IV Scientific understanding
9.18 In setting an environmental standard, the starting-point must be scientific understanding of the problem or potential problem under consideration.
9.19 Despite the great difficulties involved, determining dose-effect relationships for the effects of substances on the natural environment is an essential exercise if appropriate environmental policies are to be adopted. When environmental policies or standards are adopted, it should always be made clear in an explicit statement whether they are designed to protect the natural environment, human health, or both, and the degree or nature of protection they are intended to afford.
9.20 Use of any model of pollutant-effect relationships should be dependent on careful consideration of the way it represents understanding of the development of the specific toxic effect being considered.
9.21 All exposure models (indeed, all mathematical models used within scientific assessment) should be regarded with caution until they are properly validated.
9.22 A clear dividing line should be drawn between analysis of scientific evidence and consideration of social and ethical issues which are outside the scope of a scientific assessment.
9.23 In a scientific assessment of an environmental issue, there are bound to be limitations and uncertainties associated with the data at each stage. Standard setting and other decision-making procedures should recognise this. The requirement for sound science as the basis for environmental policy is not a requirement for absolute knowledge or certainty and should not be interpreted as such.
9.24 When considering the process of scientific assessment and its output, two separate issues need to be addressed. First, is the science well done, and are uncertainties and limitations in the data properly recognised? The answer to this question determines whether the assessment represents good science. Second, does the science provide a firm basis for policy decisions? The answer to this question determines how useful the assessment will be to the policy-maker, whether decisions will have to be taken in the face of uncertainty, and whether further studies (perhaps including experimental work) should be carried out.
9.25 Scientific assessments should indicate clearly where the boundaries of knowledge lie. To be helpful to policy-makers they should indicate clearly both what is known or considered to be indisputable and what is considered to be speculative.
9.26 Transparency should be the watchword in presenting assessments. It is essential that there should be a succinct narrative summary of the assessment covering the underlying scientific basis, uncertainties in the evidence and the rationale for any methods used to cope with variability and uncertainties (for example, any safety factors used) and the assumptions implicit in their use.
9.27 A scientific assessment should present the range of possible interpretations of the available evidence, or the range of scientific possibilities and options concerning a particular course of action, accompanied by acknowledgement of the assumptions and uncertainties implicit in the assessment. The outcome of a scientific assessment should not normally be presented as a single option or statement; an assessment yielding a single answer ( especially a single number) may give a spurious impression of accuracy.
9.28 It is necessary to build review processes and the potential for revision into standard-setting procedures. Scientific knowledge can move rapidly and standards must be readily adjustable and regularly reviewed, so that new insights can be incorporated.
9.29 To prevent development of new understanding being restricted by established regulatory procedures, vested interests or small closed communities of experts, publicly funded programmes of environmental research should include provision for independent investigation and inquiry.
9.30 We welcome monitoring by the Office of Science and Technology (OST) of
(a) the extent to which Departments are modifying their procedures for using scientific advice in policy-making in response to the principles produced by the Chief Scientific Adviser;
(b) Departmental and agency procedures for early identification of issues for which scientific research or advice will be needed.
39. It is important that policy makers (including both Ministers and officials) and the public should understand the limitations of scientific knowledge in particular cases, and the uncertainties surrounding scientific advice. The Government therefore supports the need for these issues to be highlighted when scientific assessments are being put forward, and for the process to be as transparent as possible.
40. The Government believes that ethical and social considerations need to be factored into the debate on scientific issues. That is why, for example, it is setting up two Commissions (the Human Genetic Commission and the Agriculture and Environment Biotechnology Commission) to form part of a new strategic advisory structure on biotechnology. The two new Commissions will work alongside the existing regulatory and advisory bodies, which will continue to consider detailed scientific evidence in relation to individual products or processes.
41. The Government welcomes the Royal Commission's support for the guidelines produced by the Chief Scientific Adviser (the May Guidelines). The implementation of these is overseen by the Ministerial Science Group. Two annual reports on Departments' progress in implementing the Guidelines have been produced since they were published in 1997. A review of the Guidelines themselves has recently been undertaken, involving public consultation, to establish what, if any, changes are needed. The intention is to produce a revised version of the Guidelines in summer 2000.
42. The Health and Safety Executive (HSE) is leading a research project sponsored by eight Departments and Agencies to produce principles of good practice for securing expert scientific advice and incorporating the advice in policy. The principles and accompanying guidance will complement the May Guidelines, and will address issues such as the selection, remit and independence of scientific experts; avoidance of bias; characterisation and reporting of uncertainty; resolution of conflict and presentation of the advice.
Published 21 November 2000
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