General approaches
EC independent Scientific Committees
The Stakeholder Dialogue procedures are intended to enable
structured, balanced, ordered and manageable engagement with stakeholders in
the process of elaboration of scientific opinions by the Scientific Committees
on Consumer Safety, on Health and Environment and on Emerging and Newly
Identified Health Risks (SCCS, SCHER and SCENIHR respectively), whilst ensuring
the effectiveness of the process and compliance with the principle of
independency. These procedures will be implemented as part of the Rules of
Procedure of the said Committees. It needs to be emphasised that the procedures
described below are not intended to be used for each opinion and will be
applied taking into account the expected added value in each specific case and
the need for sound management of the limited resources available. [Annex IV of
Rules of Procedure]
ECDC
According to the founding regulation (EC) No 851/2004 of
the European Parliament and of the Council, the ECDC shall provide independent
scientific opinions and scientific and technical assistance. The tasks of the
Scientific Panels of the ECDC are to assist the Centre in these tasks.
Scientific Panels are set up on an ad hoc basis by the Centre in response to a
need for external or internal scientific advice and their remit and the
duration of their work are stated in advance of their establishment.
ECHA
Representatives of stakeholder organisations regularly
attend meetings of the ECHA Committees as observers following a request of
members of the Committee or the Management Board. Other observers may be
admitted on request of a member of the Committee or the Chair. These
stakeholder observers shall conform to the 'ECHA Code of Conduct for observers
from stakeholder organisations at ECHA meetings [Article 6(6) of the Committee
for Risk Assessment
rules of procedure![pdf](/wel/images/doc_icons/f_pdf_16.gif)
]
EMA
For the EMA industry, patients, health care
professionals are considered as the EMA stakeholders. Activities with
stakeholders are defined in the legislation under article 78 of
Regulation (EC) No 726/2004
Relations with stakeholders are also provided in specific Rules of Procedure
(e.g. for the Committee for Medicinal Products for Human Use (CHMP) Article 23
and 24 of
CHMP Rules of Procedure![pdf](/wel/images/doc_icons/f_pdf_16.gif)
)
Criteria for ensuring independence and efficiency regarding relations with
stakeholders
Independence
EC independent Scientific Committees
Main requirements:
The scientific advice delivered by the Committees must not be influenced by any
consideration other than the scientific assessment of the risks in question.
This principle implies in particular the independence from any external
economic or political interests, but also from bias related to political,
economic, social, philosophical, ethical or any other non-scientific
considerations. The principle of independence refers to the organisation and
results of the process, including in particular the independence criteria and
conditions and arrangements for the participation of members, advisors and
experts. [§ 3.2 of
Rules of Procedure![pdf](/wel/images/doc_icons/f_pdf_16.gif)
]
The stakeholder dialogue procedure shall apply when and as compatible with the
fundamental requirement to ensure the full independence and autonomy of the
Scientific Committees in elaborating, determining and deciding the contents and
conclusions of their opinions and to preserve the integrity of the process for
the establishment of scientific advice. The Secretariat shall suspend the
application of the procedure in a particular case if there is any risk to the
independence and integrity of the process and shall alert the Commission of the
nature and extent of such risk. No aspect of the stakeholder procedure and its
actual application may be invoked as a reason to delay the adoption of, modify
or reconsider a scientific opinion. [§ 8.3 of
Rules of Procedure![pdf](/wel/images/doc_icons/f_pdf_16.gif)
]
Approach:
While the stakeholder dialogue procedures contribute to the implementation of
the principle of transparency and are part of the Commission's efforts to
engage with stakeholders in a spirit of openness and accountability, it should
be clear that the work of the Commission Scientific Committees is, and must
remain, independent of any influence. These procedures must therefore, not be
seen as, and must not be used to interfere with the internal work of the
Committees, claiming a right or trying to be involved in such work or exerting
pressure on Committees' members. The overall aim of these procedures is to
contribute to ensure the highest quality of the scientific opinions adopted by
the Committees. In case of any evidence of significant risks for the
independence of the committees due to the application of these procedures, the
Commission will discontinue their application in part or in total as
appropriate. [Annex IV of
Rules of Procedure![pdf](/wel/images/doc_icons/f_pdf_16.gif)
]
The practical arrangements regarding the ensurance of independence regarding
relations with stakeholders are laid down in § 5 and Annex II of the
Rules of Procedure![pdf](/wel/images/doc_icons/f_pdf_16.gif)
.
ECHA
In order to put its founding principles of
transparency, efficiency and independence into practice and to meet and go
beyond the direct legal requirements governing the issue, ECHA wants to develop
efficient channels of communication, dialogue and engagement with its
stakeholders. This policy of openness and engagement is part of the fundamental
corporate philosophy of ECHA.
For more details on the provisions concerning the integrity and independence of
the Committees and the Forum, please see the document ‘
Proactive engagement with all ECHA
stakeholders![pdf](/wel/images/doc_icons/f_pdf_16.gif)
’, approved by the ECHA Management Board. This document also
refers to the
code of conduct for stakeholders![pdf](/wel/images/doc_icons/f_pdf_16.gif)
, endorsed by
the ECHA Management Board.
ECDC
Main requirements:
According to Article 6(1) of the Founding Regulation of ECDC
(EC) No 851/2004![pdf](/wel/images/doc_icons/f_pdf_16.gif)
of the European Parliament
and of the Council: "the Centre shall provide independent scientific
opinions, expert advice, data and information."
Approach:
All scientific opinions are discussed in the ECDC Advisory Forum before they
are issued by the ECDC Director. The Advisory Forum includes public health
experts from all Member States, the Commission, the WHO, learned societies, and
patient organisations.
All the members of the Advisory Forum can give their views on the final
opinion. However, they only advice the Director: no consensus is needed, and
the Director does not have to take any views into consideration.
A policy on interactions with pharmaceutical industry, including regular update
meetings at ECDC premises on a pre-defined topic set up in collaboration with
industry umbrella organizations is currently developing. This has no impact on
the work of the scientific panels.
EMA
Main requirements:
Please see the Annex II of the
Procedural Advice to CHMP members![pdf](/wel/images/doc_icons/f_pdf_16.gif)
: Committee
for Medicinal Products for Human Use (CHMP) Members Interactions with
Applicants/Marketing Authorisation Holders during the Centralised
Procedure.
Approach:
In the case of applicants/marketing authorisation holders the relation is
limited to the dossier of the applicants.
In the case of health care professionals or patients it’s on a case by case
basis. For patients in very few cases specific meetings have been set up. For
others than industry e.g. patients organisations it’s very rare and on a case
by case basis.
Efficiency
EC independent Scientific
Committees
The Secretariat shall be responsible for providing
scientific and administrative support necessary to facilitate the efficient
functioning of the Scientific Committees, to monitor compliance with the rules
of procedure, particularly in relation to the requirements for excellence,
independence and transparency, to ensure communication on the Committees’
activities and the appropriate stakeholder dialogue, including in particular
organisation of hearings on the activities of the Committees, and publication
of the opinions and other public documents. Moreover, the Secretariat shall
provide support to the Committees and organise and apply quality control of the
opinions, as provided for in the rules of procedure, as far as completeness,
consistency, clarity, correspondence with requests and with editorial standards
are concerned. [Chapter 5, §3 of
Commission Decision 2008/721/EC![pdf](/wel/images/doc_icons/f_pdf_16.gif)
]
ECHA
EMA