Product Regulation and Metrology Bill [HL]

Baroness Brinton Excerpts

Committee stage
Wednesday 11th December 2024 Grand Committee

I am aware that the Government’s intention with the Bill is to set an overall picture, but I really hope to hear from the Minister about the Government’s intention to take action in all these areas, and to do so particularly quickly in the area of period products. These are probing amendments, but I need to hear some very positive news about action; otherwise, I may well return to them on Report. I beg to move.

[Baroness Brinton (LD)]

My Lords, I thank the noble Baroness, Lady Bennett, for tabling these three amendments. I have a question about Amendment 59.

Paragraph 9 of the Schedule says that:

“Medicines and medical devices as defined in the Medicines and Medical Devices Act 2021, other than devices designed for weighing or measuring for medical purposes”


are excluded from the Bill. I say that because the guidance on what is and is not covered by that Act is somewhat contradictory. It says that sanitary towels and tampons are

“not normally considered to be medical devices”,

yet incontinence pads, which are not internalised in the body, are. In America, tampons are deemed medical devices because they are used inside the body.

I appreciate that I am putting the Minister on the spot. I do not expect an answer, but I wonder whether the very good speech by the noble Baroness, Lady Bennett, might point to a problem with the Government’s guidance under that Act that needs to be amended.

[Lord Sharpe of Epsom (Con)]

My Lords, I was not planning to say very much about this, but I thank the noble Baroness, Lady Bennett. I do not feel remotely battered; I feel significantly better informed, and I am grateful for that.

It struck me that Amendment 57 is somewhat pertinent to the discussion we have just had about supply chains. I wonder, for example, whether the habitual buyers of fast fashion would be quite so enthusiastic if they understood how it was made and the environmental despoilation it entails. Of course, a lot of fast fashion is single use.

I am also intrigued to know—I have just been thinking about this—what makes a non-iron shirt non-iron. I imagine it is some sort of chemical. As a fan of said shirts, I would rather like to know, not least because the noble Baroness’s description of the destination for microplastics made me wince slightly, to be honest.

Of course, a lot of single-use plastic ends up in the ocean. Frankly, as a keen scuba-diver who has found single-use plastics below depths of 30 metres, I think that societies across the world need to address that.

I do not have much to say apart from that, but I will be very interested in the Government’s answers. I would also be keen to pursue these issues later.

[The Minister of State, Department for Energy Security and Net Zero (Lord Hunt of Kings Heath) (Lab)]

My Lords, that was a very interesting debate, and I am very grateful to the noble Baroness, Lady Bennett, for her amendments. She spoke tellingly about the impacts the products to which she referred are having on the world, on disadvantaged communities and on human health more generally. She gave a lot of information and I will try to respond to the general principles, but I will also take away her speech and ask my noble friend to write to her with a more considered response, as I would like our officials to have a look at some of the details of the concerns she raised.

Amendment 58 is about single-use plastics. The Government recognise the concerns the noble Baroness raised about plastic products, plastic waste and plastic pollution. We think we already have the right powers and, to an extent, with what comes in this legislation. The question she is really challenging us on, I think, is whether the Government’s action is sufficient. I will try to persuade her that we are very much on this, that we have the legislation and we are pursuing the issues she has raised.

For instance, there are powers under the Environment Act 2021 and the Environmental Protection Act 1990 that allow us to regulate certain matters relating to products, including single-use plastics and plastic packaging, that show evidence of harm to the environment and/or human health. This includes powers for bans on manufacture, product design and labelling requirements, charges and targets. UK REACH also contains powers to address harmful additives that might be added to plastics to ensure the safety of consumer products. We know about, and I pay tribute to, the carrier bag charge. It has been very successful and has had a great impact on the United Kingdom. We have also seen other product bans and restrictions, such as those relating to microbeads, and plastic straws, cotton buds and stirrers.

Additionally, the forthcoming extended producer responsibility for packaging uses the powers in the Environment Act 2021 to make producers responsible for the costs of managing packaging once it becomes waste, and encompasses packaging of all materials, not only plastic. The improved packaging design—and I think the noble Baroness made a very important point about this in the previous debate—will be incentivised through the modulation of the fee the producer must pay based on its environmental sustainability. There is, of course, a risk in focusing just on plastic that we encourage companies to use some other material that might be equally damaging. Therefore, it has to be considered in the round.

Also, the noble Baroness may have seen the Statement made by my colleague Emma Hardy, the Minister for Water and Flooding, in the other place about the final negotiations that we are involved in to develop an international treaty on plastic pollution. The Minister said:

“Plastic pollution is one of the greatest environmental challenges that the planet faces. The world produces 400 million tonnes of plastic waste each year. Scientists predict that there will be a threefold increase in the amount of plastic entering the ocean between 2016 and 2040. A global agreement on plastic pollution is urgently needed”.


She then goes on to say,

“The Government have an ambition to catalyse the transition to a circular economy”—


which we have debated in previous days in Committee—

“and the treaty is one of the key levers available to us to achieve the systems-wide changes needed to make that a reality”.

She went on to say:

“Plastic waste has for too long littered our streets, polluted Britain’s waterways and threatened our wildlife. This Government are committed to cleaning up Britain and cracking down on plastic waste. We will roll out extended producer responsibility to incentivise businesses to cut plastic packaging and the deposit return scheme to incentivise consumers to recycle”.—[Official Report, Commons, 25/11/24; col. 31WS.]


So we are taking this seriously and we think we have the legislation that we require. It is worth noting that, as part of this work, the Defra Secretary of State has convened a small ministerial group on the circular economy and asked his department to work with experts from industry, academia, civil society and the Civil Service to develop a circular economy strategy.

We will come on to the issue of clothing. In the meantime, the Government continue to fund action on clothing through Textiles 2030. This is a voluntary initiative that supports businesses and organisations within the fashion and textiles industry to transition to more sustainable and circular practices. I also assure noble Lords that Defra will keep the House updated with work in this area and we are happy to ensure that the noble Baroness can speak with relevant Ministers to discuss this matter further.

Amendments 57 and 59 seek to ensure that regulations are made to reduce the risk posed by clothing and period products. Again, the noble Baroness made a powerful speech. I must admit, a frisson of fear shook me when she mentioned London Fashion Week because it recalls the time when I was Minister for Sustainability in Defra, quite a long time ago. We were involved in starting developments in sustainable clothing, and I was invited to make a speech on sustainability on the first day of London Fashion Week. I thought it went well until I saw the review in the Daily Telegraph, which ignored my speech but referred to my suit being rather crumpled, which was a trauma I have never recovered from.

I come to the substance of what the noble Baroness said and the legislation. The General Product Safety Regulations do not make specific provisions for reducing the risk to consumers from harmful chemicals among some products, potentially including those that the noble Baroness raised, including period products. Although the legislation requires that the product placed on the market must be safe, it is not tailored to mitigating these risks. What it does is enable the introduction of new regulations to ensure that the Government can continue to reduce and mitigate the risk to health and safety posed by products, which could potentially include those listed in Amendments 57, 58 and 59.

The Bill can ensure that we are able to regulate the use of chemicals in consumer products, as we currently do for cosmetics and toys, as well as in other consumer products with similar chemical exposure risks. I reassure the noble Baroness that we will use the powers to identify product sectors and hazard types that require action, including period products where regulations may need to be strengthened or updated. This will be done on a risk-led basis. It will be evidence led, proportionate and follow appropriate stakeholder engagement. It goes back some time but, as an example, the Nightwear (Safety) Regulations 1985 set flammability and labelling requirements for children’s and adults’ nightwear. They are an example of risk-based regulations where a particular hazard was identified, and that can be done again.

To conclude, the noble Baroness, Lady Bennett, made a powerful speech. I want us to have a look at some of the details. We think we have the legislation. The debate is really about what the Government should do and we are active in this area.

I am afraid that I shall have to duck the interesting question from the noble Baroness, Lady Brinton, and write to her. We will have a look at the details of that.

[Baroness Brinton (LD)]

The Minister worked on the medical devices Act, as indeed I did. That Act is mentioned here, and I hope we might be able to table an amendment to this Bill to amend that Act because of the inconsistency. Will he look at that before he writes to me?

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[Lord Sharpe of Epsom (Con)]

My Lords, I will speak to Amendments 68 and 90, which are in my name. These amendments address the serious concerns raised by the provisions in Clause 3 and Clause 6, which give the Government sweeping powers to create or widen criminal offences and impose civil sanctions.

I have to revisit some old ground here but, given the gravity of this issue, I feel we have no choice. As was pointed out by the Delegated Powers and Regulatory Reform Committee and the Constitution Committee, these clauses are skeletal legislation, meaning that they lack detail, leaving critical decisions about enforcement and prosecution to be made at a later stage via secondary legislation. We feel that the approach of using skeletal legislation for such crucial issues is problematic. These clauses give broad powers to create and enforce criminal offences without providing clear primary legislative guidance on who will have the authority to impose sanctions. This is particularly concerning because it leaves us very little clarity on which bodies will hold the responsibility to prosecute criminal offences.

The DPRRC and the Constitution Committee have highlighted these concerns, noting the lack of detail in the Bill and its potential to bypass parliamentary oversight. The Government’s decision to leave critical decisions about enforcement powers to be determined later by regulation, rather than in the Bill, undermines the transparency that businesses and consumers need. The Bill as written provides no information about the exact scope of the criminal offences that could be created or widened. This is not just a technical issue. It raises serious questions about the accountability of the bodies that will enforce these sanctions. The Minister may not be happy that these issues continue to be addressed but, until we receive clarity, we have a duty to bring these issues up, as I hope the Committee would agree.

The most concerning aspect of the clause is the provision allowing the creation or widening of criminal offences by regulation. The powers given to the Secretary of State or any other body of a public nature in this regard are overly broad, with little or no clear guidance or justification on what these offences will be. The Bill should, at the very minimum, provide some specification of the type of offences that may be created, rather than leaving this to broad, undefined powers that will most likely lead to overreach. The question has to be asked: why is it necessary to give the Government the power to create new criminal offences by regulation in the first place? Given the gravity of criminal sanctions, the Bill should be more transparent and specific about what offences will be created and who will be responsible for enforcing them—a point that the noble Lord, Lord Fox, made in his reference to the CPTPP, incidentally.

Criminal sanctions carry serious consequences and it is fundamental that Parliament has a say in the creation of such offences, rather than allowing the Government to define them through secondary legislation. We understand that the Government have argued for flexibility in enforcement and that the regulatory framework must be adaptable, but that flexibility should not come at the cost of clarity or proper oversight.

We have heard serious concerns from businesses and industry stakeholders about the skeleton clauses in this Bill. Specifically, there is real uncertainty about which public bodies the Government intend to designate as having the authority to impose criminal sanctions. Again, the question has to be asked: what additional public bodies are the Government planning to empower to prosecute businesses for currently barely defined criminal offences under the Bill?

As my noble friend Lord Lansley pointed out on the previous Committee day, currently enforcement responsibilities for consumer protection laws are set out clearly in Schedule 5 to the Consumer Rights Act 2015, which names very specific enforcement authorities, but the Bill removes that clarity and instead gives the Government the power to designate by secondary legislation which public bodies can impose criminal sanctions. This creates a situation where businesses may have to deal with a wide array of bodies, many of which may not have the expertise or experience needed to understand the complexities of product and metrology regulations.

This broad power to assign enforcement duties to any body that is deemed appropriate opens the door to a wide range of unknown authorities, so the question here is: why are the Government attempting to create this uncertainty? Why not retain the existing list of enforcement bodies in the Consumer Rights Act 2015 and allow changes to be made to that list through normal, well-defined procedures, rather than using secondary legislation to grant powers to an unknown set of authorities? Businesses deserve to know exactly who will be responsible for enforcing the regulations and imposing sanctions. The Bill’s current drafting creates a legal vacuum where there is no certainty about the powers of various public authorities, which could have serious consequences for businesses’ legal security.

The ambiguity surrounding criminal sanctions is deeply troubling for business, especially when these powers can be used by a range of authorities that may not be clearly identified at this stage. It raises serious concerns about due process and the fairness of enforcement actions. If a business is unsure whether it is complying with regulations and there is uncertainty about which body will be enforcing them, the risk of facing criminal sanctions obviously becomes much higher and that creates an environment of fear and uncertainty for business, which is already facing difficult economic conditions.

This situation is further complicated by the fact that secondary legislation will define the details of how these sanctions are imposed, potentially without proper scrutiny by Parliament. Criminal penalties should never be determined by regulation alone; they must be clearly laid out in primary legislation with full parliamentary oversight.

The balance of probabilities standard in civil cases can create significant challenges for businesses as well, especially in the context of the provisions outlined in the Bill regarding enforcement and sanctions. The balance of probabilities standard makes businesses more vulnerable to claims from enforcement authorities or competitors. In the absence of clear regulations and objective criteria, businesses may find it difficult to mount a defence as the mere likelihood of non-compliance could be enough to trigger sanctions. This could result in a climate of fear and uncertainty whereby businesses are hesitant to innovate or engage in new activities, due to the potential for legal action based on speculative or incomplete evidence.

The Government have claimed that this Bill will support economic growth and innovation, yet its skeletal nature and the conversations that we have had with leading industry experts suggest that they are concerned. Moreover, the Bill already includes an emergency clause—we will come on to this in our debate on the next group, I think, and we will address it later—that allows for swift regulatory action if necessary. So there is no reason why criminal sanctions cannot be made clear at the outset. There is simply no need to leave the scope of criminal offences and enforcement powers so broad and undefined.

To clarify, we absolutely recognise the importance of product safety and the need both to protect consumers and for necessary regulations. We oppose the various skeletal clauses in the Bill, as we have made clear over the course of these Committee sessions, because of the lack of clarity and the potentially authoritarian powers given to unnamed, undefined public bodies in some of these regulations. I hope that the Minister will address the many concerns the amendments in this group address and will commit to clarity for business. I beg to move.

[Baroness Brinton (LD)]

My Lords, my amendments in this group—Amendments 69, 91 and 107—cover a somewhat wider area than those in the name of the noble Lord, Lord Sharpe of Epsom. I shall return to his amendments and the speech he has just made later, to comment on them—but I start by saying that Amendment 92 in the name of the noble Lord, Lord Jackson of Peterborough, is helpful. One of my concerns at Second Reading was how Parliament can be made fully aware by more than just the laying of regulations, when a Minister or another body decides to create or widen the scope of criminal offences, that they must lay an Explanatory Memorandum in the Libraries of both Houses. I look forward to hearing the noble Lord speak later; his amendment is part of a possible solution.

At Second Reading, the Minister said:

“We have minimised the use of the powers in the Bill as much as possible and we have worked closely with the Attorney-General—who, quite rightly, is a stickler for these kinds of things—to find the best approach. So we look forward to the report of the Delegated Powers and Regulatory Reform Committee, which we will carefully consider”.—[Official Report, 8/10/24; cols. 1940-41.]


In my speech later on in that debate, I raised my concerns about a Minister who was not based in the Justice Department being able to create or extend criminal offences by regulation, with no ability to amend and much less detailed debate in both Houses of Parliament.

At Second Reading, we had not seen the second report of the Delegated Powers Committee, because that was published on 15 October—a week afterwards. Its summary about this part of the Bill is blunt. It says:

“We consider that … the Government have failed to provide a convincing justification for the inclusion of skeleton clauses in the Bill”


and suggests that

“the delegations of power in clauses 1, 2, 3 and 9 are inappropriate and should be removed”.

There is some detail about why it thinks that, in particular, there is a problem with the creation of, or the widening of the scope of, criminal offences. I mention this because I absolutely appreciate everything that the noble Lord, Lord Sharpe, has said about the skeletal nature of the Bill earlier on—indeed, my noble friends have also made those comments—but I want to focus on the impact of having new criminal offences on the criminal justice system. I shall come to that in a minute.

My first two amendments tackle the creation of criminal offences—in the first part of the Bill on product regulation and in the second part on metrology. I have also laid Amendment 107, which seeks to ensure that new criminal offences are not created through the clauses on information-sharing regulations. Clause 7(3)(d) talks about

“sanctions for non-compliance … including … creating, or widening the scope of, criminal offences”.

That is exactly one of the points that the Delegated Powers Committee is making: the Bill is so skeletal in nature, it appears that information sharing is a route by which criminal offences could be made. I would be grateful if the Minister could respond to that.

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I understand the good intentions and concerns—of all noble Lords—behind these amendments. I have highlighted, I hope, that we are following precedent. With that in mind, I ask noble Lords not to press their amendments in this group.

[Baroness Brinton (LD)]

My Lords, the Minister has been very helpful in explaining about the affirmative process, and he has talked about the Explanatory Memorandum, but he has not responded to my questions about the consultation with the Home Office, the Ministry of Justice and the relevant agencies. If that happens, will it form part of the Explanatory Memorandum? My concern is that this is all still led very much by the Department for Business and Trade and does not take account of the concerns and pressures faced by the Home Office, the justice system and their respective arm’s-length bodies.

[Lord Leong (Lab)]

I thank the noble Baroness for the question. I will need to come back to her on it because I want to be absolutely clear that I am giving her the correct information, rather than me saying something now on the fly.

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[Baroness Brinton (LD)]

I am grateful to the noble Lord, Lord Jackson, for his question because it reminded me that when all the primary and secondary legislation on Covid was going through, most of the references to “emergency” were the definition in the Civil Contingencies Act. That Act is not defined in this Bill, and “emergency” is used loosely on its own. I wonder whether there is a bear trap there. If the department means to use “emergency” in the sense of the Civil Contingencies Act, it may be better and more helpful to name it. If not, will the Minister explain why the use of the definitions in the Civil Contingencies Act are inappropriate?

[Lord Leong (Lab)]

My Lords, I really do not know the answer to that. Obviously I will find out and write to the noble Baroness.

[Baroness Brinton (LD)]

I thank the Minister—I am grateful.

[Lord Leong (Lab)]

I am told that we were advised by counsel that this word is more flexible to use. I do not know whether that is sufficient but perhaps we can explore that further.

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Moved by

[Baroness Brinton]

82: Clause 5, page 6, line 8, at end insert—
“(3A) Regulations under this section must have regard for the impact of metrology regulations on small and medium sized enterprises.”Member’s explanatory statement
The amendment ensures that new metrology regulations under the act have regard for impacts on small and medium sized enterprises.

[Baroness Brinton (LD)]

My Lords, the noble Lord, Lord Fox, is unable to be in his place at this stage of the day because today’s Committee date was confirmed only after he had made an appointment that cannot be changed. On his behalf, I will speak to Amendment 82, which would ensure that new metrology regulations under the Bill have regard for impacts on small and medium-sized enterprises.

It is self-evident that the capacity of small and medium-sized businesses to process and understand regulation is many orders of magnitude different from that of large companies. That is why the Bill should explicitly consider this difference in capacity every single time a new regulation is to be tabled. How will a two-person organisation cope? What is the appropriate level of regulation? This Government say that they are about growth. SMEs are largely the engine of growth, and misplaced overregulation is a key brake on those size of companies. I hope the Minister can answer these questions. In the light of these concerns, this simple amendment calls on regulators to keep this at the front of their minds.

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[Lord Leong (Lab)]

My Lords, I thank all noble Lords and noble Baronesses for their contributions in the debate on this grouping of amendments; in particular, I thank the noble Lords, Lord Fox and Lord Sharpe, for their amendments. This Government are committed to supporting businesses as we get the UK economy growing.

I begin with Amendment 82 in the name of the noble Lord, Lord Fox, which was moved by the noble Baroness, Lady Brinton. He specifies that regulations made under Clause 5 of the Bill

“must have regard for the impact of metrology regulations on small and medium sized enterprises”.

The noble Lord has also proposed the publishing of impact assessments of affirmative regulations, to be laid every six months after the Bill’s implementation.

Similarly, Amendments 103 and 104 in the name of the noble Lord, Lord Sharpe, propose publishing a report assessing the Bill’s impact on consumer choice 12 months after the Bill is passed, as well as another report every two years on the economic impacts of the Bill. The noble Lord’s Amendment 104B would further require the Secretary of State to present a report to Parliament detailing the impact of regulations made under the Bill’s powers on SMEs.

I am happy to confirm that the impact of any new regulations will be fully considered through the development of proportionate impact analysis. As I said before, the Better Regulation Framework is the system that government uses to manage the flow of regulation and understand its impacts, including on SMEs and micro-businesses. On 7 December, the Government launched their new Business Growth Service to ensure that it is easier for SMEs to find government advice and support, giving them more time and money.

In line with the Better Regulation Framework, for regulations where significant impacts—above £10 million per year—are anticipated, full impact assessments will be published. For regulations with lower anticipated impacts, a proportionate assessment impact analysis will be completed. These assessments will, as a matter of course, consider the impacts of regulations on SMEs. Furthermore, officials currently routinely engage with SMEs and stakeholders to shape policy, including in the light of emerging technological and industry developments, and to identify and address any disproportionate burdens. The OPSS regularly engages with a small business panel as part of policy development.

I hope that this confirmation provides reassurance to the noble Baroness, Lady Brinton, and the noble Lord, Lord Sharpe, on this important area, and I am grateful to them for raising it today. The Government remain committed to supporting SMEs and recognise the vital role they play in the UK economy. As such, the Bill will allow the Government to update product and metrology regulation to avoid extra cost to business and provide continued regulatory stability. It will also allow the Government to end recognition of EU requirements where this is in the interests of businesses and consumers. The Bill will enable the Government to introduce proportionate product safety requirements that protect consumers and create a fairer playing field for law-abiding businesses.

As some noble Lords will know, before I came to this place I was a serial entrepreneur all my working life. I understand how micro-businesses and SMEs work. SMEs spend most of their time creating and growing the business. They do not want additional costs or regulations impacting their business. Having said that, all that businesses want is a level playing field where they know the rules of the game and what regulations are in place. Imposing additional regulation is not the intention of this Government. We are constantly consulting SMEs to ensure that, whatever regulation is in place, it does not impact SMEs and micro-businesses.

As I said, growth is the Government’s number one priority. On 14 October, we published a Green Paper, Invest 2035, setting out a credible 10-year plan to deliver the certainty and stability that businesses need to invest in the high-growth sectors that will drive our growth mission. This industrial strategy will create a pro-business environment and support high-potential sectors and clusters across the country. By giving the UK the flexibility to adapt its own regulatory framework to keep pace with international regulatory developments and respond to global trends, the Bill supports economic growth and innovation.

This flexibility ensures that the Bill supports economic growth—as I mentioned—reduces unnecessary regulatory burdens and ultimately benefits businesses, including micro-businesses and SMEs. However, introducing a statutory reporting obligation would risk duplicating existing processes, diverting resources and delaying the implementation of timely and effective regulations that provide businesses and consumers with the certainty they need.

I am sure that many noble Lords know that the EU’s general product safety regulation comes into force this Friday 13 December. Under the terms of the Windsor Framework between the UK and the EU, we have to apply it in Northern Ireland, so we will publish on the Government’s website clear guidance to SMEs that want to export to Northern Ireland and the EU. We will prepare a statutory instrument to implement a new enforcement regime in Northern Ireland to allow this GPSR to be enforced. This is a requirement of the Windsor Framework.

I mention this to show that there are regulations that SMEs have to abide by—this is one of them—that will impose a certain amount of burden on SMEs, especially in the run-up to Christmas. Many small businesses will now find it very difficult to export to Northern Ireland and Europe if they do not have a legal representative in the country to verify their goods.

As I have outlined, I believe that the very laudable sentiment behind these amendments is already covered by existing practice, so I ask noble Lords not to press them.

[Baroness Brinton (LD)]

I am grateful to the speakers in this debate and to the noble Lord, Lord Sharpe, for his Amendments 103, 104 and 104B. They aim, I think, to achieve the same objective as Amendment 82 in the name of the noble Lord, Lord Fox, but in more detail.

I am with the Minister—I thank him for his response —in saying that more paperwork and more regulation is not what we on these Benches wanted to achieve in Amendment 82, which is why it says that any regulations “must have regard for”. I hope that the Minister will take that on board. I want to ask him something; perhaps he might write to me, if he intends to write anyway. He kindly talked about the different types of impact assessment, including whether they would be full or proportionate. We completely understand that those would happen, but will those impact assessments specifically highlight SMEs? In other words, will an untutored eye flicking through see “effect on SMEs” in bold, and then something underneath it? I am seeing nods from the Minister, and I look forward to his letter.

I am glad that the Minister raised the extra burdens on firms either selling into Northern Ireland or the reverse. It is not just about that: over the last few years, we have seen very small businesses having sometimes to double the number of their administrative staff to cope with, for example, things such as music groups touring across Europe. The objective has to be keep that paperwork down as much as possible. Obviously, I will confer with my noble friend Lord Fox, and I look forward to the Minister’s letter. We may return with this later.

[Lord Leong (Lab)]

Before the noble Baroness withdraws, I can confirm that, when we do the impact assessment, we take SMEs into consideration as well.

[Baroness Brinton (LD)]

I beg leave to withdraw the amendment.

Amendment 82 withdrawn.