If you read the minutes of the Regulatory and Advisory Committees, you’ll get a good idea of what works best. I find it useful to read the minutes from the:
Reading the official record, you will see the approaches that work and those that don’t. I’ve adapted my game plan based on these useful feedback loops.
A browse through the official record brings up some useful lessons for any chemical lobbyist:
1. If after a classification decision has been made, and you have new science, the best option is to get a Member State to submit a new classification proposal with the new studies.
2. Governments and the Commission won’t stall a decision because a new study came up after the decision has been made. They just see it as a means to stall the decision.
3. There have been a few cases when new and relevant science has come up during the adoption of a decision. The Commission sent the opinion back to the RAC. I believe that in all those cases, the RAC re-confirmed their previous position.
4. There are always going to be uncertainties – scientific, technical and economic – but that’s not a reason not to act.
5. The Commission and Member States common view is that remaining uncertainty is often due industry providing limited or no feedback.
6. Alternative evidence is not only welcome but is taken into account and it can change the outcome.
7. You need to bring good quality independent information to the table.
8. To do this, you’ll need to start early and prepare your case. If you present information after the key decisions have been made, the information is unlikely to be taken up.
10. The same goes on any on-going or emerging issue. If you don’t have the right evidence available, pleading for extra time just won’t work.