29 Jun 2019



The Formulation of National Biotechnology Policy


1.0     INTRODUCTION                                                                   3

2.0     NATIONAL BIOTECHNOLOGY POLICY                             4
          2.1     Evaluation on the role played by the main stakeholders
in the formulation and implementation of
National Biotechnology Policy                                      5

THE PUBLIC POLICY   PROCESS                                         8

4.0     CHALLENGES IN BOTTOM UP APPROACH                       13

5.0     CONCLUSIONS                                                                     16


Malaysia is a country that is unique because it is a country that is derived from two regions of Peninsular Malaysia and Sabah and Sarawak. Malaysia is a country of different races, ethnicity, religion and culture that reflects the diversity of the country. Malaysia also does not deal with natural disasters that continue to produce and delegated much like petroleum, tin, and so forth. Therefore, Malaysia should have a policy not only to mobilize resources, but can reduce the gap between people and the region will further enhance the relationship between race and religion.

Public policy refers to the act by government to address certain problems affecting members of the public. Various governmental organizations formulate and implement public policy so as to address issues affecting the public. Besides, public administration defines the process of implementing public policy. Therefore, public policy fits quite well in the field of public administration; the study of public administration enables one to acquire knowledge on how to manage organizations, public policy analysis and solving public problems. Public administration involves professional experts for the development of sound public policies that can help in solving, easing or preventing the problems.

Public administration requires skills like budgeting, research and management, which are important in the implementation of government policy. A public administrator oversees the design and execution of government policies. Public policy is just one among the various pillars of public administration. Other pillars include human resource, statistics and ethics. The public administrators are legislators, mayors, public servants among others. This fits well in the agenda of public policy. For instance, a mayor seeks legislation on public policy and undertakes its implementation for the benefit of the general public.

This paper seeks to examine the policymaking process of National Biotechnology Policy, which is aimed to provide a structured guideline in developing the industry. This paper will also discuss the rationale of bottom up approach in the public policy process and the main challenges behind the bottom up approach.
The emergence of new technologies such as the Information and Communication Technology (ICT), biotechnology and new material sciences have successfully altered the dynamics, composition and production patterns in the industrialized as well as developing nations (Chaturvedi & Rao, 2004). Biotechnology, in particular, will undoubtedly be the major technology of the twenty-first century. In fact, biotechnology is one of the fastest growing sectors in the world and is seen as a major area of investment and target for support by government worldwide (MOSTI, 2006). Over the past 55 years, biotechnology has supported many scientific discoveries and has become an integral component of the economies of many industrialized countries (Glassman & Sun, 2004). There are significant potential benefits to the nations committed to participating in the biotechnology industry, for instance, in term of higher crop yields, better healthcare and better economic returns (Daar et al., 2007).

Recognizing the potential contribution of biotechnology to the economy, many Asian countries, including Malaysia have begun to invest in the biotechnology industry. Although biotechnology can be considered as relatively a new industry in Malaysia, yet it has been identified as a potential engine of economic growth for the nation. Following the lead given by the development of Multimedia Super Corridor (MSC) which represents a successful investment in the ICT industry, biotechnology is considered as the next growth area in the industrial development for Malaysia (MOSTI, 2006). Hence, with the necessary motivations and great opportunities, biotechnology becomes the subject of public policy aspiration in Malaysia. However, a structured policy is vital as it becomes the key for the implementation of activities in this sector. With a clear direction and indication, the progress and growth of this sector is not only immeasurable but the success will then be proven relative. The Malaysian cabinet then entrusted the Ministry of Science, Technology and Innovation (MOSTI) to lead the drafting of an effective policy for this industry.

2.1       Evaluation on the role played by the main stakeholders in the formulation and implementation of National Biotechnology Policy
In general, the formulation of the National Biotechnology Policy can be divided into six phases – Problem Recognition; Appointment of Policy Agent; The Emergence of Policy Network; Interaction; Evaluation and Policy Outcome.

            2.1.1    Problem recognition
The policy initiation phase in the policy process can be extremely a complex one. It includes perceiving that a policy problem exists, identifying the problem context, determining the policy objectives and generating suitable policy agendas. According to Evans and Davies (1999), policy process begins with the recognition by policymakers of the existence problem which requires, due to contextual factors, pressing attention. The policy problems can be in the form of political interest, economic competition, or social need.

2.1.2    Appointment of policy agent
During the search process, an organization may come across a potential policy agent or policy consultant with specialist skills to develop the necessary political and knowledge resources to satisfy successful policy development (Khairiah, 2008). As MOSTI was entrusted to lead the drafting of the biotechnology policy, MOSTI engaged the Malaysian Industry-Government Group for High Technology (MIGHT) as the principle consultant to accomplish the given task in the best possible manner.

MIGHT is an independent and non-profit governmental organization that is responsible to enable consensus building and coordination for industry-government partnership in high technology such as biotechnology. It is a prominent organization and has strong international links.

2.1.3    The emergence of policy network
This stage in the process of policy making identifies the emergence of an information feeder network which is developed by the appointed policy consultant (Khairiah, 2008). In this case, it was MIGHT. The curiosity of the Ministry of Science, Technology and Innovation (MOSTI) as a client was increased through preliminary processes of contact. Thereafter, it is crucial for MIGHT to increase the volume and the detail of information for MOSTI by demonstrating the quality of their access to communication and knowledge network in order to facilitate the formulation of National Biotechnology Policy proposal.

2.1.4    Interaction
In this stage, policy consultants will often be expected to organize forums for exchange of ideas between the client and knowledge elites as well as relevant policy stakeholders (Evans, 1999). This may take a form of representatives of relevant stakeholders who have similar professional beliefs and standards of judgment as well as share common policy concerns (Khairiah, 2008).

Various contexts of interaction can be identified in this case study through which MIGHT, MOSTI and representatives from academia, non-governmental organizations and industrial players discussed issues of central importance in the formulation of National Biotechnology Policy. At least nine important meetings were held starting from the appointment of MIGHT as the official consultant until the official launch of the National Biotechnology Policy.

Figure 1: Chronology of Meetings between MIGHT, MOSTI, and Policy Stakeholders
Source: Malaysian Industry-Government Group for High Technology (2009)

            2.1.5    Evaluation
Once the client is satisfied with the degree of intelligence gathering that the consultants have engaged in, the process of evaluation will commence (Khairiah, 2008). The evaluation process is critical in determining that the elements such as policy objectives, structure, contents, and concepts are designed appropriately according to the needs of Malaysian setting.

2.1.6    Outcome
After the National Biotechnology Policy draft has been evaluated by MOSTI and the various government agencies and non-governmental organizations, Jamaludin Jarjis, the former Minister of MOSTI presented the policy draft to the Malaysian Cabinet. According to the Principal Assistant Secretary, Finance and Corporate Section, BIOTEK, the cabinet approved the policy draft in the first presentation itself without any amendment since the proposal has been reviewed several times earlier by the various government agencies and was deemed complete.

The bottom-up theories emerged in the late seventies and early eighties as a major approach to policy implementation. Several studies showed that the top-down approach was not able to achieve their original objectives and policy statements. For example, although the New Economic Policy introduced in 1970 assumed that poverty would decrease by providing various tools such as subsidies to farmers and fisherman, many of them were still in poverty. In other words, if providing subsidies would lead to a decrease in poverty, then why did it not happen?

This could be because the policy was developed from a top-down approach and disregarded the complexity of putting policies into action. The top-down approach ignored the behavioral aspects of implementation and, more importantly, the key role played by implementers at the local level such as teachers in schools and local village heads in districts. Moreover, the bottom-up approach contends that if local bureaucrats are not allowed discretion in the implementations process with respect to local conditions, then the policy will likely fail (Matland, 1995).

Bottom-up theorists emphasize target groups and service deliverers, arguing that policy is made at the local level (Matland 1995). These scholars (e.g. Hjern and Hull 1982, Hanf 1982, Barrett and Fudge 1981, Elmore 1979) thus criticize top-down theorists for only taking into consideration the central decision-makers and neglecting other actors. The bottom-up approach, developed by Hanf, Hjern and Porter (1978), identifies the networks of actors who are involved in service delivery in one or more local areas and asks them about their goals, strategies, activities and contacts. It then uses the contacts in order to develop a networking technique to identify the local, regional and national actors involved in the planning, financing and execution of relevant governmental and non-governmental programs. This provides a mechanism for moving from local actors and decision-makers such as teachers or doctors up to the top policy-makers in both the public and private sectors (Sabatier 2005). In terms of policy areas, bottom-uppers examine policies with greater uncertainty in the policy (Matland 1995).
Bottom-up designers begin their implementation strategy formation with the target groups and service deliverers, because they find that the target groups are the actual implementers of policy (Matland, 1995). Moreover, bottom-uppers contend that if local bureaucrats [implementers] are not allowed discretion in the implementation process with respect to local conditions, then the policy will “likely fail” (Matland, 1995). Accordingly, goals, strategies, and activities must be deployed with special attention to the people the policy will directly impact. Thus, evaluation based upon the street-level bureaucrat would be the best practice (Matland, 1995). For example, Matland discussed Hjern’s findings that central initiatives poorly adapted to local conditions failed, and, that success depended greatly on the local implementer’s ability to adapt to local conditions.

Discretion by agents is the underlying premise of the bottom-up approach (Elder, Lecture, 2011). Discretion may be a very good thing, especially when it uses expertise of people impacted by the policy to increase the likelihood of success and approbation. In bottom-up, one size doesn’t fit all cases, and so discretion may enable implementers to activate more useful practices or to ignore policy that will hamper the goal of the program. For example, the safe water drinking act became prohibitively expensive for smaller water systems. Of the 350,000 municipal water systems in Malaysia., only the conglomerates had the financial resources to quickly live up to the law without federal / state aid. However, the size of the water systems meant that a visit from a regulator was unlikely, so the great financial burden that would have occurred with a visit from a regulator was ignored. On the other hand, a regulator using the bottom-up approach in Chicago may overlook minor code violations for a bribe—since the mom and pop shop is out of code but is not a real threat to safety. The bottom-up model is thus a challenge to administration due to the reality of delegated authority, to the discretion allowed to different agents, which invariably causes a measurable variance of goal achievement. The bottom-up approach thus creates ambiguous goals.

Bottom-uppers are at times guilty of two criticisms. First, street-level bureaucrats are usually not accountable to the people. In this case, the local agents may intentionally subvert the elected officials’ policy goals and engage personal sub goals (Matland, 1995). Second, bottom-uppers ignore the fact that many policies are created in a top-down manner, and likely in a manner which reinforces top-down authority. For example, Matland describes Sabatier’s analysis of environmental regulation in the United States, whereas the federal designers of the federal act integrated the necessary clauses to allow for class and individual lawsuits (150). Overtime, it was these lawsuits that adjusted the rule-of-law, not the local implementers.

DeLeon and DeLeon (2001) find that bottom-uppers are more likely to be reflective of community interests, while top-downers are more likely to impose policy narrowly upon focused interest groups. They conclude that bottom-up implementation is “more realistic and practical” and much more “democratic” than the top-down approach. Further, if the policy is indeed meant to coerce people’s behavior, then the bottom-up approach may go beyond informing people of the proposed legislative action to manipulate behavior. In fact, bottom-uppers may garner the consent of the target group before their representatives’ vote for the law.

Citizen e-participating is one of good example of bottom-up approach in public policy process in Malaysia. Figure 2 shows the general overview of public policy formulation in Malaysia and figure 3 shows how the bottom-up approach through e-participating works in formulating public policy.

Figure 2: General overview of public policy formulation process in Malaysia

Figure 3: E-participation framework for public policy formulation

The bottom up-up approach is not free from challenges. Among the main challenges faced by public administrators in the policy formulation and implementation by using bottom-up approach is as follows:

Ego dimension of politicians: The ego of most politicians in Malaysia leads to the twist and turns of policies usually for political survival and perpetuation of party interest. There is needless policy change if not abandonment. New governments come into office and fail to continue with the policies started by the previous opposition government. In rare cases, the best they can do is to change the name of the policy or enlarge it to cover other extraneous societal issues.

On the other hand, politicians in their effort to quickly satisfy the demands of the people formulate policies that provide short-lived solutions and fail to address the actual problem in the long run. The winning of elections is held as more important than the sustainability of policies and the attainment of their core goals (Makinde, 2005).

Bribery and corruption: Bribery and corruption sometimes become problem in bottom-up approach. In the policy setting, it accounts for most of the difficulties faced at the implementation stage. Policy actors both at the top level and at the field syphon financial resources to satisfy themselves. Agents and institutions put in place to ensure accountability are also bribed to falsify their reports and massage their probing. In the end, the system is weakened and the formulated policies are unable to achieve their stated goals (Makinde, 2005).

Narrow View in Policy Formulation: Policy formulators using the bottom-up approach focus on very few variables that influence the problem identified. In most cases, they focus on only the political and economic variables failing to include the social, administrative and external environmental variables. Hence, right from the start, the policy is formulated with deficiencies (Makinde, 2005).

Lack of participation by the target group: participation is when the target group which the policy is meant for is given much room to contribute in policy formulation and implementation. However, in Malaysia the target group is usually left out at the policy formulation stage. Only high officials of government and policy actors are made to participate. The policy so defined therefore fails to be client-oriented and gets out of touch from the local people. Ownership of the policy becomes difficult (Makinde, 2005).

Time Required. One of the main problems encountered to the bottom-up process is the amount of time it consumes. In case of financial policy, first of all, individual managers have to create their own budgets, taking into consideration past budgets and spending during the integration of cost projections for the next year. Then, upper-level managers and executives have to review all the budgets submitted by the managers, and also to sum them in order to find out totals. The next phase is the approval or feedback that requires recalculations, meaning that the whole process can repeat itself several times before a final form of a budget is approved.

Lack of Expertise. In this form of policy making, the responsible for policy is likely to have enough experience in policy domain and some confidence working with financial resource allocation. However, a bottom-up approach required managers, who detain professional positions based on their specialized skills in specific fields, to perform the same administrative tasks as those that deals with this kind of skills. Even though there are managers who excellent motivate their teams and specialized in one particular field of business, they could not find cost savings and also estimate expenditures as well as someone else who work all day long with these figures or is higher in the organization.

Lack of Context. Bottom-up process ask stakeholders to elaborate policy without the benefit of context within the issues. stakeholders could have some information about other policy activities but a bit amount of knowledge about main strategic goals and financial objectives for the policy overall. Instead, stakeholders elaborate their main issues in separation or without guidelines from their top order, working to ensure for own structures needs but missing out on what's best for the country as an entity.
In general, the disadvantages of bottom-up approach can be identified as:

a)      The main fault of the approach is that it gives too much autonomy and power to lower-level bureaucrats. This might lead to the lower-level officials misusing their power and deviations in policy implementation or even complete overhaul of policies at the local level.
b)      The street-level bureaucrats are not politicians and therefore do not have to be accountable to the people, should the policies the implement go wrong. They may also thwart the elected officials’ policy intentions and have their own agendas to pursue at the local level.
c)      Policies can be made by local bureaucrats with total disregard to the fact that policies should be made by elected representatives.
d)      The lower level bureaucrats may actually not have much discretion with respect to policy implementation because the way that some policies are structured.
e)      Finally, it is impossible to control lower-level bureaucratic behavior by providing or withholding resources necessary for implementation by top-level policy makers.

This paper generates insights that may help develop better understanding of public policy making in Malaysia, in particular the National Biotechnology Policy. Two observations that can be made from the National Biotechnology Policy formulation process in Malaysia are highlighted here. Firstly, policymakers in developing countries like Malaysia often assume central roles in initiating, shaping and pursuing public policies. They are frequently the most important actors in propelling issues and problems into agenda for government action. Secondly, a well mobilized policy consultants and policy network may make a critical difference in ensuring a successful adoption and implementation of the policy proposal in a multiracial country like Malaysia.

Selecting an appropriate approach to use as the most appropriate approach to formulate and implement a public policy should be determined by reference to the need and suitability issues to be assessed.

Bottom-up approach recognizes that individuals at subordinate levels are likely to play an active part in implementation and may have some discretion to reshape objectives of the policy and change the way it is implemented.  The bottom-up approach sees policy implementation is an interactive process involving policy makers, implementers from various levels of government, and other actors. Policy may change during implementation.

There is no conclusion as to whether the top-down or bottom-up approach to implementation is better. What can be concluded is that both approaches provide valuable information to the implementation process and have their individual strength and weakness.


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Sabatier, P. (2005), ‘From policy implementation to policy change: a personal odyssey’, in A. Gornitzka, M. Kogan and A. Amaral (eds), Reform and change in higher education: analyzing policy implementation, Dordrecht: Springer.

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