Engaging throughout the Risk Assessment Process - A workshop of the digital event series on the evolution of EFSA's engagement framework
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Engaging throughout the Risk Assessment Process A workshop of the digital event series on the evolution of EFSA’s engagement framework 22 June 2021 Virtual meeting
1. Background The digital event series on the evolution of EFSA’s stakeholder engagement framework started with a kick-off event (held in October 2020) to set the scene, report back on how EFSA has taken onboard stakeholders’ input so far and to introduce the series of thematic events focusing on the three engagement streams of the evolved engagement framework around quality of science, preparedness for future challenges, and stakeholder dialogue, and to gather stakeholder input to fine-tune them as appropriate. The third workshop of the series focused on the ‘Quality of Science’ stream of EFSA’s evolved engagement framework. The main objectives of this event were to: • provide a clear overview of the engagement windows in both the applications and mandates cycles put in place by the Transparency Regulation; • understand the level of familiarity of registered stakeholder with these engagement opportunities including with the ‘ground rules’ for providing input, the feedback loops and additional options (e.g. Open.EFSA, Connect.EFSA); • manage expectations regarding the extent of possible engagement considering that EFSA needs to adhere to their mandate as a neutral, science-based entity, • gather suggestions on how the engagement processes itself could be further improved and how information on it could be shared more efficiently. The outcomes of the workshops will be discussed at the Stakeholder Bureau meeting of October 2021. Based on the input by the Bureau, the fine tuning of the way forward will continue at the Stakeholder Forum 2021, which will be considered as the concluding appointment of the series. 2
2. Outcomes of the workshop Information session on engagement opportunities as part of a lifecycle of a mandate After a presentation of engagement windows in EFSA’s mandate lifecycle, participants were invited to respond to a short poll: Participants were then invited to think about how EFSA could improve the accessibility of information on engagement opportunities in the life cycle of a mandate. Here are the questions and comments received orally or in the chat: • One of the tools to tackle mandates is Open.EFSA and the tracked question system, but at the moment, with the new system, it is difficult to find the new mandates. It was easier previously when mandates were organized in chronological order. This is a recurring comment. Could EFSA investigate improving this functionality? • Generally, search engines are useful tools to keep track of mandates and EFSA should investigate further developing such functionalities. Information session on engagement opportunities as part of a lifecycle of an application In the following session participants were then introduced to engagement windows available within the lifecycle of an application. Before opening the floor for discussion, participants were requested to answer a short poll: 3
As with the previous session, the floor was opened for participants to comment and think about ways EFSA could improve access to information on engagement windows in the context of applications. Here are some of the key comments and questions: • Manufacturers plan many years in advance. The list of intended studies on Connect.EFSA is well understood, however it is quite normal that, during the period that follows, plans need to be adjusted for instance with studies unveiling the need for further research. After public consultations, if there are plans for more studies to be submitted, is there a chance that applicants could submit additional data? • Are peer review meetings accessible to observers? It doesn’t seem to be the case now; however, this is seen with other agencies such as ECHA and it seems to work well. • When a conclusion is released at the end of a mandate, it is taken by the European Commission to investigate risk management. During the process that EFSA has gone through to get information and different perspectives, if there has been extra information gathered at that point, is there any opportunity for an applicant to engage? • The Pesticide Scientific Network has been mentioned. What types of skills are represented in this network? Engagement outside mandate and application: partnering for scientific quality After a short break, participants were introduced to engagement opportunities existing outside the framework of mandates and applications. The floor was then opened for comments and questions: • What will be the scope of the upcoming digital platform for registered stakeholders? It has been noticed that the current Stakeholder Forum is not sufficiently focused on science and can get quite messy sometimes. In general, duplication of platforms should be avoided as much as possible. A suggestion could be to have engagement activities (roundtable, discussions) with less 4
participants but focused more on science, and a stakeholder platform available for less science-oriented stakeholders who wish to engage with EFSA. • On the SPIDO project specifically, is there a harmonised way to engage stakeholders now? EFSA’s scientific engagement cycle To get a better understanding of stakeholders’ perception of engagement opportunities with EFSA in general, a short poll was launched: Following up on this poll, participants were sent into breakout groups, where they were invited to discuss where they still see gaps in the engagement with EFSA and what they think could be solution or ideal scenarios to bridge those. Below are the key take-outs from these group discussions: 5
Breakout group 1 – Katharina Faradsch & Cinzia Percivaldi GAPS in mandate/application/other SOLUTION & Best-case scenarios to engagement address the gaps Technical meetings following a public More dialogue/details on the reason why a consultation on a draft scientific output stakeholder’s comment is discarded by the sometimes come too late in the process, panel (not just taken/rejected). when the margin of manoeuvre is not enough to inform the draft scientific output before its adoption with the comments of stakeholders (little influence). No overview of mandates to be informed Communicate more clearly in a single about engagement opportunities on location the new/upcoming mandates and new/upcoming mandates. the engagement opportunities associated to them (e.g. an enhanced Open.EFSA). Make engagement opportunities more See EMA as example of best practice. open to a broader public (e.g. NGOs and consumers who do not necessarily have scientific skills). Receive more guidance from EFSA on the Please improve the process, be more open type of tests and data that should be and provide recommendations. generated to support an application. Now it is very difficult to obtain technical recommendations/support – in particular to reduce the use of animal testing; opportunities to change an OECD protocol to obtain more information. Breakout group 2– Matthew Ramon & Mihai Popa GAPS in mandate/application/other SOLUTION & Best-case scenarios to engagement address the gaps Open EFSA – the general public/media. Are More opportunities for the stakeholders to they aware of the EFSA changes? engage – more communication channels Widening the EFSA audience and engagement activities 6
Open EFSA and Ask EFSA – rather technical Gather all the engagement opportunities in (not easily accessible) one platform Hard to find reliable information (from the public perspective) Not enough focus on science Working Group meetings – minutes too Discussion groups – quite effective. Should short. More details are needed when writing be used more frequently. the minutes of the meetings. Pre-notification for mandate – an improved process that could be more clear If it is possible before publication. Breakout group 3 – Max Blanck & Paula Rozadilla Castillo GAPS in mandate/application/other SOLUTION & Best-case scenarios to engagement address the gaps There would be a feeling that comments are - The possibility of having a second lost, especially when it comes to guidance round of comments dedicated to documents. registered stakeholders (not including public here). - New ways to support transparency for clustering of comments, with the purpose of improving feedback. - 1-hour info session to inform on the expected type of comments, particularly on big guidance documents, just after the public consultation has been launched. Perhaps in the form of a webinar. This would help participants in managing their time more efficiently by providing to-the-point contributions. This would also facilitate the clustering of comments and support transparency. Tracking related to mandates would be Possibility to subscribe to particular topics: relevant to be improved. not to miss any topic of interest, to be possibly tackled by the digital platform. 7
Better explanation to support info sharing More sharing of info from EFSA to for members of stakeholders. stakeholders to be shared with members would support clarification of information. Breakout group 4 – Clara Boissenin & Maria Scherbov GAPS in mandate/application/other SOLUTION & Best-case scenarios to engagement address the gaps - In light of the Chemical Strategy for One Substance, One Assessment (OSOA) to Sustainability, there is the need for be used as possible hook for that and needs agencies (e.g. EFSA and ECHA) to stakeholder involvement to ensure come together to address future transparency and inclusivity of the process. issues/challenges and to proactively interact with the stakeholders throughout to strive for common processes/harmonisation. - There is a lack of mutual stakeholder engagement (and transparency) when it comes to some of interactions between the agencies, in particular when it comes to the One Substance, One Assessment (OSOA) approach. Gaps in the application process include: - Allowing more time for submitting - The timelines for engagement the missing items during the which doesn’t allow for enough stakeholder engagement process. time to address the incompleteness - There is an overall need for the of information and data gaps. advice to be binding, of course, - Non-binding advice/engagement taking into account the legal remit of from EFSA EFSA. 8
3. Conclusions and recommendations The workshop provided an opportunity for stakeholders to communicate their doubts and concerns and constituted a possibility for EFSA to get valuable feedback to be considered in the continuing evolution of the engagement framework. While the opportunities for engagement that are made available during the lifecycles of applications and mandates appeared to be reasonably clear to the participants, a feeling of confusion seemed to persist towards the proper venues through which to access relevant information. This degree of confusion among registered stakeholders implies the need to strengthen external communication efforts. If possible, communicating earlier about engagement opportunities would help stakeholders better prepare to contribute. The workshop has also revealed stakeholder needs which could affect the current engagement culture in EFSA and the development of new processes. EFSA’s teams should discuss the degree of engagement possible, boundaries, as well as when and how to engage in the future. For instance, there is demand for better feedback on the engagement activities, especially of the public consultations, such as further improving the transparency of the clustering approach. Participants also expressed the desire for info sessions once a public consultation is launched to inform them on the nature of the required input. This would allow for a more efficient use of time by the stakeholders in drafting contributions but also by EFSA during the analysis of the inputs. While some of these points could potentially be addressed by improving the functioning of existing tools (Open.EFSA, Connect.EFSA ), the upcoming digital stakeholder platform, the concept of which was co-designed in previous meetings of the series, needs to be integrated in the solutions and become central to efforts to improve information flow. 9
4. Stakeholder evaluation A total of 22 stakeholders came to the workshop, out of a total of 30 registrations. The registrations covered the following groups: Academia 4 registrations Business and Food 16 registrations industry Consumers 1 registration Distributors 2 registrations Farmers 1 registration NGOs 3 registrations Practitioners 1 registration Other 1 registration The evaluation took place through a form sent to participants in the chat on Zoom at the end of the meeting, and through a follow-up email. The questions were based on the evaluation carried out by EFSA at previous workshops of the series. The form was hosted on a platform of EFSA’s choice and 41% of the participants responded to the survey. How would you rate the workshop overall? 100% of respondents declared that their event experience was good or excellent. This is the same appreciation level as in the Preparedness workshop and the Stakeholder Dialogue workshop. Has the event fulfilled your expectations? All respondents considered that the workshop fulfilled their expectations. 10
Participants generally found that the workshop helped them gain a better understanding of engagement windows around mandate and application, though some participants felt that the meeting hasn’t helped them get more familiar, flagging a below average to poor understanding of the issue. Familiarity of with the event topics Excellent Good Average Below Poor average Before the event After the event Along the lines of similar evaluations in the past, respondents reported their ‘digitalisation fatigue’ and missed interacting in-person with EFSA and other stakeholders; and the effectiveness of digital meetings compared to physical ones was questioned again. An increase in participants flagging they get more distracted online is seen, probably due to the more informative, less interactive nature of this workshop. In general, the different aspects of the workshop were considered either good or excellent, in particular the content, the presentations and the relevance of the topics. However, a third of participants felt there wasn’t sufficient time allocated to interaction. 11
0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Event content / agenda Relevance of the topics addressed Presentations Time allocated to Q&A and interaction Event format Event length Online platform Excellent Good Average Below average Poor Do you think EFSA is evolving its engagement framework in the right direction? Finally, just like for the Stakeholder Dialogue workshop the totality of respondents is convinced that EFSA is evolving its engagement framework in the right direction. 12
5. List of participants Stakeholder Association Stakeholder Category Camille Perrin (BEUC) Business and Food Industry Costanza Rovida (ECOPA) NGO Erna Botjes (EFA) NGO Eugenia Chaideftou (SETAC) Academia Fran Proscia (FVE) NGO Gülden Pekan (EFAD) Practitioners Hans Mattaar (ECCA) Business and Food Industry Jennifer Lewis (IBMA) Business and Food Industry Jakub Rusek (FEDIAF) Business and Food Industry Jan Demyttenaere (EFFA) Business and Food Industry Jeroen Meeussen (ERM on behalf of IBMA) Other Josep M. Pagès (ENA) Farmers Kalila Hajjar (FEDIOL) Business and Food Industry Kinga Adamaszwili (EDA) Business and Food Industry Laurent Lagadic (SETAC) Academia Laurent Oger (CropLife Europe) Business and Food Industry Martina Helmlinger (FEFANA) Business and Food Industry Miguel Angel Prieto Arranz (CEFIC) Business and Food Industry Patrick Coppens (Food Supplements Europe) Business and Food Industry Rebeca Fernandez (FoodDrink Europe) Business and Food Industry Timothée Jourdain (EuChemS) Academia 13
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