FSA Response to Public Body Reviews 2022-23
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The FSA’s Scientific Advisory Committees (SACs) are non-statutory and advisory non-departmental public bodies (ANDPBs) or Departmental Expert Committees (DECs) which are subject to review under the Cabinet Office’s ‘Guidance for the Review of Public Bodies’.
In August 2022, the FSA set out the intention to review all 8 SACs per the guidelines, including an independent review of the Science Council (SC) and Advisory Committee for Social Sciences (ACSS). The FSA has completed an internal review of three of its SACs, and one review encompassing all three Joint Expert Groups (JEGs). The FSA commissioned external experts to undertake the independent review and the report and recommendations were submitted at the end of March 2023.
The purpose of these reviews is to provide assurance to the FSA, and its stakeholders, that the SACs and JEGs roles and purposes are appropriate in addressing the future needs of the FSA, consumers and wider government, and that the bodies are operating effectively and efficiently. The SC and ACSS were the only two SACs submitted to Independent Review due to this being the first review cycle since they were commissioned in 2017.
FSA’s Response to the Internal Reviews
The internal reviews of the FSA SACs were completed using Self-Assessment Models (SAMs) provided by the Cabinet Office in their ‘Guidance for the Review of Public Bodies’.
The committees reviewed by SAMs were;
Advisory Committee for Novel Foods and Processes
Advisory Committee for the Microbiological Safety of Food
Committee on the Toxicity of Chemicals in Food, Consumer Products, and the Environment
Joint Expert Group for Additives, Enzymes and other regulated products
Joint Expert Group for Food Contact Materials
Joint Expert Group on Animal Food and Feed Additives
Recommendations from the Internal Reviews
All committees were found to be in good working order. There are five common recommendations from all four published internal reviews.
1. The SACs should consider publishing a complaints procedure on its website.
2. The SACs and FSA could consider publishing performance data to show transparency around SAC performance.
3. The SACs should consider publishing rules on lobbying and guidelines for political activity for SAC members to ensure compliance with any restrictions.
4. The SAC Chairs should be given opportunities to meet with the FSA Board, as is stated in the CoPSAC.
5. The FSA Board should send an annual 'Chair's Letter' to the SAC Chairs setting out the FSA’s short-term priorities and expectations.
Response to the Internal Reviews
The FSA notes recommendations 1 and 2 and will look to implement these for future updates to the SAC websites and best practices. The practicalities of implementing these considerations are being discussed with SAC Chairs.
In regard to recommendation 3 it is felt that this is covered satisfactorily by our thorough declaration of interest process and during the recruitment of all SAC members. All members’ declarations of interest are shared publicly on our websites and if any conflicts occur, they are clearly recorded in meeting minutes.
It is felt that recommendations 4 and 5 are currently covered satisfactorily. The Chair of the Board of the FSA is invited to the biannual SAC Chairs meetings, which are chaired by the FSA’s Chief Scientific Advisor (CSA). These meetings are a forum to facilitate cross working of the SACs, and for the Chair of the Board and CSA to address the SAC Chairs. Typically, priorities and expectations are already discussed during that meeting, but going forwards we will explicitly signpost these within the meeting papers/minutes. Alongside these SAC Chair meetings, where it is felt important or of interest, Board members will be invited to observe sections of relevant SAC meetings. It is felt that these meetings are sufficient to create communication opportunities with the FSA Board, whilst allowing the SACs to operate and work independently.
FSA Response to the Independent Review of Science Council and the Advisory Committee for Social Sciences
The FSA would like to thank Professor Sir Charles Godfray and Professor Annette Boaz for their thorough approach in undertaking the Independent Review of the FSA’s SC and ACSS. The FSA feels that the report and recommendations will have a wide impact and be helpful for assuring the SC and ACSS are in the best possible position to support future work of the FSA and its SACs.
The FSA is pleased with all recommendations that were put forward by the Independent Review. Further details of our response to each of the recommendations is provided in the table below.
1. The SC shifts its focus from producing infrequent large reports to becoming more involved in helping the FSA deliver on its operational agenda*.
*For clarity, the reviewers define ‘operational agenda’ as “the SC getting more involved in helping the FSA face the challenges it encounters in delivering its current main objectives and mission.”
2. The FSA considers a role for the SC in planning its response to a major emergency or crisis.
The FSA deeply appreciates the work of the SC over the 6 years of its existence and recognises the important role it has played in supporting and building capacity at the FSA. We therefore welcome the recommendation to move SC’s working model to more short, sharp, responsive pieces that are timely for the FSA’s needs, in order to ensure that the combined SC expertise is of maximal benefit to the organisation.
Some examples of these types of input could include;
We are committed to working with the SC and jointly deciding how to implement practical working models that do not impact on the quality of the current work produced by SC.
The FSA feels it is important to emphasise that the SC should not be routinely involved in operational FSA discussions, since that may complicate the governance of operational decision making. However, we recognise that SC members are experts in their fields and therefore may be of considerable value in providing informal, ad hoc advice, especially to fast-moving incidents within their area of expertise.
It is important to note that the FSA’s Operations Directorate is currently reviewing emergency practices across the FSA. Consequently, once this review has concluded, we will take steps to ensure that SC members’ areas of expertise are well understood across the FSA, with ‘access routes’ to informal SC advice clearly mapped out.
3. All FSA units are made more aware of the SC with a clear articulation of how it can assist the Agency’s work.
4. The SC secretariat and the CSA takes a more proactive role reaching out to different parts of the FSA to identify areas where the SC might contribute to the FSA’s mission, and to ensure members are fully briefed on FSA priorities.
12. FSA officials more clearly articulate where the ACSS can best help support the Agency’s work.
We agree that there could be better sharing of knowledge across the FSA to increase awareness of the purpose of the SC and ASCC and support both groups in setting the direction of their work. Therefore, we commit to build on the work we already do to further raise the awareness of the SC and the potential roles they could play to support teams across the FSA.
5. The SC chiefly engages with the Board and Senior Leadership Team through the CSA and through the submission of an Annual Report to the Board. In addition, the SC through its Chair would have the right to meet with the CEO and/or Board Chair to discuss specific issues if they felt it necessary.
We agree it is sensible to keep SAC Chairs at arm’s length from the FSA Board, with communication via the CSA, to prevent any misinterpretation of the independence of our SACs in delivering advice to the FSA. We also agree that there may be exceptions to this rule, whereby the SC Chair wishes to raise and discuss a specific issue directly with the FSA Board. In these circumstances the SC Chair could directly contact the FSA Chair and ask for the issue to be raised to the Board. Contact could be via email, or at a SAC Chairs meeting, as discussed above in our response to the internal reviews.
6. A more proactive strategy of SC recruitment with targeted approaches made to potential candidates.
7. SC membership is expanded to include social scientists.
The FSA notes this and will use it to feed into an internal review of our SAC member recruitment in time for the next campaign planned for September 2023, where the FSA will seek to expand membership of the SC to include social scientists.
We need to be fair and open with Public Appointment processes but will seek to build on work that has already been started on ways in which we can advertise to potential candidates.
8. The SC moves from meeting twice to once a year in public session.
9. SC open sessions are held to coincide with a major meeting of a relevant society.
We agree with reducing the number of public sessions from two to one. Coinciding SC meetings with a relevant society major meeting will be taken forward where possible and appropriate to encourage public attendance at these meetings. The FSA will look to model this in the SC and consider the approach for the other SACs in future.
10. SC members are paid a flat honorarium, rather than payment by the hour, with the Chair receiving a higher fee.
15. ACSS members are paid a flat honorarium, rather than payment by the hour, with the Chair receiving a higher fee.
We recognise the potential advantages of a fixed honorarium although also note that this may, in some situations, be restrictive. We are therefore investigating several alternative scenarios for SAC remuneration with a view to simplifying this process and better aligning it with remuneration practices in other departmental SACs.
11. We found that the ACSS played an important role in supporting social science evidence commissioning and interpretation at the FSA and recommend it continues doing this good job in much of its present form.
13. The way the SC and ACSS together provide social science expertise and support to the FSA is reviewed again once our recommendations, if implemented, have had time to settle in.
14. During future recruitment that the ASCC retains its economic analytical function and supports the FSA in expanding capacity in this area.
In the next review cycle, the FSA commits to reviewing the distribution of social science expertise and the interaction of the SC and ACSS with regards to social sciences at the FSA.