Memorandum submitted by the Director of
Political Campaigns, Consumers for Health Choice (E25)
Our Director, Sue Croft, is writing to you with
a detailed formal submission to your inquiry, but there are a
number of aspects about the Government's proposals in relation
to the retail of vitamin B6 which have also been raised separately
with the Government's own Better Regulation Task Force.
In this specific context I enclose for
your information:
(a) a copy of the letter which was sent to
Mr Christopher Haskins, the Chairman of the Better Regulation
Task Force on 16th February (See Annex), and
(b) a leaflet produced by that Task Force
that sets out the principles which good regulation should follow
(not printed.)
In addition to considering the scientific arguments
set out in the letter which you will shortly receive from Sue
Croft we hope that your Committee may also take time to consider
the enclosures and, in particular, to assess the extent to which
the Minister's proposals conform to the principles for regulations
set out in the enclosed leaflet, namely:
(1) that "their fairness and effectiveness
and the public support they command are critical to public confidence
in a Government";
(2) "good regulations and their enforcement
should be measured against five principles: transparency, accountability,
targeting, consistency, and proportionality";
(3) policy objectives which justify regulation
should "protect and enhance the rights and liberty of all
citizens";
(4) formal alternatives to state intervention
include "voluntary self-regulation"; and
(5) tests of good regulation are that it
"Must have broad public support", "Must be enforceable",
"Must be easy to understand", "Must be balanced
and avoid impetuous knee-jerk reaction", "Must avoid
unintended consequences", "Must balance risk, cost and
practical benefit", "Must have accountability"
and "Must be relevant".
We believe, and think that you will agree, that
the Minister's proposals in relation to the retail sale of vitamin
B6 are found wanting when measured against all these principles
espoused by its own Task Force.
14 April 1998
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