Introduction
Principles
Intervention rationale
Assessing public concern
Creating intervention options
Precautionary action
Limits to Government intervention
Appraising costs and benfits
Public involvement
Developing options into solutions
Implementing solutions
Public concern assessment
tool
This
guidance is designed to help decision makers address
the risks that the public faces, and also its
perceptions of risk. Government has a role to protect
and assure the public, which includes taking cost
effective action to reduce risk, and to provide
accurate and timely information about risk.
One objective of
this guidance is to achieve greater consistency and
transparency in government decision-making. It aims
to achieve this by recommending greater use of
evidenced based values of preventing fatalities, and
other harms, and supports further studies to inform
our understanding of the appropriate economic values
to use given differences in context.
This guidance also
recommends that, alongside the economic analysis of
options available to reduce risk, decision makers
should take explicit steps to involve the public: to
understand what they are concerned about and why, and
to communicate good information about risk, targeted
to the needs of the audiences involved.
The guidance also
contains a tool (see Appendix A) to help structure
and make explicit the evaluation of concerns that may
exist about risks of fatality and harm, which is a
strand of decision-making where there is currently
little extant cross-government guidance.
1.4
The Principles of Managing Risks to the Public:
- Openness and
transparency - Government will be open and
transparent about its understanding of the
nature of risks to the public and about the
process it is following in handling them;
- Involvement -
Government will seek wide involvement of
those concerned in the decision process;
- Proportionality
and Consistency - Government will act
proportionately and consistently in dealing
with risks to the public;
- Evidence -
Government will seek to base decisions on all
relevant evidence;
- Responsibility
- Government will seek to allocate
responsibility for managing risks to those
best placed to control them.
2
Rationale for Government intervention
The first stages of
the policy development process involve:
- Understanding
why government is required to intervene. It
may appear to the policy maker self-evident
why government action is required. However,
in practice it is not always obvious.
Understanding the fundamental reasons for
intervention can later help to direct the
policy response.
- Assessing the
level of risk and the nature of the hazard.
If government is justified in taking action,
the next step is to understand the degree of
risk and scale of the hazard that needs to be
addressed. This will often involve expert
assessments of the scientific and medical
evidence.
- Assessing the
level of public concern. Government has a
role to reassure the public, to respond where
public concerns are legitimate, and, in
certain cases, to raise the profile of little
understood or appreciated risks.
Understanding why the public might be or is
concerned can help frame the problem and
direct the policy response. Frequently a key
issue is the lack of effective communication.
Building a two-way communication with the
public from the start is vital to improve
understanding of risks, and consequently the
trust and acceptance of government actions.
3.1 If government
action is justified, an expert risk assessment should
be carried out. Such an assessment will generally
require the exercise of judgement, in structuring the
analysis, evaluating relevant data, conducting
sensitivity analysis etc, and important judgements
and assumptions should be explicitly stated.
3.2 Although
assessment methods are specific to the nature of the
risk being examined, a robust assessment should
generally include the following stages:
- Hazard identification – where the hazard being
examined is defined;
- Risk characterisation – where the potential
effects of the hazard are identified;
- Risk estimation – where the probability and
magnitude of effects are estimated;
- Risk evaluation – where the importance of the
estimated risk is evaluated.
3.3 Risk assessments
should also include an analysis of potential
uncertainty surrounding the risk estimate, which may
be substantial if risks are unpredictable or evidence
is weak. Where uncertainty is very high there may be
need to consider precautionary action (see section
4.10).
Assessing public concern
[see Appendix A below]
3.5 Public, non-expert or lay perceptions of risk can
differ greatly to those of experts because:
- They may have a different understanding of the
nature and magnitude of the risk (and which may be
less well informed);
- They have different and diverse views about the
acceptability of risks, particularly if they are
likely to suffer because of them.
3.6 Involving lay stakeholders in the decision-making
process can assist the creation of policy choices and
greatly improve the public’s acceptance of
policy choices that affect them. It is therefore
appropriate that their concerns are evaluated
carefully.
3.7 Familiarity and experience of the risk
– in general, people are more concerned about
risks which are new to them and about which they have
only a little knowledge or experience.
3.9 Some concerns will be valid; others will be
unsubstantiated by the scientific, or other,
evidence; still others will be generated by
uncertainties about which there is little evidence
either way. It is important that understanding,
reconciling and (where possible) resolving these
different viewpoints should be an explicit objective,
which is likely to require involving the public.
Creating options
4.1 Options should be created and appraised to help
develop responses that meet the objectives and
targets established. The Green Book provides advice
on option appraisal, and the techniques that should
be used, in terms of assessing option costs and
benefits, both monetary and non-monetary.
Precautionary action
4.10 If ... the risks and hazards are currently
unknown or the uncertainty about their likelihood
and/or consequences is very high, but there is a
potential for devastating impact, more limiting
action may need to be taken (e.g. reflecting the
precautionary principle) – to prevent the worst
conceivable outcomes from having the chance to
develop. Normally, precautionary approaches should be
adopted alongside research and monitoring.
Consequently, highly restrictive or expensive
precautionary interventions should be reviewed on a
regular basis in the light of research findings and
new data.
Limits
to government intervention
4.23 Policy makers should also be
aware of the limits to government intervention. The
paragraphs in this section are adapted from Securing
Good Health for the Whole Population, Derek
Wanless (February 2004).
4.24 Interventions to reduce risk
have the potential to significantly reduce personal
freedoms. This is most clear when government acts
explicitly to prevent or restrict individuals from
behaving in certain ways, or from consuming
particular goods. Of course the impact will not
inevitably be restrictive - providing people with
information that they can use to protect themselves
can increase personal freedom.
4.25 In general, if the freedom to
be curtailed or limited is a significant one and
valued highly by the individual, the state would need
strong reasons to impose its will over the individual
on public health or safety grounds. Usually, there
should at least be a strong consensus that the
measure is necessary to prevent harm to others.
Government can of course legitimately intervene when
one person’s freedom to act would infringe
others’ human rights – for example, a
person with a highly infectious disease may need to
be quarantined without consent. In other cases,
however, the mere fact of social or professional
consensus may not provide sufficient justification
for action.
4.26 Ideally, individual consent
provides the strongest foundation for government
action. However, in cases where it is only the
individual’s health and safety that is at issue,
the question of intervention without consent poses
challenges. Nevertheless, there are examples where
such measures have been enacted and have become
accepted. First, individuals may already prefer not
to be free to choose, and may accept restrictions
(the banning of class A drugs, for example). Second,
they may come to accept the reasons behind the
restrictions and no longer see them as an imposition
(legislation to require people to wear front seat
safety belts, for instance). However, it is important
to recognise that measures should be justifiable in
the public interest and to individuals as a
reasonable restriction of their freedom.
Appraising cost and benefits
5.1 Once a range of options has been
created, they should be assessed by estimating their
costs and benefits, and/or by their cost
effectiveness. The Green Book provides more guidance
on how proposals should be costed and adjusted (for
instance, for optimism bias).
5.4 A basic principle in cost benefit analysis is
that benefits should be valued wherever feasible, to
ensure comparison with costs.
Involving
the public
6.1 Involving the public is an important part of the
policy development process. It is vital to understand
how the public perceives issues and whether or not
they are particularly concerned:
- Government, including elected politicians and their
officials, is entrusted to manage risks to the
public. This is one of its core roles and it is
responsible to take into account the public’s
views;
- ... more time and effort is required to communicate
in ways that people can understand, to enable them to
make informed choices and to enable them to trust
those managing risks on their behalf;
- The public can reasonably expect to be consulted,
and to have the chance to challenge ‘expert
opinion’, not least because experts can
sometimes be wrong, be at variance with each other
and be concerned with issues which differ from the
public’s concerns;
- The views of government and society can be changed
for the better by good two-way communication –
it is wrong to think that people’s views do not
change and cannot be influenced; similarly, policies
are more likely to be refined and improved through
consulting the public.
Developing
options into solutions
7.1 More widespread use of evidence-based values
would lead to greater consistency in decision making,
increasing (in certain areas) risk management
activity, and preventing or curbing it in areas where
the benefits are not justified by the costs.
Implementing policy
7.6 the specifics of managing public health and
safety risks will involve in particular: The need for
clear communication strategies (see Chapter 5);
Monitoring of costs, risks and hazards, particularly
where highly interventionist action has taken place,
or where the evidence base is weak; and Continuing to
listen to minority positions and being open to the
possibility of adapting or changing responses in the
light of new evidence.
Appendix A: Concern assessment
tool
This Appendix sets
out a framework for understanding people’s
concerns in order that they can be considered in
policy development and in the development of related
consultation arrangements and communication
strategies. A good understanding of relevant concerns
is necessary for developing an effective risk
management strategy although the effort expended
should be proportionate to the risk in question. The
information gained on relevant concerns should inform
and assist the development and selection of policy
options and the development of the associated
communications strategy. For example, a public
information programme can be implemented if it is
discovered that public concern stems from a lack of
understanding about the risk. Being responsive to
public concerns and involving the public in
decision-making, helps to improve the accountability
and transparency of risk management.
Understanding the
framework
The framework is based on the psychometric model of
risk perception developed by Fischoff, Slovic and
others, in which characteristics of a risk are
correlated with its acceptance. For example, risks
that are undertaken voluntarily are generally
considered more acceptable than risks that are
imposed without consent. Similarly, risks that cause
dreaded forms of harm are also considered to be less
acceptable (see Sections 4.24 – 4.28).
The assessment
framework is based around six risk characteristics
that research suggests are indicators of public
concern. As explained earlier (section 3.7) These six
indicators were chosen as being reasonably
transparent, representative indicators of public
concern which, from the available ‘psychometric
paradigm’ research would correlate well with
almost any other set that is likely to be proposed. A
background note by Baruch Fischoff can be found at http://greenbook.treasury.gov.uk/documents/Fischhoff_Background.pdf
Two of the
characteristics relate to the nature of the hazard
(Awareness and Experience; and Understanding), two
relate to the risk’s consequences (Fear or Dread
and Equity) and two relate to risk management
(Control and Trust). Research indicates that each
characteristic is correlated with concern so, for
example, risks that are perceived to be highly
uncontrollable would be expected to associate with a
high level of concern. By collecting evidence about
these indicators, the framework can help understand
the likely nature and strength of concern and its
drivers.
Collecting evidence
Each indicator should be scored on a 5-point scale by
reviewing relevant evidence. For example, two pieces
of evidence to score the first indicator (Awareness
and Experience) are:
How familiar are people with the hazard?What is the
extent of their experience? For each piece of
evidence a number of bulleted questions act as
prompts to explore related issues. For example, the
first piece of evidence under ‘Familiarity and
Experience (How aware are people of the
hazard?)’ has 3 prompt questions:
- How familiar is the public with the hazard?
- Are all sections of society familiar, or is
familiarity confined to specific groups?
- Are those exposed to risk familiar with it?
These prompts are intended to give an indication of
the range of issues that should be explored to
collect enough relevant evidence to come to a
decision on the extent of concern and not as literal
questions to be asked (e.g. as a questionnaire). They
are indicative and not prescriptive or exhaustive
lists. Having reviewed these prompt questions, a
summary of the evidence should be entered in the
scoring table.
Scoring indicators
Once all the evidence has been collected, it should
be considered as a whole to score the indicator on a
5-point scale, where Level 1 is associated with the
lowest level of concern and Level 5 with the highest.
The specific score should be taken as indicative
rather than a determinant of a particular action and
may be useful in identifying those risks requiring
further consideration for action.
Identifying policy
responses
Possible policy responses to each indicator should be
entered into the scoring table. Suggested policy
responses are discussed in Chapter 4, paragraphs 4.16
– 4.22. It is intended that the information on
concerns should be used to inform but not constrain
decisions on policy developments, options etc. and on
consultation and communications strategies.
Using the framework
Measuring and evaluating public concern requires
expertise and understanding of risk perception. Use
of the framework should be proportionate to the scale
of the policy initiative, the likelihood of high
levels of public concern, the potential impact on the
policy etc. Tools such as the Risk management ladder
developed by Ortwin Renn may assist with this. http://greenbook.treasury.gov.uk/documents/riskmanagementladder.pdf
General principles
The framework provides a structure for organising and
evaluating evidence of actual or potential public
concern but is not prescriptive about the methods by
which such evidence should be collected. However, it
is intended that the framework be used primarily as a
guide for a facilitator to explore public concerns
(e.g. through workshops or interviews) rather than be
used as a questionnaire to elicit views directly.
In addition to
evaluating evidence using the framework structure,
facilitators should also ask the public about their
overall level of concern about a risk to check that
the framework’s output is reasonable. It is
recommended that this be asked both before and after
using the framework, as respondents may change their
opinion after exploring the issue in detail. It may
also be helpful to ask if there are any other
important drivers of concern not already considered
in the framework. For example, people may be
concerned simply because friends or family are
concerned.