title: Quantitative Text Analysis: Uses and Application in the Institutional Policy Process at EU level
Creators: name: Vasilescu, CL
Publisher: name: London School of Hygiene & Tropical Medicine
Year: 2018

description: Institutional policy processes (whether pre-legislative, legislative, post-legislative or administrative) in the European Union (EU) are probably among the most commonly misrepresented and misunderstood processes in Europe. The relationship between institutional actors and the general public, (mis-) informed and influenced by media outlets, is often hindered by high levels of distrust and by barriers to communication. One issue that has attracted considerable concern has been the role of vested interests, represented by large teams of lobbyists, in the development of legislation and regulations. This has led some to characterise the EU as having been captured by “big business”, to the detriment of Europe’s citizens. Yet while there is extensive circumstantial evidence of the ability of these interests to exert influence, for example through meetings with key decision-makers, and in a few cases from the inclusion of specific features in legislation (or a failure to legislate), it is more difficult to quantify such influence. One approach that has been considered to offer potential in this regard is quantitative text analysis (QTA). This refers to the application of one or more methods for drawing statistical inferences from text samples. In contrast, qualitative text analysis methods are comparatively more inductive, non-statistical and exploratory. QTA has been used to show a progressive shift away from language used in public health submissions on EU tobacco legislation towards that used by the industry. This study begins with the premise that industry, and especially multinational corporations, and possibly other stakeholder groupings (e.g. trade organizations, industry front groups) use particular vocabulary, evidence, position-taking and semantic shifts to influence the policy process. Business case language and economic perspectives dominate over a narrative featuring public health or ethical concerns. The study then explores the scope to use QTA as a tool to “interrogate” the subject (the text submitted to a public consultation), to examine and assess the content of public consultation documents and to evaluate the policy position of stakeholders as well as their evolution. Finally, it asks whether a more sophisticated package of tools, including QTA of policy briefs, mission statements or policy papers, can complement traditional methods such as stakeholder analysis to provide a more robust assessment that can protect public institutions against misuse and misrepresentation of scientific evidence in public consultations. I do this by investigating the experience of public consultations in influencing the evidence base for institutional policy-making in the field of health, aiming to identify who stands to benefit from public consultations and whether they achieve an advantage. I propose that QTA could help to foster a dialogue between groups weakly or rarely represented in public health consultations and institutional knowledge systems, and focus attention on the role of public consultations in challenging power hierarchies between public health activists, industry professionals and regulatory affairs practitioners as risk managers. I undertake QTA in three separate health-related case studies in which some variant of public consultation took place. This study looks at: a) the experience of public consultation applied to a draft scientific opinion by the European Food Safety Authority (on the chemical compound acrylamide), b) the process of consultation on the findings of an externally commissioned study on pharmaceutical pricing policy in Europe and c) the draft text sequence of an important piece of EU legislation as it progressed through the co-decision procedure, the application of rights of patients in cross-border healthcare, i.e. Directive 2011/24/EU.