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Date: Wed, 8 Oct 2003 12:00:41 -0400
Reply-To: PSA Forum
Sender: PSA Forum
From: Edward Groth
Subject: Groth Comments on Paper 1a
Comments: To: fao.who.psaforum@WHO.INT
Content-Type: text/plain; charset="iso-8859-1"

Dear Forum Colleagues,

Before making comments on this first paper I would like to suggest that each of us "introduce ourselves," as we might if we were all in a room together, so that we may have a better sense of "who is speaking." I myself am a Senior Scientist with Consumers Union, a non-profit consumer testing, publishing and advocacy organization, in New York, USA. I have participated in about a dozen Codex meetings on various topics over the past decade, representing Consumers International, and have taken part in other joint WHO/FAO events, as either an invited expert or a CI delegate. I am a biologist by training, with more than 30 years of professional experience in the areas of environmental health, food safety and risk communication. Before I came to CU I worked for five years as a staff member at the US National Academy of Sciences, which provides scientific advice to agencies of the US government.

Regarding Paper 1a:

This paper gives an excellent overview of issues to be considered by the Forum. I have comments on several general themes that will resonate through discussion of many other papers:

(1) Boundaries. In essence, where does "science" and "scientific advice" end, and "policy" or "risk management" begin? In order to manage the work of expert bodies more effectively, the international community needs a clear definition of the appropriate tasks and roles for these bodies. Sometimes this is clear (e.g., reviewing scientific data is obviously a task for experts.) But sometimes, the boundary between science and risk management is blurred. For example, when JECFA or JMPR establishes an ADI or an RfD, part of that decision (a judgment about the safety margins that should be incorporated) is a risk-management decision. While such decisions must have a basis in science, they also rest on value judgments and perceptions of trade-offs which are not necessarily best resolved by scientists meeting in a closed session, with few or no inputs from affected stakeholders. Granting that things have been done this way for a long time, we should ask: Is this the best way to make such decisions? And if not, what different models should we consider for how the process should work? One possibility is to narrow the tasks for the expert bodies and place responsibility for such risk management aspects squarely on the policy-making Codex committees. A more practical solution might be to improve and expand the interactions between risk assessors (expert bodies) and risk managers (Codex committees). Which approach of these (or others) is preferred will have many implications for how the process should be "redesigned."

(2) Resources. Many steps could be envisioned to improve the quantity, quality and efficiency of the scientific advice system that supports Codex. Many of those steps would require expanded resources. In comments I will make on later papers, several ways to improve the system would only be feasible with an expanded professional secretariat. I think it is incumbent upon us as we discuss these issues, to try to identify resources needs as explicitly as possible. A stronger scientific advisory system, capable of meeting the current and expanding needs of Codex, will have a price tag. We need to spell that out so that FAO and WHO can make needed budget adjustments.

(3) Communication. The importance of improved communication is evident in several ways in Paper 1a. A common problem (noted here) is that sometimes the request from a Codex committee for scientific advice is unclear, too broad, or inappropriate. The paper by WHO/FAO presented to the 26th meeting of the Codex Commission in July of this year includes a section on communication, which describes some significant recent improvements in disseminating information about the work of expert bodies. However valuable these improvements have been, they are primarilty one-way, "outbound" communication. A very clear need exists to create mechanisms for interactive communication, within the system: Communication between risk assessors and risk managers, and communication among both of those groups and various stakeholders and interested partries with significant information and perspectives to contribute. More and better communication among all the "players" is needed to better define priorities, improve efficiency, and enhance the usefulness of the expert advice that is provided. Communication, of course, requires time and resources that could also be used for other things (such as producing risk assessments). But communication needs to be a fundamental part of the process, designed in at the outset, not a secondary element added on at the end.

I will return to these themes in commenting on other papers in the coming days.

Thank you for considering these remarks, and I am looking forward very muct to seeing the views of others and exploring how well this interactive E-Forum can work.

Sincerely,

Edward Groth III, PhD
Senior Scientist
Consumers Union of United States., Inc.
101 Truman Ave.
Yonkers, NY, 10703-1057 USA
Phone: 1-914-378-2301
Fax: 1-914-378-2908
e-mail: groted@consumer.org