House of COMMONS












TUESday 13 MAY 2008




Evidence heard in Public Questions 121 - 180





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Oral Evidence

Taken before the Regulatory Reform Committee

on Tuesday 13 May 2008

Members present

Andrew Miller, in the Chair

Gordon Banks

Lorely Burt

Mr Quentin Davies

John Hemming

Judy Mallaber

Dr Doug Naysmith


Memoranda submitted by Department for Environment, Food and Rural Affairs, Department for Work and Pensions, Health and Safety Executive

and Department of Health


Examination of Witnesses

Witnesses: Mr Richard Gregg, Head of Regulation, Division and Programme Director of the Better Regulation Programme, Department for Environment, Food and Rural Affairs, Mr Trevor Huddleston, Strategy director, Department for Work and Pensions, Mr Geoffrey Podger, Chief Executive, Health and Safety Executive, and Mr Giles Wilmore, Director of System Regulation, health and Adult Social Care, department of Health, gave evidence.

Q121 Chairman: Welcome, gentlemen. We have a lot of questions for your organisations to answer today. If I cut you off at any point, please feel free to follow up in writing. You will get the flavour of the themes we are trying to gather information on. Some of my colleagues will be coming and going as well, as there is an awful lot happening today. I want to ask all of you about your experience of working with BRE, what value it has had - does it have the right people; is it organised in a way that helps you; and does it talk to you enough? For my own convenience, I will start to the left with you, Mr Wilmore, and move across, just posing those introductory questions to you.

Mr Wilmore: Thank you and good morning. From the Department of Health perspective, we have a very positive relationship with the BRE. We have a good day-to-day working relationship with the officials there. They have worked hard to understand our agenda and the particular issues facing health and social care, which are often very complex in a regulatory environment. Generally speaking, we feel that the balance between being a critical friend and challenging, offering advice and support, and the generic learning we can pick up from having a central government point of expertise works well; so we would generally say "yes" to your question. The relationship works well and the process does add value, and it allows us to promote the Better Regulation agenda with a bit more teeth across the Department and within the sectors that we work with.

Mr Podger: Chairman, our experience in the Health and Safety Executive is pretty similar. Currently, we have very good relations with the BRE, both formal and informal - which is also important. We have ourselves seconded staff to the BRE, which is a measure of confidence. Obviously, the BRE does play a challenge function in relation to us, which we accept and have no problem with; but inevitably it means that from time to time we do not agree, and I think that is perfectly proper.

Q122 Chairman: Can you give examples?

Mr Podger: We have had quite a number of discussions with BRE in relation to inspection of premises and the value of inspection. They, quite understandably, tend to come from a business perspective, which is not, shall we say, over keen on inspection! We ourselves, although in no sense manic inspectors - I would stress that - do see a need to use inspection both as an advisory tool but also as an enforcement tool; so there are certainly areas for legitimate argument.

Mr Huddleston: I would agree very much with the broad thrust of my colleagues' remarks; it is a positive relationship. Also it is worth saying that it is tailored to the particular challenges that we face. Our relationship has evolved over time, as the Better Regulation agenda has broadened into areas beyond business. We have a range of day-to-day contacts with account managers to more formal arrangements with Better Regulation Executive colleagues sitting on our Better Regulation Stakeholder Group, which is chaired by our Minister. Quite often, the Better Regulation Executive, meeting bilaterally with, say, policy folk, leading on pensions and issues like that, would get directly involved in the thinking about policy. Certainly over the couple of years I have been working with BRE, I welcome the flexibility of finding the right relationship for the right challenge.

Mr Gregg: Since I took up my current role in July, I think my experience would point to BRE as being a driver both in direction and pace in terms of value and assisting driving the development of common shared strategy across Whitehall, producing mechanisms that enable read-across between departments and co-ordination of where pressure points are likely to be felt. I think their role, as voice of business, can be very helpful in that it backs up our own attempts to get out and manage effectively our stakeholders. In terms of the right people, for an organisation of a hundred they have some very senior people in there, with a good mix, including from the business sectors. I think that, too, is helpful, to bring that reality and real experience, which may contrast with some of our officials. In terms of whether they talk enough - yes, they make every effort to talk and, more importantly, to listen.

Q123 Lorely Burt: There we are; we might as well all go then: everything is completely rosy! Mr Wilmore, in your memorandum you talk about alerting each other when support is required and you have positive examples of where the partnership approach taken between the BRE and the Department of Health have successfully identified priorities for action, and facilitate the Department to deliver tangible benefits. Can you give us an example or two of that?

Mr Wilmore: There are two main areas in relation to both private sector and public sector. Obviously, as the Department of Health, most of our activities are public sector related. Most of the work we have been doing with the BRE is related to the public sector strategy over two or three strands. One is reducing duplicative and unnecessary data collections from the NHS, where we have achieved about 10 per cent reduction already. This is quite a complex agenda given the range of data that is collected, the uses of it and the lead-in times being quite long to change that. That is one example. We have also had a lot of support from the BRE in developing what we would call a concordance arrangement, which is led by our main Health Service regulator, the Healthcare Commission, which brings together users of information from the Health Service to try and avoid duplicate and overlapping inspections of data collection as well. They have been very supportive in facilitating that process and setting out the cross-government context with key stakeholders.

Q124 Lorely Burt: Defra sent a copy of its partnership agreement with BRE, and that sets out working on matters such as information-sharing, targets and monitoring. Is your concordat something similar to that?

Mr Wilmore: The concordat is more about the relationship we, as a department, facilitate alongside BRE with our various regulatory bodies under the bodies that have a need to visit and inspect and collect information from the Service; so it is not a direct comparison. We do not have, as a department, a formal partnership arrangement with BRE. Things have worked generally well and we have not felt the need to have that.

Q125 Lorely Burt: You have not got anything that formally framed your relationship with them.

Mr Wilmore: Not in the way of a formal partnership document.

Q126 Lorely Burt: Can I ask the same question to Mr Huddleston about how you frame your relationship because you do not have a partnership agreement, as I understand it?

Mr Huddleston: We do not, and I think that reflects on what I was saying in answer to the first question. There is a flexible relationship tailored to the challenges we face. Within the Department of Work and Pensions we have a fairly broad-based commitment to Better Regulation, particularly on the pension side, but more broadly in terms of the benefit system itself and the burdens we place on citizens and front-line staff. In that instance, where we are seen as going with the flow, actually having a detailed concordat is not really necessary. I guess I make the distinction between almost a principles-based approach to the relationship than a rules-based approach. We both know the outcomes we are trying to achieve; let us get on and do it and not bother too much about the detail of agreements.

Q127 Dr Naysmith: Should the Department have one major strategic vision or should it presume a number of goals based on expediency and what is likely to get results? Are the BRE's expectations of departments realistic, and does it have a coherent strategy and firm grip of the objectives?

Mr Gregg: Absolutely so. Certainly my experience of attending the board level Champions meeting is that collectively departments work with BRE to develop that strategy, but we are still in relatively early days from their formation. The challenges get greater in terms of what we have to do for business, and that strategy has got to be responsive. It is true to say that there is a feeling sometimes of initiative overload - have we got the priorities right, because resources are tight and if new developments come forward somehow we have to take those up? Departments can challenge back when there are ideas. In answer to your key thrust, yes, there is a coherent strategy in that we are trying to find the right mechanism collectively for balancing the needs of protection versus the burdens that that creates for business.

Q128 Dr Naysmith: You are quite clear it has one strategic vision and you are in no doubt about that?

Mr Gregg: The strategic vision falls within that objective, a shared objective: we are collectively trying to achieve our outcomes, and in terms of Better Regulation, it is "better" regulation. Regulation itself is certainly for Defra the main plank in how we seek to achieve our outcomes.

Mr Huddleston: I would agree with most of that. The overall vision the BRE is putting forward is a clear one and is certainly shared with the Department for Work and Pensions. That embraces not just the ambitions and not just reducing unnecessary burdens on business, but also burdens in the public sector and on citizens, which is where we have been going. Overall, the approach, which is to have a series of initiatives dealing with elements of that vision, is the correct one. So you have an approach that tackles the stock of existing administrative burdens; you have an approach to try and slow down or mitigate the flow of new burdens; and then you have issues such as common commencement dates, which are ways of making a reality of some of the simplification activities. Overall, it is right to have a series of initiatives. I do not think you can bite off a strategy as big as Better Regulation with one initiative. It seems to me they are coherent. I think the pace at which they have been coming has been great. It has been a challenge, but we have responded positively and effectively to that.

Mr Podger: I generally agree with what Trevor has just said. It is quite right to have an over-arching goal for BRE in reducing unnecessary burdens on business and people - I do not think any of us could object to that. The key point though is how you do it, and what is appropriate will inevitably vary from one sector to another. That is why if one just has a one-size-fits-all approach, for example to try and regulate on the basis of a mathematical quantification risk, which is something that sometimes occurs, that fails completely to take account of issues around public perception, issues around public expectation, which also have to be faced. I would just say that I think the over-arching goal is fine. I think it is perfectly proper for BRE to see to intervene in different ways in different sectors.

Mr Wilmore: I support the fact that there is a clear vision. It is about Better Regulation, and in health and social care is very important to distinguish between Better Regulation than just cutting regulation. We envisage a strong role for regulation in health and social care to ensure people receive quality of service. Our experience of working with the BRE is that through the annual reduction targets and other initiatives, there is a clear framework in which there is an expectation the departments will work towards that - but we are not told how to do it, so we have a constructive dialogue about the areas we think we can reduce the regulatory burden; but equally we will come back sometimes and say that there are areas where we think we might need more regulation because there are new risks coming along. We have that dialogue on a constructive basis within the framework that we are trying to promote more risk-based approaches and a more proportionate approach to regulation.

Q129 Dr Naysmith: The British Chamber of Commerce representative suggested to us that there should be a more robust approach to the policing of departments. That raises the question of what the BRE's role should be in relation to its various customers, clients and stakeholders. Should it be a policeman; a think-tank; a deliverer; a teacher, or any of these things: what should its role be? Should we agree with the British Chamber of Commerce?

Mr Podger: From the Health and Safety Executive's perspective the one thing which is important is that we are an independent regulator accountable to a board, indeed a board created by this committee. I think it is their role to monitor us on a day-to-day basis. We make a huge amount of information public. We certainly provide a lot of information to BRE. We do not have any problems with occasional initiatives like the Hampton Compliance Review that they have just done. However, it is important that we preserve a structure whereby bodies are accountable to their own management and through there to Parliament and the public; not that they start an alternative line of accountability, off to colleagues in BRE because I think that would only lead to confusion.

Q130 Dr Naysmith: Should the BRE step more into the role of ideas generator now, instead of being a policeman and monitor; should it be generating ideas rather than policing?

Mr Podger: Clearly, the RRSE is a young body so we do not know quite what it is going to do. I certainly agree that there is a role at the centre for - if I might put it this way - perking up ideas - which is not always easy for those of us who have operational commands to do on a day-by-day basis. I think that is certainly a part of the role. I think it should not just be drawing up, frankly, rather complex administrative issues.

Mr Wilmore: I would support that in terms of balance being as much about a centre of excellence and learning from the experience of other centres. Inevitably, there has to be a method of monitoring and evaluating success, but I would not want to see that as a policeman role. After all, we are Departments in the same Government, working for shared objective, so we should be allowed to regulate our own effectively and be challenged on that. I think that is the right kind of balance. The specific comments from the Chamber of Commerce are probably more difficult for the Department of Health to respond to in the sense that we have minimal involvement only in one or two key areas with the commercial sector where we have already made quite good progress and have good working relationships, say, for example, with the pharmaceutical industry on regulatory initiatives. We feel that we can demonstrate progress in those areas anyway.

Mr Gregg: I think it would be a mistake to force BRE into a role of enforcer. Their added value has come as facilitator because Better Regulation is not something that is being imposed on departments; it is a wish for departments to regulate in a better way to achieve their outcomes. The facilitation role is important; the visionary role, making sure that we share that vision is important. Some consistent monitoring around how departments are performing so that we can communicate our successes is absolutely vital to maintaining support. I think the annual publication exercise of the simplification plans, where departments are required to report on how they are going against the specific measurable targets and how we are achieving progress culturally in the way we think about the need for intervention and how to construct those.

Mr Huddleston: One thing I found useful is related to the policeman role; it is essentially looking across all of the regulatory activity across departments, and identifying best practice where perhaps one department is a little ahead of another, and drawing that to your attention to say, "these have had success in this area; why do you not try that?" That has been quite useful to us particularly when we have been thinking about reconstituting our Better Regulations Stakeholder Group. That has been a positive aspect. I also think that across Government there is a broader mechanism for looking at performance in this area, which is of course public service agreements and the delivery board that oversees that. That is a useful mechanism in the round for saying, "Are we, as a community, making progress?"

Q131 John Hemming: Within that context is it a better idea for the BRE to look at the individual impact assessments or more widely on how departments are handling things from the point of view of training et cetera?

Mr Wilmore: I think the BRE's input in revising guidance and broad support on how to do good impact assessments has been very good because there is no point having a department reinventing a slightly different way of doing that; so I would support that; but beyond that I would not support the BRE scrutinising individual impact assessments. I think the departments should manage that and encourage them to promote the importance of that within their department; and that is a key part of the mechanism of challenging whether regulatory proceedings are adding value and not adding unnecessary burdens.

Mr Podger: I take essentially the same view. I think it is very important that Better Regulation is embedded in all of us; it is not something that can just be enforced on a day-to-day basis by BRE, coming from the outside. Whilst I think it is quite right for them to pioneer and lead things off, I think it is perfectly proper that once they are bedded in it should be entrusted to departments to be accountable for them.

Mr Huddleston: I agree with that. I think the consistency that the impact assessment approach gives is very useful and very welcome. The training supporting that was very effective. I do not think there is a great deal of mileage in the BRE actually scrutinising all the impact assessments. The role that chief economists have got within departments to sign off the quality of the analysis is sufficient internal policing: it gives you a commitment to rigour.

Mr Gregg: I very much agree with Trevor's last point. It has been extremely valuable to have support on the training side in terms of getting the policy officials that are doing the work to think about impact assessments and what they really mean. In Defra we have put something like 600 of our policy staff through impact assessment training, and the process has proved to be a really useful culture-change tool. I do not think that scrutiny of individual impact assessments by BRE would add value especially given the Chief Economist's sign-off procedures; but I do think the establishment of the central repository to the impact assessment library is a useful step forward. It has only just started and there are very few impact assessments on there at the moment; but that will become a useful tool for departments and for businesses and the general public.

Q132 John Hemming: Where would you put BRE now it has moved from the Cabinet Office? Does that help or hinder; is it a good idea or not such a good idea?

Mr Gregg: It is a difficult one. Looking at it domestically, one has to think what sort of message are certain stakeholders taking from that, in a department where there is a voice for business: could one read it as BERR needed some reform more than the four Departments you see in front of us? I think it is useful from the context of BRE being closer within the Department to the realities of picking up on the challenge that collectively we set ourselves. Perhaps in relation to taking forward the European agenda, it might be more difficult for BRE, embedded within a delivery department, to establish a strategic relationship with key opinion-makers in Brussels. That is something that collectively we are working hard at to improve.

Mr Huddleston: I certainly have not noticed any change in our relationship since the move to BERR took place on a day-to-day level. Things are progressing very well and effectively. We share the concern about perceptions. Is it the case that this could be seen as downplaying the importance of burdens on the public sector and citizens, which is the particular area the Department for Work and Pensions is interested in? I guess I would say that in the DWP we have so much internal commitment and so many drivers for those agenda anyway that the BRE is, if you like, more of a critical friend than somebody driving us along. However, I could imagine circumstances in the future where if BRE were a little less hot in that area, we would lose a little bit of clout in the Department potentially to help push this along. One of the roles that the BRE plays for us is that it makes everyone aware that this is an important agenda, and it helps us spread that message within the Department.

Mr Podger: I think we, frankly, noticed very little difference since the move to BERR; in fact, it seems to have been a very smooth transition. From our particular perspective of the Health and Safety Executive it impacts most on the business community and rather less so on wider public issues. For that reason, we do not have the problem that other colleagues have drawn attention to. My own view is that it is also perfectly possible for BRE to exercise their European functions, to which we attach a great deal of importance, and within BERR there is a lot of activity going on there.

Mr Wilmore: Likewise, we felt the transition was very seamless. We noticed no practical change in our working relationship with BRE since they became part of BERR. Again, the biggest risk for us is the perception of the Department largely in public services, that people will think the emphasis is predominantly around regulation of commercial and business sectors and it is less interested in public sector; but the reality of our experience is that that is the position BRE takes. It is equally interested in promoting Better Regulation in the business sector, so we need to do work to ensure that our key stakeholders understand that message, that we are not sidelining their interests.

Q133 John Hemming: Does anyone have a strongly-held view as to whether HMRC should be brought within BRE's remit?

Mr Podger: No.

Q134 John Hemming: Is that "no" - any view at all? No comment?

Mr Wilmore: Again as the Department of Health, we do little direct business with HMRC in terms of the sector we represent, so we have no direct experience, I am afraid.

Q135 Chairman: Can we move on to your own work in the field of Better Regulation, specifically the Administration Burdens Reduction Programme? As, Mr Huddleston, your Department is perceived to create the greatest number of admin burdens, at least in the eyes of my constituents, I will start with you! Are you on target to meet your 25 per cent admin burden reduction programme by 2010?

Mr Huddleston: Yes, we are.

Q136 Chairman: Why do you think there is not a perception that Better Regulation is genuinely reducing burdens? I deliberately frame that question in that way: all of us, as Members of Parliament, will see attempts that have been made to, for example, improve the design of DLA application or whatever; but none of us have seen the real re-engineering of business process that would radically change the volume of admin burden both for the department and for the client.

Mr Huddleston: The first point I would make is that the Administrative Burdens Reduction Target we are referring to meeting is administrative burdens we place on business, which is largely via pension regulation and via statutory sick-pay regulation; so this, if you like, is the form-filling that accompanies policies to increase pensions saving. You are talking about the wider definition of burdens, which -----

Q137 Chairman: I just have a feeling it might be endemic in the Department.

Mr Huddleston: It is certainly the case that the benefits system is a very, very complicated system, but we do have a range of activities going on in departments, a lot of them driven by their own self-interest to start to chip away at that burden. For instance, we have been simplifying our suite of leaflets to improve quality and consistency of the leaflets. We have been moving to more telephone-based claims, particularly for benefits for pensioners, which allow more benefits to be awarded in the course of a single telephone conversation. Then we have this very ambitious programme, which we call the "lean initiative" in the department, which is asking our front-line staff, who administer our processes, to take the process of, say, claiming benefit, apart, break it down into its constituent parts and work out which of those parts are actually needed. There is a very, very strong push within the Department to simplify both the benefits of products and the way we deliver them. That is going to be a long-term ongoing activity. With reference to the Administrative Burdens Reduction Target, there we have made some progress in reducing some of the information obligations we place on pension schemes. We have done some work to deal with some complex statutory sick-pay and we have been doing some recent work to look at the employer's liability compulsory insurance issue with retention and display of certificates. In that sort of area, where we have a specific measurable target, I think we will achieve it.

Mr Gregg: We certainly are on target. We have seen the 2007 Simplification Plan: Cutting Red Tape. The current estimate is 29 per cent by our 2010 due date. In terms of the difference, perception is the biggest challenge that faces all of us. In looking at how we can take forward the agenda and how effective what we are doing has proved to be for our stakeholders, we do go out and consult. On a fairly small scale, in January we asked 15 representative organisations and sent a short questionnaire asking: "Do you know about this regulation; do you think Defra is doing okay at it; have you spotted any differences?" It was quite interesting that although we only had six responses, it was a very tight timetable. All six came up with, "Yes, we have noticed a difference" and they all came up with an example, and there were six different examples. They are not major in themselves, but in the numerous sectors that we deal with, those small differences are starting to build up. Things like an environmental permitting programme - the major simplifications that are engaged in there will take time to be really felt. It is only when you go out with specific examples to business and say, "Do you remember yesterday you used to have to do this; and today you have to do this" that you get a positive response. If you ask for a general feeling, then business memory is fairly short when it comes to improvements that Government is able to bring about because they face day-to-day pressures like all of us to find more.

Q138 Chairman: I was impressed, Mr Gregg, with a process that your Department is responsible for on the Solway Firth that has very deeply brought together the environmental needs of your own Department and those of the DWP and HMRC in managing cockle-picking there, by introducing a very neat licensed bag in which people collect things. Is that kind of cross-departmental activity central to your thinking?

Mr Gregg: It certainly is, particularly when faced with challenges like that, where you have a relatively new organisation, a licensing authority, but there are many players both in central departments and at the local authority level as well. An agenda like climate change is something where we do not have armies of people who can solve that particular problem; we are entirely reliant on co‑operation, including with BERR on the energy front from other departments, but also in terms of the response from business and the general public. It is one of those areas where the non-regulatory response, the communication/education/persuasion route, stands to make nearly as many dividends for that agenda as the regulatory route; so this co‑operation and working together is increasingly important.

Q139 Chairman: The Minister told me the other day that the deregulating order, which has been long outstanding, will be coming shortly, and I look forward to efficient design on that as well!

Mr Wilmore: We feel we have made good progress on the ABR Target; we are about half-way to meeting the 25 per cent target and we are comfortable we will do that. Most of the gains to date have come through regulatory efficiency savings around the pharmaceuticals and medicines industry, and particularly the Better Regulation Medicines Initiative, which has involved a lot of joint working with the business community in the pharmaceutical industry to streamline and improve regulatory process such as online applications, simplification of medicines labelling procedures that allow companies to get medicines to market earlier and so on. That has had a lot of support and won an EU Cutting Red Tape award in 2007, so we are very confident that that programme will continue to deliver further reductions in regulatory burden as we start to look at how that applies to other areas such as prescribed medicines and generic medicines. The other main area that the Department has involving the business sector is around social care, and particularly in care homes for older people and other forms of adult social care, where we are starting a process of reviewing the national minimum standards and funding regulations that apply to social care providers, to simplify those and make them more outcome focused and less based on prescription and input. We expect to make significant savings by 2010 from that initiative as well.

Mr Podger: Just to complete the picture, I ought to confirm that we are ourselves also on target in relation to the Administrative Burdens exercise. On a perception point, to follow on from what Richard was saying, I think it is an inherently difficult question to ask people, to say, "Have you noticed the difference?"for the simple reason that people will notice it differentially in different sectors; and, second, inevitably, as happens to all of us, as soon as one things takes slightly less time each day something else takes more; and therefore people do not find themselves with spare time on their hands as a result of these initiatives. That does not mean to say these initiatives do not have considerable impact. I think they do. Our own experience within the Health and Safety Executive is that people who have got to deal with us are generally quite appreciative both of need for the regulation, but also the manner in which we enforce it. I think problems become greater in terms of wider public misunderstanding of the so-called "health and safety" problem but that goes well beyond what the Health and Safety Executive itself is responsible for.

Q140 Chairman: Is the 25 per cent target too broad-brush, or does it work for you all?

Mr Gregg: Can I take up on that one? Defra was considering what it could do in terms of Better Regulation and how we could respond to the voice of stakeholders who were saying "There is all this form-filling; reading voluminous guidance is consuming all our time and we do not have time to do business"; so I think we anticipated a target centrally. We looked to a 25 per cent target in the fairly early stages. It is something that has to be achievable, but it must be stretching; and 25 per cent is pitched at about the right level: it does not leave any of us feeling comfortable and it is quite a struggle to meet that target and make a difference. Too easy a target does not have that impact and does not help raise the culture changes that are necessary. I think making it a net target domestically has really forced us to think hard not only about the flow of legislation but about our existing stock, because departments do want to achieve outcomes and do sometimes need new mechanisms to do that; and therefore anything new that is coming forward we need to find offsetting savings. I think it has been a very good discipline like that; and I think the level at which it is pitched is about right. The unanswered question is - when we, all four of us, and our colleagues have succeeded in 2010, what will be next and what might the expectation be?

Q141 Chairman: That is precisely what I was going to ask next. Mr Huddleston, let us assume you hit your target - you say you are ahead of your target: when you have hit that goal, what is on the stocks next? What are you planning?

Mr Huddleston: We are planning to try and exceed the target fairly significantly because although 2010 is the point at which we are working to at the moment, if we look beyond that, certainly in DWP, we have a significant regulatory burden that will be associated with the new system of personal accounts, which is due round about 2012. We have roughly quantified what that burden is going to be. We are trying to get well ahead of the target so that when we are looking at things in net terms, we are still staying within that 25 per cent envelope. So our deregulatory review of private pensions that took place last year has identified some areas where we can get further savings we think. We think we can probably get some further savings from further simplifications to statutory sick pay. All of that is really saying that 2010 is only a date, if you like: if 25 per cent is going to mean anything, you have to look over a longer horizon.

Q142 Mr Davies: It is a most fascinating response! Did I understand you to say that actually you were trying to get ahead of the 25 per cent reduction target so that you would then have, if you like, some credit at the bank and you would then be able to regulate some more subsequently without breaching the 25 per cent ceiling: is that what I heard you say?

Mr Huddleston: I guess, or something similar to that. I am saying this is a net target.

Q143 Mr Davies: It is the most revealing insight into your office's approach to the 25 per cent target I have ever come across!

Mr Huddleston: Can I qualify? It is a net target so the idea is to find savings if you are going to impose costs -----

Q144 Mr Davies: I can see exactly - if you set that target, you can play this game; and if you can succeed in getting ahead of the 25 per cent - one would have hoped of course - and that would be very nave, I know - one would have hoped that you would have been so committed to the principle of deregulation for its own sake that you would have wanted to get to 25 per cent and get beyond and stay improving, getting to 30 per cent, 35 per cent or what-have-you. On the contrary, what you are doing is interpreting the 25 per cent target as something which, once you have got to it, once you get above that, you will then have some credit at the bank and be able to regulate some more, which is what you really want to do, I suspect!

Mr Huddleston: I do not think that is what I am saying; it is certainly not what I meant.

Q145 Dr Naysmith: That is the area that I was going to explore next with all four. Are there plans already to reduce the flow of new regulation, particularly statutory instruments, or at least ensure that the net burden is reduced, because we assume that other regulations will come along - not just because there is a gap appearing, but it will probably happen in the natural course of our activities because that is what we do in order to introduce laws and regulations? Quentin has already touched on that, so I will switch to the supplementary. There appears to be a consensus that influencing European legislation at an early stage is probably the best way of controlling the flow of new regulation - the earlier it can be the better, and achieving Better Regulation as well. Beyond simply agreeing that it is a good idea, what are your four departments doing to influence that kind of regulation and statutory instruments and European legislation?

Mr Wilmore: In the Department of Health it is mainly around the medicines industry again, where the European regulations have an impact. We have already seen some benefits through the savings we have had on the ABR targets already by simplifying European regulations. We will continue to work more closely with the BRE to keep a weather eye on where those will impact on the Department, because much of the regulation of the health Service is not subject to wider EU regulatory legislation; it is quite a specialised area that impacts on the Department of Health.

Q146 Dr Naysmith: I would have thought that European legislation on working time has a huge effect!

Mr Wilmore: Yes, sorry, in terms of working time - that is pretty much played through the service of the doctors' hours targets now and there are of course implications, but we do not foresee that changing in the future.

Q147 Dr Naysmith: Even though it will have a huge effect still - junior doctors still have more regulations to come, have they not?

Mr Wilmore: Yes.

Q148 Dr Naysmith: Is it that they are going to happen, and that is it?

Mr Wilmore: No, no, I am not saying that. I am saying is that we are aware of the direction of travel there so we have already got plans in place in terms of the workforce implications for that. It is not that we are expecting new regulations that we are unaware of that would impact on us.

Mr Podger: I think the major tide of European legislation in the health and safety field has temporarily at any rate abated, so we are rather more in the business at the moment of trying to, frankly, help our European Commission colleagues in meeting their targets for reducing administrative burdens. We have had some success, for example, in relation to the Electromagnetic Fields Directive, which has now been delayed because we and others doubt the evidential base for it. We have suggested simplification proposals to the Commission on directives that are already in force, which they have actually -----

Q149 Dr Naysmith: I did not know about that. Are they bringing in electromagnetic regulations from Europe?

Mr Podger: Yes, indeed.

Q150 Dr Naysmith: Even though, as you say, the evidence base is not very strong?

Mr Podger: Indeed so; and this has been a cause of considerable difficulty; but we and others have succeeded - very unusually in my experience - in persuading the Commission to not proceed with their proposal.

Q151 Dr Naysmith: Thank goodness for that! I am sorry, I interrupted you.

Mr Huddleston: I guess there are not very many EU regulations that impact on our burdens on business. Our usual tactic is to get involved as early as we can to head them off. That is all I would add to that.

Q152 Dr Naysmith: Do you think it works well? Are your antennae well enough tuned to pick up these things at an appropriate stage?

Mr Huddleston: These are fairly few and far between. They tend to be on the pensions side, and we are in early on those and are very successful.

Mr Gregg: I think it would be true to say that we are probably quite experienced in the area of EU legislation. A lot of effort goes in jointly both through the UK permanent representation from Defra officials back in home and from the Better Regulation Executive in trying to influence the European agenda directly with director generals - and we have had commendable success, I think, in this part of the 2005 UK presidency in getting regulating better on to the agenda. DG agriculture are certainly right on board; there are very encouraging signs now from the environment side; and I think we work with DG Enterprise, which leads on the European 25 per cent target, albeit that that target is not due to be delivered until 2012 and its make-up is slightly different in that it is specific about certain areas of EU legislation, a lot of which Defra leads on. As well as with the Commission, I think we are increasingly working successfully with other Member States. Commontology issues mean that the UK alone cannot achieve anything without support from at least a blocking minority. A recent example is the proposal on the Soils Directive, which had impact not just on the Defra agenda but on other agenda in Government departments. I think there was a slight sigh of relief that the proposals, as they sat, were successfully blocked, the UK being part of that, and work is continuing on trying to find something that balances things better. It is an ongoing collective effort with other Member States and with the Commission, and with business - because we should not underplay the impact that business representatives in Brussels can have, both at the UK level and collectively at the European level in taking the message to the European Parliament and to the Commission when the ideas are still at the gestation phase. By the time that the Commission proposal emerges you could say you are 80 per cent too late, so that early action is important.

Q153 Dr Naysmith: Is there a good working relationship between business representatives in Europe and yourself?

Mr Gregg: There is. We could always be better, and we could step back and think about the challenge from Europe. About a third of the flow of new legislation has sprung from Europe. Looking forward, it is likely to be two thirds - we have got to take that more seriously and take a step back and look at the strategy of how the UK engages with the European legislative machinery. Are we effective in a partnership with business, both UK businesses but also European businesses? Are we effective with Member States in getting alliances that are like-minded, so we talk to others just than the Dutch, who are clear leaders in this field?

Q154 Mr Davies: How do you communicate with your stakeholders, including business, to make sure that they are properly aware of Better Regulation initiatives?

Mr Wilmore: In relation to business, we work through particular sectors, again mainly the medicines and pharmaceutical industry, through a roaming initiative and also for social care providers through representative organisations such as the Care Home Association. With our public sector stakeholders the main mechanism is a provider advisory group that sits alongside the concordat I was talking about earlier, which brings together independent health and social care and NHS provider bodies and allows them to feed back to us the bureaucratic and burdensome irritants within the system which they have to face and their suggestions for reducing that. That is mainly around overlap and duplication of collection of data. That is a body that is supported by the Department and the Healthcare Commission, our deregulatory body which is the formal voice of stakeholders in health and social care; but we equally have a number of mechanisms and regular engagements as well.

Q155 Mr Davies: Mr Podger, how do you make sure that the Health and Safety Executive communicates with business and victims of your regulations?

Mr Podger: I would not myself describe people in those terms, but leaving that point aside it is fair to say that we, like Giles, have quite a variety of devices. For example, we have a small business trade association forum which has got 51 members and it is chaired by one of our board members, Judith Oliver, herself a small business person. They do therefore get very much of an inside look into HSE and they are able to make their points strongly and forcefully.

Q156 Mr Davies: How are the 51 members selected out of whatever it is- three or four million businesses?

Mr Podger: Basically the chair of the forum, Judith Oliver, who as I say is a board member and not a member of HSE staff, actually has quietly gathered about herself as many people as she could from the sector.

Q157 Mr Davies: She selected them.

Mr Podger: She has invited -----

Q158 Mr Davies: You did not ask people like the Small Business Association or the CBI or something to -----

Mr Podger: No, we do indeed do that as well. Sorry, when I say she selected them - in a sense everybody who sought to join has joined; it is not that we have thrown people out of the blue - we have made a lot of effort with small businesses, who are the most difficult people to reach we find and I do not pretend otherwise. We have also made a lot of effort working with representatives from businesses in particular sectors: for example, we have on our website now 29 different sets of advice on how to do simple risk assessments for small businesses - hairdressers or whatever - which basically says, "It does not have to take a long time and it is pretty straightforward; and this is how you go about it". We try and use the Web a lot, and I find that small businesses do access the Web a lot to get basic information. Like other colleagues, we have major links with all the major organisations, and we form specific ones on specific issues.

Mr Huddleston: At the highest level, the strategic level, the Better Regulation Stakeholder Group chaired by our Minister, pulls together representatives from the CBI, small businesses, TUC, Association of British Insurers, to give us a high level insight into the future direction of travel of Better Regulation.

Q159 Mr Davies: How often does that body meet?

Mr Huddleston: It meets with Ministers on a half-yearly basis and with officials on a quarterly basis, with one in between. More generally, I guess, very intensive stakeholder engagement with businesses occurs on specific policies, for instance the development of personal accounts; there has been a massive programme of engagement with businesses, both large and small, to pin down the issues of design, and similarly we involve businesses in looking at statutory sick pay as a policy. It is a fairly well-embedded culture.

Mr Gregg: Collectively, in terms of the Better Regulation agenda, publication of the Simplification Plan and the discussions that take place with businesses, and putting them together, is the main communication mechanism. At the strategic level we have periodic stakeholder workshops. We recently had one with energy producers where the focus was on the Better Regulation agenda. There are formal groups such as our ministerial challenge panel on regulation, which includes representatives from business. We have recently responded to representations from the National Farmers' Union and others in relation to land managers. We have an agricultural monitoring group relating to regulatory burdens there.

Q160 Mr Davies: Do you have a continued structured dialogue with the NFU about deregulation or the regulatory burden on farmers?

Mr Gregg: We do indeed. In response to their suggestion that they would like to participate more in this agenda, we responded to their idea of setting up an agricultural monitoring group. One of the issues that has generated that is now being looked at is the issue of record-keeping on farms - a particular burden that we are aware of - so we are looking to work jointly with them on that. In addition, it is true to say that we endeavour to make sure that those that are generating policy and producing impact assessments actually get out there and see what life is like in the real world, so it is not just a case of talking to representative bodies but also of going out there and experiencing it for real. The forthcoming code on consultation will actually help to make sure that the formal processes of engaging with stakeholders and collecting their views becomes slicker and more efficient and more visible in terms of departments understanding and responding to ideas that are coming from business.

Q161 Mr Davies: I would like to stay on the Defra issue, Mr Gregg, because that is the Department about which I get most complaints in my constituency in terms of regulatory burden. You said in your memorandum and you have already said this morning that you are on target to meet your 25 per cent reduction, but then in paragraph 1 of your document you say that though you got rid last year of 800 statutory instruments you introduced 1050 more - in the 2007 period. So you reduced the number of statutory instruments by 800 and increased it by 1050, which is a net increase of 250. How does that reconcile with the idea of you reducing the regulatory burden?

Mr Gregg: In terms of administrative burden, that is about the burden of filling in documentation and reporting - the administrative processes which to an extent are in some sectors a relatively minor proportion of that. In terms of the generation of statutory instruments, a number of those are revocations, as you have kindly identified; a number of them are technical amendments, so they might be updates of charging regimes; they might be implementation of the EU's annual agreement on total catches and quotas for the fishing industry. It is very difficult to look at a headline number of statutory instruments and make assumptions from that. The report we have placed in the Library of the House on SIs that have been promulgated since 2000 to date we have endeavoured to categorise and identify to help people such as yourself understand where these are coming from. They are not regulatory innovations; they are developments of existing regulatory frameworks.

Q162 Mr Davies: Right, but you understand the cynicism created by a department that says it is reducing the regulatory burden, and on its own evidence they are increasing the number of statutory instruments on that basis! To what extent are you still suffering from gold-plating of European directives?

Mr Gregg: The Davidson Review looked at gold-plating. I do not think that the Defra arena was one that came in for major spotlighting. Clearly, there were recommendations on the waste area, which I think we have responded to extremely positively. Gold-plating is something that is an understandable response from business. We do seek to ensure that at the domestic level and when implementing at the EU level, we are taking a balanced proportionate approach, particularly to those things that impact on business, and those are things like the touch points in terms of inspections, the monitoring activities and returning of data.

Q163 Mr Davies: You are telling me it is balanced and proportionate and all these nice words, but you are not telling me you do not gold-plate. You do gold-plate - you are admitting that!

Mr Gregg: We do not gold-plate; we comply with the requirements of -----

Q164 Mr Davies: You add additional burdens that are not required in the Directive, which other Member States, if they are implementing in a minimalist way, might not be legislating for at all.

Mr Gregg: We will consult with business in formulation of our negotiating position relating to an EU directive. In regard to some of the legislation that emerges from Europe we have no discretion whatsoever on how it is implemented, and neither do other Member States. In some areas, yes: how we technically go about implementing that legislation is down to domestic legislation, and in that process of designing the detailed regime we will consult widely, and we are anxious to make sure that it is proportionate and it is not gold-plating.

Q165 Mr Davies: Why can you not just give me an assurance that you will not gold-plate; that you will take these directives in which we have taken part in a formulation in Brussels in the decision-making process, and implement them minimally so that we do not create additional cost burdens and reduce the competitiveness of our own farms or our own businesses in relation to the rest of the Single Market?

Mr Gregg: Gold-plating for me personally is a phrase that requires some definition.

Q166 Mr Davies: Adding to; adding something other than the minimal required by the European directives: that is what I mean by gold-plating.

Mr Gregg: There are some areas where the general public and business are looking for the UK to not only comply but go further than compliance. I am thinking of areas such as animal welfare, where EU legislation would say, "Here is the minimum", but the British public would expect the United Kingdom to go slightly further.

Q167 Mr Davies: This is exactly the problem, Mr Gregg, and I am glad we have had this exchange because it is very revealing for anybody who wants to follow it. We obviously are committed in Defra to a continual policy of gold-plating. The argument about animal welfare is quite simply this: if we create greater compliance costs in this country because of higher animal welfare regulations, we will not improve the sum of animal happiness by one iota; it would simply mean that that type of activity moves somewhere else in the Single Market, where it can be legally carried on, where they have guaranteed access to the UK market, with a lesser compliance cost. All we would have done is shifted business to the rest of the Single Market, and we will not have improved animal welfare. However, this is a long and complicated subject, and I am glad that at least we have revealed that you are not committed to getting rid of gold-plating - at least I am sorry you are not going to do that, but I am glad you have revealed what the truth of the matter is. Sometimes the statements we get from Defra are a bit ambiguous. Can I put to you a final point on forms? If I may, and my colleagues will indulge me, it would be quite useful if I were able to quote this document Cutting Red Tape, the Defra Simplification Plan, because it is very revealing. "The 2005 Hampton Review found that overlaps in regulators' activity resulted in too many forms and too many duplicate information requests." Gosh, right, it recognises the problem. "It recommended that the Department should substantially reduce the need for form-filling." So I read on, hoping to hear that you had reduced the need for form-filling - no, no, no! You say: "Following research commissioned by Defra" - so you have responded to one report by commissioning another - "and an internal scoping review carried out in Spring 2007" - so you carried out an internal scoping review as well - "on the extent of form-filling requirements across the Defra network, the Department" - this is priceless, Mr Gregg, is it not? "The Department is looking at introducing a new strategic approach to minimising the form-filling burden that it imposes on business." So you had a review in 2005 which said there was a problem, that you were imposing too many regulations - that was three years ago. All you have done since is spend a lot of money on new reviews and new reports, and all you are doing as a result is "looking at introducing" - not planning on introducing, let alone "have introduced"! Is that not a pretty pathetic response to what has now been generally recognised as a serious problem?

Mr Gregg: I am glad that you have got a full copy of the report, and I would point you towards the areas where we highlight improvements which have led to administrative burden reductions, and are not only being on track to meet the 25 per cent admin burden reduction target, but we have exceeded 29 per cent, much of which flows from administrative processes such as form-filling. The environmental permitting side has reduced both the length and complexity and data requirements involved in that particular area. The single payments system - an awful lot of effort has gone in by the Rural Payments Agency to streamline that process and reduce the level of form-filling. I sit on a committee representing Better Regulation that looks at the statistical requirements that the Department requires in order to have evidence-based policy-making. There has individually, as part of the Simplification Plan been a major step towards reducing the number of forms and the content of those forms in terms of data requirement and removing duplication. We have reviewed the way we have forms. We know that we have a lot and there are some that are no longer used. There is now a strategy in place which will ensure that the efforts that have taken place within the context of the Simplification Plan fit within an ongoing strategy that will take us beyond 2010.

Q168 Mr Davies: That is just a lot of generalised aspiration, I think. Let me ask you a very precise question: you say in this document that the Department is looking at introducing a new strategic approach, which I said is a very inadequate response after three years of thinking about it: when are you going to decide whether you are introducing a strategic approach and what that strategic approach will be?

Mr Gregg: I am glad you highlighted the "new" strategic approach, because we did have an ongoing strategic approach as part of our Better Regulation agenda. The new strategy is being discussed now. Provided we can identify the -----

Q169 Mr Davies: When are you going to take action, Mr Gregg? This problem was identified in the Hampton Review in 2005 and you have been simply going round in circles ever since. When are you actually going to take action?

Mr Gregg: With respect, I bring you back to the fact that we have taken action. We have delivered substantial savings on business, reported in that report you have in front of you. We are -----

Q170 Mr Davies: In what timescale will you be able to send this Committee a copy of your new strategic approach?

Mr Gregg: I will, with pleasure, supply through the Clerk to the Committee an update on where our review is at, and we will take care to make sure that we signal in that when we hope to complete and publish our strategy. But we would like to take time to work with stakeholders to make sure that that strategy meets business needs.

Mr Davies: We look forward to that. Thank you very much.

Q171 Gordon Banks: I should say first that none of my questions are directed at DWP but I am engaged in SPPS work, and I think I should make that clear. We are told from information provided to us that 54 per cent of HSE forms that have been scrapped have saved something like 250,000, but in the next year nine forms will save 20 million, and Defra are claiming 44.6 million through different retailer record-keeping requirements. I suppose the first question I would like to ask is to the HSE. Why not do the 20 million first because of the significant impact, if it is nine with a 20 million saving; but also I have got issues on the absolute accuracy of the savings and how it is determined that nine equals 20 million; 54 per cent equals 250,000. They are very precise figures and there does not seem to be a margin of error in there or any scoping band.

Mr Podger: That is down to me! Fair enough! First, I will just explain that although the 54 per cent of forms seems a large number, which it is, actually it is in relatively small sectors which affect only a small population of businesses; so the consequence is the impact of the further nine further forms which relate to for example to registering a factory, which affect a much higher population of businesses. That is the reason for this apparent disparity. The answer probably is that if you are moving in a small sector it is much easier to make progress quickly than in a large one, for the reasons we have been discussing before, because you have to do a wider consultation before you can make progress. Equally - and I would not see this as a criticism of us - it is very sensible to take the low-hanging fruit first. As you can see from what we are doing, we are engaged in further form reduction, which will mean a major increase. We have done a major decrease in our forms before the present exercise of admin burdens came along at all, so it is important to see this as part of the process. The costs are indeed estimates, and they are very rounded figures, as you can see. They reflect the best estimates we could get through the Administrative Burden measurement exercise.

Q172 Gordon Banks: Do you think it is better to see 20 million then between 18 and 25 or whatever the numbers might be - that it is better to arrive at a firm number?

Mr Podger: As you will know well, and as the Committee will know well, the whole issue has been extensively gone through in this whole exercise because inherently the numbers are estimates. I know the TSE had a hearing on this at which this was made very clear by the people who gave the figures. I have no problem in saying the figures are estimates; they are inherently so. That has always been presented, how this particular exercise was done.

Q173 Gordon Banks: Would it be better saying 20 million is a fixed number than saying between two scopes?

Mr Podger: My suspicion, to be honest with you - and I am not a statistician - is that it would be quite difficult to provide a margin of estimates given how the figures were originally derived. The process, which again is known to you, was largely by approaching businesses themselves for estimates. Therefore, it is more difficult, as you rightly say to me - you can normally say it is between 18 and 22; but to be frank with you I think this particular exercise is costed in a way that does not lend itself to that approach.

Q174 Gordon Banks: Mr Gregg, in relation to Defra claims of 44.6 million through lifting retailer record-keeping requirements in relation to TSE, how credible is that figure?

Mr Gregg: I would echo Jeffrey's comments. It is credible. It uses a standard approach that is capable of being audited. Its accuracy and the impact on individual businesses is more fluid, but your point about giving a range - we are looking at a collective across-stakeholder summary of "these are the savings". If you are running a business, you are interested in your component of that. I think the saving is realistic. It was significant and it reflected an improvement in an overall strategy on dealing with that particular issue.

Q175 Gordon Banks: Mr Wilmot, in regard to the 30 per cent drop in information requests that the Department of Health are enjoying, how can we be sure that that drop in requests does not negatively affect the quality and reliability of the information and the statistics that are gathered?

Mr Wilmore: That is a very important point, and there are two ways we can do that. The Department is undertaking a review of informatics at the moment and is expecting to publish the results at around the same time as Lord Dharzi publishes his review in the summer; and that is really looking at the effectiveness of information flowing through the system and trying to strengthen the role of the information centres in health and social care, which has an important function in quality, assuring the data at the source of collection; so the recording of data for example in hospital trusts and the accuracy of the records, which is an important point in terms of administrative data, is an exercise that would have to go on regardless of the number of data collection, so it is a slightly different dimension in terms of the collections we are looking to pull or streamline are those that we set up some time in the past for the purpose or where there is not a clear need for the data at the moment, or subsequent data collections have gathered something very similar. So it is not about reducing the quality of data; it is about reducing the number of collections or collections that duplicate each other.

Q176 Gordon Banks: Mr Podger, relating to the earlier evidence about sharing of best practice or not, as the case may be, do you think people are working in silos, that the regulators are working in silos; that they have their own individual client problems to deal with; or do you think there really is this generic overlap that we would all aspire to? Is best practice being shared effectively from your point of view? If it is not a perfect world in that area, what improvements could be made? Should you have a role in disseminating best practice?

Mr Podger: I think personally that historically regulators have tended to work in silos, and I speak as somebody who was a regulator for a previous organisation, for the Standards Agency, in an earlier life. One of the things that BRE can take considerable credit for is what they have done to, frankly, move us all away from this particular way of working. You will be aware that BRE have published a series of Hampton compliance reports, where they looked at the five major regulators to see whether they were Hampton compliant. One of the things I thought they imaginatively did was not only to conduct these reviews with NAO colleagues, but they invited people from other regulators; so in a sense each regulator started doing a peer review of another regulator. This is extremely valuable because it is all too easy to believe that one's own sector is unique and peculiar, and nobody else can understand it; and actually I think it was a very valuable exercise. I think the NAO and BRE are about to publish individual reports or overall lessons. The other thing that is true is that precisely because of the pressure from the BRE over Better Regulation, the regulators themselves now meet regularly together with BRE so they do not just meet bilaterally, they meet together, which exposes a whole series of issues. I do not think it is any secret, but we also meet together to prepare ourselves for the next challenge. All of this seems to me to be a considerable step forward. That is not to say that I should tomorrow go and run the Financial Services Authority because I think that would be extremely unwise for a variety of reasons! However, it is to say that actually - that was not in any way a candidature notice! It is to say that there are things which are common to regulators, and we gain from that kind of exchange.

Q177 Gordon Banks: How long has this coming out of silos been in operation?

Mr Podger: I would say probably in the last two years. I joined HSE two and a half years ago, and I would say it is within the last two years.

Q178 Gordon Banks: Is there some way you measure the effect of coming out of your silos?

Mr Podger: That is a very good question, and I think the answer is what alterations we all decide to make as a result of seeing what other people are doing. It seems to me that that is the most effective measure. It is a process that has only just got started in the last two years, and it is one we need to build on. It is important to encourage exchanges between regulators.

Q179 Mr Davies: What you say is very convincing about the benefits of exchanges with other regulators or peer reviews, but I wonder to what extent you have contact with other regulators in other countries, for example in the United States or other countries where there may equally be lessons to be learned on both sides.

Mr Podger: We do. We are a party to something which has the horrid acronym of SLIC within the European Community, which looks at various labour organisations, because on the whole in Continental Europe they have labour organisations as opposed to health and safety ones. Indeed, that is an area that is very beneficial to us in learning how other people go about it. Frankly, we can see whether people can find better ways of doing things, what risks they identify and new ways of working - and also, to be frank, practices that we would not want to follow - for example, manic inspection and enforcement, which you can find.

Q180 Mr Davies: How often do you meet with SLIC?

Mr Podger: SLIC meets, if I remember correctly, around four times a year. It is very much about going out on inspections; it is not just sitting in a room like this; people go out and see what is going on. That is very helpful and we ourselves have some other bilateral contacts with other regulators in similar fields to ourselves.

Chairman: Gentlemen, that has been an enlightening morning. Thank you very much for your contributions. If there is any other information you would like to place before the Committee, please feel free to write to us and to clarify any of the points, or add, in the way Mr Gregg offered to, to Mr Davies. That would be extremely helpful. Thank you very much for your frank responses.