermore a
new group is being established, comprising Directors General from
departments, to help ensure learning and spread of best practice.
Finally, the National School of Government will play a continuing
role through its programmes on risk issues.
HM Treasury is continuing to provide a limited central resource
to support the risk agenda and in particular to support the network
of departmental Risk Improvement Managers.
Recommendations 60, 61 and 62—the Precautionary Principle
61. (Recommendation 60) We can confirm our initial view that
the term "precautionary principle" should not be used,
and recommend that it cease to be included in policy guidance.
However, we do see value in further work which seeks to clarify
the terms and correct application of a precautionary approach
as set out helpfully by the GCSA. We believe that it is best to
use the term precautionary approach, but with a consistent explanation
of the degree and nature of the risks, benefits and uncertainty
and an explanation of the concept of proportionality. It should
never be considered a substitute for thorough risk analysis which
is always required when the science is uncertain and the risks
are serious. It should not be used, in itself, to explain a decision
or course of action. (Paragraph 166)
62. (Recommendation 61) We believe that further work should
also focus on the practical application of risk management theories
in circumstances of scientific uncertainty and the effective communication
of the decision making process. (Paragraph 166)
63. (Recommendation 62) The term precautionary principle is
in current use in other jurisdictions, including the EU, so it
can not simply be wished away. However, both the Government's
current use of the term precautionary approach rather than principle
and the further work we are recommending to properly clarify,
constrain and apply a precautionary approach is something that
we recommend the Government invite the EU and other countries
to consider and adopt. (Paragraph 167)
The Government agrees with the thrust of the Committee's views,
although it would not be possible to avoid the use of the term
'precautionary principle' given its widespread use in international
agreements. The practicality of reopening these agreements, which
go well beyond the EU, is doubtful.
In practice, the precautionary principle is interpreted as a flexible
precautionary approach to enable innovation and learning in circumstances
of significant uncertainty, while not putting the public at unacceptable
risk. It must always be used with the best evidence-based risk
assessment available.
Recommendations 63, 64, 65, 67 and 68—Risk Communication
64. (Recommendation 63) We welcome the public commitment to
transparency in the handling of risk in policy guidance and the
recognition by Chief Scientific Advisers of the need to improve
public communication on risk. (Paragraph 171)
65. (Recommendation 64) We recommend that the Cabinet Office
assume greater responsibility as the centre of excellence on risk
communication within Government. It should have a leading role
in collating and disseminating best practice on risk communication,
commissioning further research as appropriate, in conjunction
with other departments, and for monitoring performance in implementing
guidelines. (Paragraph 174)
66. (Recommendation 65) We strongly endorse the development
of alternative voices for the provision of information and advice
of a technical nature. Given the issues of trust identified by
research, the often instinctive reaction of departments to field
a minister should be resisted. (Paragraph 175)
67. (Recommendation 67) We believe that the Government's communication
strategy would benefit from the adoption of a higher public profile
by departmental CSAs on policies with a strong evidence or science
base. We recommend that the Government CSA explore with ministers
and departmental CSAs how this might be best achieved and that
the impact of this enhanced role be monitored. (Paragraph 180)
68. (Recommendation 68) We welcome the Government's attempts
to liaise with the media on risk communication and its recognition
that there is more work to be done on this front. We recommend
that the Government continue to develop a strategic and pro-active
approach to engagement with the media. The work started under
John Hutton should be part of a structured programme, with attention
being given to learning from recent examples of coverage as well
as informing coverage of current risk related issues. Newspaper
representatives should be a priority for engagement. Government
guidance should encourage a more aggressive approach to correcting
inaccuracies or mis-interpretations in media coverage of risk,
with departmental Chief Scientific Advisers playing a leading
role when appropriate. (Paragraph 186)
The Government welcomes the Committee's endorsement of its public
commitment to transparency and its commitment to making improvements
[Rec 63].
The Cabinet Office does and will continue to play a prominent
role in risk communication across Government. Improved and detailed
guidance on risk communication has been published in the 'Engage'
strategic communications section of the Government Communication
Network[23]. Further
case studies will be published and seminars held to spread best
practice and share information [Rec 64].
A significant amount of guidance relating to risk management has
also been produced by HM Treasury in recent years, including the
'Orange Book'[24]
(Management of Risk - Principles and concepts) and Managing
risks to the public: appraisal guidance[25].
The importance of communication within the organisation, between
the organisation and its partners in delivery, and between the
organisation and its stakeholders is stressed in this guidance.
A network of Risk Improvement Managers is embedded in departments.
Risk management is integral to the Capability Review Programme[26]
led by the Cabinet Office. The Capability Reviews form part of
the wider Civil Service reform agenda designed to identify key
areas for improvement and action and lead to a Civil Service that
is better able to deliver public services. The scope of the reviews
means that they can identify risks that need addressing within
individual departments as well as across Government. The Cabinet
Secretary's office monitors resulting action plans.
It is agreed that those who are appointed to Government in an
expert or quasi-independent capacity should have an active media
role where appropriate [Recs 65 and 67].
DCSAs are often best placed to clarify issues and provide an authoritative
voice on specialist or complex issues for the general public.
It is normal in the case of 'live' issues, such as human health
(radiation contamination, pandemic flu, Measles Mumps and Rubella
vaccine) or animal disease outbreaks (foot and mouth, 'bird flu'),
that the relevant chief adviser engages proactively with the media
to ensure the public are provided with independent, expert information
and advice from the outset.
Strategic and pro-active engagement with the media continues and
the Government recognises and agrees with the Committee on the
importance of this. For example the Media Emergency Forum (MEF),
which brings together senior editorial figures from the media
(broadcasters, national and regional newspapers) with representatives
of central and local government and the emergency services and
utilities, meets twice a year. As well as strategic issues, there
is frank and open discussion of communications issues arising
from specific emergencies and from joint exercises. Regional MEFs
have been set up to extend this best practice across England [Rec
68].
Government departments try to help accurate media coverage by
releasing evidence, statistics and other information in a timely
and balanced way. In most cases, if risks have been mis-reported
or mis-represented, the department's Communications Division will
contact the journalist or editor and ask them to correct or balance
their story immediately. Most media outlets are willing to do
this and it is the quickest way to get the correct facts into
the public domain. If a newspaper refused and went against their
Code of Conduct then the department would consider reporting the
case to the Press Complaints Commission.
Recommendations 66 and 69—Common language on risk
69. (Recommendation 66) We believe scientists, including departmental
CSAs, should play a leading role in communicating to the public
levels of scientific agreement, where necessary, and the degree
of certainty in the scientific advice being offered. We recommend
that common terminology be developed to be used consistently across
Government in order to communicate these uncertainties. (Paragraph
177)
70. (Recommendation 69) We recommend that the Government build
on existing work to develop, subject to academic peer review,
a scale of risks for use by all departments, as appropriate, when
communicating levels of risks to the public. (Paragraph 194)
Just as the Government has not developed a standardised table
of risks, as risks mean different things to different people,
it does not agree that a common terminology or scale of risks
would be helpful to DCSAs or the public. Each case and each issue
needs to be dealt with individually and communications or actions
tailored appropriately. Generic categorisation of risks may infer
that one risk is directly comparable to another, which is often
not the case.
The Government does however adopt a common methodology and scale
in specific areas where the advantages outweigh the disadvantages,
for example in assessing disruptive challenges to the UK. There
is a duty on Category 1 responders (those organisations at the
core of the response to most emergencies, eg emergency services,
local authorities, NHS bodies), under the Civil Contingencies
Act 2004, to assess risk in their area and communicate those risks
by publishing a community risk register. The Civil Contingencies
Secretariat in the Cabinet Office provides these responders with
guidance on which risks to consider, a common methodology and
a common scale for assessing the likelihood of those risks to
ensure that there is some consistency between the assessments
made across the country at a local level and those made as part
of the national risk assessment.
The Government analytical community has a role in explaining to
the public, as well as to policy makers, the true nature of perceived
risks. Their involvement ensures that the Government is in a position
to adopt a balanced and proportionate approach to managing risk.
In order to achieve this, the public needs to be in a position
to understand the available information and set it in context.
This will ensure that any debate is based on an understanding
of the facts.
The reporting of risk and uncertainty is specifically addressed
in the CoPSAC, paragraphs 55 to 60. The proposed update of the
Code in 2007 will make clarifications where appropriate.
1 Professional Skills for Government (PSG) website:
http://psg.civilservice.gov.uk/ Back
2
The Science & Innovation Investment Framework 2004-2014 can
be viewed on-line at: http://www.hm-treasury.gov.uk/spending_review/spend_sr04/associated_documents/spending_sr04_science.cfm Back
3
Code of Practice for Scientific Advisory Committees (December
2001) can be viewed on-line at: http://www.dti.gov.uk/science/science-in-govt/works/advice-policy-making/codeofpractice/page9483.html Back
4
The Government Chief Scientific Adviser's Guidelines on Scientific
Analysis In Policy Making (2005) can be viewed on-line at: http://www.dti.gov.uk/files/file9767.pdf Back
5
'Pathways to the Future' announcement of 24 November 2006 can
be found on-line at: http://www.pm.gov.uk/output/Page10478.asp
Back
6
Guidance on Freedom of Information Act can be found on-line at:
http://www.foi.gov.uk/guidance/index.htm Back
7
Guidance on data protection can be found on-line from the Information
Commissioner's Office at: http://www.ico.gov.uk/ Back
8
'Modernising Government' can be found on-line at: http://www.policyhub.gov.uk/docs/modgov.pdf Back
9
'Professional policy making for the 21st Century' can be found
on-line at: http://www.policyhub.gov.uk/docs/profpolicymaking.pdf Back
10
Code of Practice on Consultation can be found on-line at:http://www.cabinetoffice.gov.uk/regulation/consultation/code/index.asp Back
11
'Long-term opportunities and challenges for the UK: analysis for
the 2007 Comprehensive Spending Review (November 2006)' can be
viewed on-line at:http://www.hm-treasury.gov.uk/media/298/55/csr_longterm271106.pdf Back
12
Government Skills (the Sector Skills Council for central government,
the Armed Forces and Non-Departmental Public Bodies) can be found
on-line at: http://www.government-skills.gov.uk/ Back
13
The Leitch Review of Skills can be found on-line at: http://www.hm-treasury.gov.uk/independent_reviews/leitch_review/review_leitch_index.cfm;
Back
14
The pre-budget report (December 2006) can be viewed on-line at:
http://prebudget2006.treasury.gov.uk/ Back
15
The Prime Minister's Strategy Unit work can be viewed on-line
at: http://www.strategy.gov.uk/ Back
16
'Grand Challenges' commitment can be found in DTI's Five Year
Plan 2004 on-line at: http://www.dti.gov.uk/files/file12618.pdf#page=20
Back
17
Trying It Out - The Role of 'Pilots' in Policy-Making Report of
a Review of Government Pilots can be viewed on-line at: http://www.policyhub.gov.uk/evaluating_policy/pilots/02.htm Back
18
Pre-conditions of pilots can be found on-line at: http://www.policyhub.gov.uk/evaluating_policy/pilots/downloads/rop.pdf#page=9
Back
19
'Red' Gateway reviews relate to those major procurements that
risk unsuccessful delivery without corrective action. Back
20
National Audit Office Report 'Improving IT procurement: The impact
of the Office of Government Commerce's initiatives on departments
and suppliers in the delivery of major IT-enabled projects' can
be viewed on-line at: http://www.nao.org.uk/publications/nao_reports/03-04/0304877.pdf Back
21
National Audit Office Report 'Delivering successful IT-enabled
business change' can be viewed on-line at: http://www.nao.org.uk/pn/06-07/060733.htm Back
22
'Thinking about risk: Managing your risk appetite: Good practice
examples' can be viewed on-line at: http://hm-treasury.gov.uk/media/A61/FE/pu135_risk_appetite_good_practice_examples_final_p1_vers3a.pdf;
its associated publication 'Thinking About Your Risk - Setting
& Communicating Your Risk Appetite' can also be viewed on-line
at: http://www.hm-treasury.gov.uk./media/A61/E0/pu026_thinking_about_your_risk_final_vers1a_.pdf Back
23
Government Communications Network (GCN) can be viewed on-line
at http://www.comms.gov.uk/ and its 'Engage' resources can be
found on-line at: http://engage.comms.gov.uk/ Back
24
'The Orange Book: Management of Risk - Principles and Concepts'
can be viewed on-line at: http://www.hm-treasury.gov.uk./media/FE6/60/FE66035B-BCDC-D4B3-11057A7707D2521F.pdf
Back
25
'Managing risks to the public: appraisal guidance' can be viewed
on-line at: http://www.hm-treasury.gov.uk/media/8AB/54/Managing_risks_to_the_public.pdf.
Back
26
The Capability Review Programme can be viewed on-line at: http://www.civilservice.gov.uk/reform/capability_reviews/index.asp Back
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