What is Impact Assessment about?

Impact Assessment is a tool used to assess ex-ante the potential impacts of policies, in order to better inform the decision-making process. Impact assessment may focus on specific types of impacts (economic, environment, social, health…) or try to assess multiple impacts at the same time.

How has impact assessment been used in the EU context?

The systematic use of Impact Assessment at EU level stems from a movement of reform of the EU policy-making launched in the early 2000s, which aimed to answer concerns about the complexity of the body of EU legislation (known as acquis communautaire) and the lack of transparency of the decision-making process.

The July 2001 White Paper on Governance outlined a series of necessary changes in the policy-making process. The proposed first step is an effective analysis of whether EU action is appropriate and by which means, supported by a comprehensive assessment of economic, social and environmental impact.

Impact assessment had previously been used by European Commission services, but with no overall coordination. Different types of impact assessment where conducted by some Directorate-Generals depending on their policy focus.

In 2002 the European Commission set up an integrated approach to impact assessment, with the application of common impact assessment guidelines.

The 2005 Better Regulation Communication reaffirmed the central part to be played by impact assessment in achieving the objectives of the Lisbon Strategy for growth and jobs. The planning and use of impact assessments has been subsequently enhanced, in particular with the establishment of an Impact Assessment Board in 2006.

The latest revision of the Impact Assessment Guidelines took place in 2008, and was accompanied by a public consultation . In its contribution , EPHA recommended that health impact assessment be a separate part of the Impact Assessment.

How is Impact Assessment concretely carried?

Scope

As a general rule, all major policy initiatives and legislative proposals listed on the European Commission’s Annual Legislative and Work Programme (CLWP), the inventory of main Commission initiatives for the year, are required to undergo an impact assessment. The precise scope of application of impact assessment is decided on an annual basis. The roadmaps, the planning documents accompanying the CLWP, give a first indication of the main areas to be assessed and the planning of subsequent impact analyses. The Roadmaps are available in the Commission Impact Assessment website.

Timeframe

The Impact Assessment process is carried by the European Commission lead service after the public consultation (if applicable) and before drafting the main document (legislative or non-legislative proposal). For each proposal, an Impact Assessment Steering Group (IASG) is set up with representatives from the relevant DGs, impact assessment support units and the Secretariat-General. The IASG is involved in all phases of the impact assessment, and reviews the IA report. According to the guidelines the production of an impact assessment usually spans across a period of 52 weeks.

The IA report is then submitted together with the main document to the Impact Assessment Board (IAB), an independent body composed of high-level Commission officials, who acts as a central quality control of impact assessments.

The Board provides advice to Commission departments on methodology at the early stages of preparation of the impact assessments, and examines and issues opinions on the quality of individual draft impact assessments. In its opinion the IAB can ask to revise the impact assessment and resubmit it.

The opinions of the Board are in theory not binding, but they accompany the draft initiative together with the impact assessment report throughout the Commission’s political decision-making.

The IA report and the main document are then sent to other Commission service for an inter-services consultation, before an adoption by the College of Commissioners.

All impact assessments and IAB opinions are published once the Commission has adopted the relevant proposal.

General content of an IA report

According to the European Commission guidelines, impacts assessments should answer a number of questions, in order to:
- "Identify the problem: What is the nature and scale of the problem, how is it evolving, and who is most affected by it? What are the views of the stakeholders concerned? Should the Union be involved?
- Define objectives: What objectives should it set to address the problem?
- Develop main policy options: What are the main policy options for reaching these objectives?
- Analyse the impacts of the options: What are the likely economic, social and environmental impacts of those options?
- Compare the options: How do the main options compare in terms of effectiveness, efficiency and coherence in solving the problems?
- Outline policy monitoring and evaluation: How could future monitoring and evaluation be organised? “

The analysis of impacts is therefore only one part of the Impact Assessment process, which aims to take into account the broader policy context and ensure the coherence of specific initiatives with the European Commission strategic priorities. The integration of stakeholders’ views and the coordination between the different Commission services are also key elements in the IA process.

A three-pillars analysis

The analysis of impacts follows a three-pillars structure:
- Economic impact assessment
- Social impact assessment
- Environment impact assessment

For each pillar, the IA guidelines set a series of questions Commission services must consider and answer in their analysis.

Format

The final Impact Assessment report must be written in a non-technical language, and should not exceed 30 pages (with some exceptions). It is made public together with the relevant proposal.

What about Health Impact Assessment?

As of today, impacts on health are considered only as one aspect of the social pillar. In order to assess impacts on health, Commission officials should consider the following questions:
- “Does the option affect the health and safety of individuals/populations, including life expectancy, mortality and morbidity, through impacts on the socio-economic environment (working environment, income, education, occupation, nutrition)?
- Does the option increase or decrease the likelihood of health risks due to substances harmful to the natural environment?
- Does it affect health due to changes in the amount of noise, air, water or soil quality?
- Will it affect health due to changes energy use and/or waste disposal?
- Does the option affect lifestyle-related determinants of health such as diet, physical activity or use of tobacco, alcohol, or drugs?
- Are there specific effects on particular risk groups (determined by age, gender, disability, social group, mobility, region, etc.)?”

The annex 9 of the Impact Assessment guidelines and the DG Employment and Social Affairs “Guidance on assessing social impacts ” provide further details on the methodology to adopt to identify and measure potential health impacts.

Quantification of health impacts

As a general rule, the successive reforms of the impact assessment procedure have put an increased focus on the quantification of impacts, in order to allow a full comparison of costs and benefits across the three pillars, including in for health impacts.

The key indicators used to measure health impacts are the Healthy Life Years (HLY) indicator and the Quality Adjusted Life Years (QALY) indicator.

Additionally the guidelines advise Commission officials to try and put a monetary value on health impacts, albeit recognizing this might be a controversial point. Several types of methodologies are proposed: the Cost of Illness (COI), the Human Capital, the Value of Statistical Life (VOSL) and the Value of Statistical Life Year (VOLY) methods.


Related EPHA Articles

Health Inequalities Communication- a case study for Impact Assessment

*Update with the New Guidelines* EPHA response to the consultation on the draft Commission Impact Assessment Guidelines, July 2008.

Health Impact Assessment capacity building project for North West of England

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Last modified on January 29 2010.