Principle 3: Proper consideration
of advice
21. We start from the position as summarised by the
Institute of Food Science and Technology that "policy-making
should be evidence-based and, therefore, if the issue is one which
requires independent scientists to assess the scientific evidence
in the light of current knowledge, and to provide advice based
on such assessments, then it should usually be expected that the
advice would be accepted after consultation with interested parties."[23]
22. In his memorandum to us Professor Iversen, a
member of the ACMD, made the point that the Government appeared
to have pre-judged some matters before the ACMD had stated its
views.[24] Such a state
of affairs would be reprehensible and would undermine the rationale
of providing independent scientific advice to Government. We consider
that the principles must ensure that proper consideration is given
by the Government to the advice of scientific advisory committees.
We recommend that the Government's
statement of principles contain a commitment that the Government
will not prejudge the work of scientific advisory committees and
will give proper consideration to scientific advice from committees.
23. We explained in Putting Science and Engineering
at the Heart of Government Policy that the Government should
be free to reject the advice of its scientific advisory committees,
"since scientific evidence is only one factoralbeit
a very important onein policy decisions: Advisers advise,
Ministers decide. However, when the Government does take a different
policy decision to that recommended by a [scientific advisory
committee], it should make clear its reasons for doing so".[25]
In its submission to us the Wellcome Trust pointed out that the
Council of Science and Technology had recognised that
policy decisions involve difficult choices that need
to take account of a very wide range of factors. Academics must
recognise that where a particular view does not prevail, or where
decisions are taken for political reasons, this does not mean
the academic input was not valued.[26]
We agree with this point. We
consider that the definition of the principle on the proper consideration
of advice should include recognition that the Government can reject
the advice of a scientific advisory committee but should explain
why it chose not to follow the advice.
24. The Wellcome Trust also made the point that that
the requirement in principle 3 that "Reports will not be
criticised or rejected prior to publication" needed clarification
to specify that it refers to criticism or rejection by Government
alone.[27] We agree.
We recommend that requirement
in principle 3 that "Reports will not be criticised or rejected
prior to publication" be clarified to specify that it refers
to public criticism or rejection by Government.
Process for agreeing the principles
25. In
order to secure broad agreement to the principles, we recommend
that once the Government issues a set of principles in December,
it should invite all interested parties, including all scientific
advisory committees, to comment before they are finalised.
17 For example, PR 02 [The Physiological Society],
PR 07 [The Society for Biology], PR 08 [Professor Iversen], PR
09 [Institute of Food Science and Technology], PR 12 [Dr Measham] Back
18
PR 05 [Professor Jones], para 15 Back
19
PR 09, para 7 Back
20
PR 14, para 4 Back
21
HC (2008-09) 168-I, para 69 Back
22
HC (2008-09) 168-I, para 68; see also para 73. Back
23
PR 09, para 3 Back
24
PR 08, para 2 Back
25
HC (2008-09) 168-I, para 69 Back
26
PR 06, para 6 Back
27
PR 06, para 8 Back