On 22-23 September the NGO Corporate Europe Observatory is organizing an event in the European Parliament called “Science vs. lobbying – How to escape regulatory capture?” I very much welcome this initiative as indeed this is an issue that requires attention and a public discussion is overdue. In the past, industry and NGOs too often sat in their ideological trenches and such debates open the possibility to talk to each other. Having worked for the European Commission’s Chief Scientific Adviser (CSA) in the past three years, I would like to add my view to the debate.
First of all, let’s be clear that the overwhelming majority of scientists are honest people committed to deliver the best possible evidence. Even in cases where uncertainty is high, I would always rather believe in the educated guess of a scientist than the “facts” presented by non-scientists.
However, we should also be clear about the fact that the ivory tower is not populated by fairies and elfs. Actually, looking closely, the ivory tower is not even pure white, but has a lot of grey patches here and there, a couple of satellite dishes, some do-it-yourself wiring on the façade, drying clothes and flower pots on the balconies, a large set of door bells with exotic names, and a battery of mailboxes, some of them having a “no advertising” sticker. It is inhabited by very different people, from fuzzy Einsteins, to Big Bang Theory nerds to people just like you and me – and yes, there are always people going in and out (the only strange thing is that the door mat with the word “Welcome” is faced towards the inside, i.e. you can read it when stepping out).
In other words: scientists are no saints. Even if they are committed to good scientific practice they are social animals that have their convictions that may distort their view when interpreting the evidence. To overcome this natural bias, science has invented a system called peer review. It’s not perfect, but it’s the best we have (one could amend the famous Churchill quote to: “Peer review is the worst form of review, except for all the others”). What has gone through peer review can reasonably be trusted, despite the few black sheep which will always fool any system. Evidence accumulates over time and, although evidence sometimes contradicts each other, you will get something you can call a scientific mainstream or “consensus” (which is not static, but develops as new evidence comes in).
Now let’s talk about science advisers. Science advisers interpret and translate the evidence to somebody (e.g. a politician) who is not an expert in the field. Here comes an issue many NGOs are worried about: How to ensure that the science adviser is an honest broker and not somebody who provides distorted evidence, being lobbied by industry? The answer of some NGOs seems to be very easy: any scientist who has ever had contact with – yet alone worked for – “big” industry is per definition biased and cannot sit on advisory boards, e.g. of EU Agencies. That’s of course the nuclear bomb approach, eradicating all the good and the bad stuff. It ignores not only that scientists are supposed to work with industry (e.g. to turn scientific results into products for the benefit of all of us), but also that industry – which provides more R&D funding than the public sector – has an important role to play because industry lives in the real world and has to implement many policies, thus being an important source of advice as well.
Of course, industry has interests. They want to make profit. It’s the same way NGOs have interests and follow a particular agenda because that’s what their funders expect them to do (believe it or not, even anti-lobbying NGOs are lobbying for something). The difference is that industry has money, while NGOs have not, so it’s an uneven battle. So the question is, and here the NGOs certainly have a point, how to prevent that science advisers are misused as a back door to get lobbying interests into politics, being cloaked as “independent” scientific evidence?
The fact that Anne Glover, the former Chief Scientific Adviser in the Euroepan Commission, had an impeccable scientific record, seven honorary degrees, and never worked for industry, obviously wasn’t sufficient to convince NGOs of her independence.
Let’s feed in a story here. In October 2013 Anne Glover organized a meeting with two scientific camps who were bombarding each other via journal editorials and open letters on the issue of endocrine disruptors. As she thought that this clash was not helpful for policy-makers, she invited 3 experts from each camp – they could choose themselves who – to her office (each expert had to pay for his/her own travel expenses as the CSA office had no budget for this). Policy-makers were not invited to avoid that any of the two groups tried to lobby them. The meeting lasted three hours, in a constructive atmosphere, and the participants were able to agree afterwards to conclusions that outlined where there was consensus (actually, there was quite a lot) and where there was not (either because there wasn’t sufficient evidence available or because there was disagreement on how to interpret it). After the meeting the polemics between the camps stopped and scientists from both sides as well as policy-makers applauded the CSA’s initiative. It was an honest attempt to solve a scientific dispute in a scientific way.
What happened afterwards was that the CSA got attacked by NGOs: that she was a lobbying conduit of industry, that she had given a stage to scientists that were in the pockets of industry, that she has lifted this to the highest stage by copying in the top level of the Commission (which was her duty – after all, her boss was the President). A French journalist produced a film portraying the CSA as a target of industry lobbyists intending to delay legislation (in fact, according to the Commission the involvement of the CSA in the case had no impact on the sequence of events leading to the decision to make an impact assessment, and anyway the CSA never had any influence on the policy process itself). The CSA office got bombarded with freedom of information requests from NGOs asking to release every single e-mail related to GMOs, endocrine disruptors, the precautionary principle and many other topics (all of them were released). The CSA became a kind of hate figure for the NGOs, arguing that the CSA role had to be removed. The main argument was: one person as a science adviser is too easy to influence (interestingly, this argument is not brought forward against the UK Chief Scientific Adviser or the Chief Scientist of Greenpeace).
In my opinion, a lot of these arguments stemmed from a wrong impression of what a Chief Scientific Adviser is and can do. The impression among NGOs was: there is a high-level figure next to the President who has the power to override all the scientific advisory processes that happened at lower levels, whisper anything into the President’s ear and then the President snips with the finger and the policy comes to a halt or is changed significantly. Indeed, industry tried to lobby the CSA on various occasions, probably following the same assumption. Even representatives from the scientific community sometimes seemed to believe that the CSA would mark a new era in which all policies would be based on evidence.
The reality is much more simple. Neither was the CSA consulted on policy proposals of the Commission nor did she try to exercise such an influence. With one exception she never participated to meetings of the College of Commissioners, and the President met her only occasionally, being busy with other things. In any case with very few staff in the office there is not much you can do.
Let’s be clear: Science advice given to politics does not replace or override scientific-technical support given to policy. They are complementary. It’s not the job of a Chief Scientific Adviser to check that every single number in a piece of legislation is correct or even to change the numbers. It’s his/her job to help the politician understand what the numbers mean. A science adviser is not an evidence provider, but an evidence translator. Of course, it is up to the politician whether he or she wants to listen to the advice or not. For sure the least a science adviser wants to lose is his or her scientific credibility by providing advice that is not backed by the scientific community at large.
The NGOs criticized Anne Glover for being “unaccountable, intransparent and controversial”. Was she controversial? Yes, without any doubt because she dared to speak up for science on politically controversial topics. Obviously, the science academies of Europe felt represented by her opinions, otherwise they would have complained. Was she unaccountable (apart from being obviously accountable to her line manager, the President)? No, because contrary to political and economic advisers she voiced her views in public, thus opening them for scrutiny by her fellow scientists. Was she intransparent? Ah, here comes the tricky point.
In my view, the Chief Scientific Adviser in the European Commission would have been more successful if the role would have been allowed upfront to be much more transparent. There is no doubt that the best way to ensure that scientific advice is unbiased is full transparency – here I am fully on the side of the NGOs. The new Commission rule whereas Commissioners and Directors-General can only meet with lobbyists who are on the Transparency Register and that all such meetings should be published is certainly a big step in the right direction. Also, conflicts of interest must be made transparent in a consistent manner and this includes, of course, scientists. Managing conflicts of interest is not rocket science.
However, I would go a step further and would like to see this transparency applied throughout the policy process. There should be clear guidelines for Commission services on how to procure, use and communicate scientific evidence, as practices vary considerably. One possibility would be to create something like an “Evidence Portal”, on which Commission services would publish “calls for evidence”. Everybody who thinks to have useful evidence can submit it via this portal and it would be transparent for everybody what the evidence is and who submitted it, be it academia, industry, NGOs or citizen scientists. This would be followed by a quality assessment step, synthesizing and valuing the evidence, again the results being made transparent. And then comes the political step in which the policy-maker weighs the evidence against other factors, such as economic viability, ethical considerations, social acceptance, etc. This may lead then to a decision to ignore the evidence or parts of it. Perfectly fine, that’s democracy. But again, this should be made transparent – if the evidence is ignored, politicians should say so and say why.
This way we would get much more honesty into the political debate. If there is something to be learnt from the GMO story, then that we should never allow science to be blamed by politics for taking or not taking a decision which in reality is motivated by other reasons. Transparency, combined with a code of ethics, is the way to go, for politicians, for public administration, for industry, for NGOs, for scientists – and, naturally, science advisers.
Editorial remark: Following a comment received I have corrected the paragraph describing the endocrine disruptor case.