Ms Stella Creasy
MP for Walthamstow · Labour (Co-op) · United Kingdom
“I thank the Foreign Secretary for his clear-sighted commitment not only to talk about a two-state solution, but to actually try to act to achieve it, as the only foundation of a safe Israel and a free Palestine.”
“Could he reassure the House that we will not acquiesce and bend to such pressure, and that the only action that could ever be acceptable to us to make us contemplate reversing this ban would be a halt on the E1 development and a permanent end to settler violence?”
“I start by paying tribute to the new Minister, my hon. Friend the Member for Vauxhall and Camberwell Green (Florence Eshalomi), for all the work she did on the Housing, Communities and Local Government Committee on these issues. I know that she will do a brilliant job in this role.”
“I do not really understand the technology, but I know that he does, and I understand and share his fear accordingly. We come here today to debate this Bill because we all know that trust is a bygone issue in our politics.”
“We would welcome her having that conversation, which might be more illuminating than whether she is concerned about Zach Goldmsith’s leaflets. I add my support to the amendments tabled by my hon.”
“From today, if we do not take a stand with this Bill to tackle the ways that money has infiltrated our politics, the risk is that they will think we are acting in the interests of our own back pockets.”
The complete record
Every one of 4,976 lines we hold for Ms Stella Creasy, in date order, each linked to its source. Free to read, in full, without an account. Page 25 of 100.
“We must be clear that nobody is banning praying. We are saying that there is a time and a place to do it appropriately, which balances with people’s human rights. There has been some concern that, somehow, the buffer zones will take up police resources. Does my hon. Friend agree that, actually, amending the buffer zone legislation—as the amendment intends—would mean that more police resource would be needed, because it would become so unclear what was and what was not harassment, even when women repeatedly say that praying in their face is not acceptable?”
“I respect the fact that the Minister has his own personal opinion. For the avoidance of doubt, can he confirm to the Chamber that this legislation, as amended in the Lords, is compliant with the European convention on human rights and that it does not criminalise praying but sets out boundaries for where it should occur?”
“In order to support what he has presented to the House today, will the Prime Minister confirm that all remaining retained EU legislation will be retained in Northern Ireland itself, using the powers that he has and that Stormont currently cannot exercise? If he does not, how can anybody have confidence that we will avoid the regulatory divergence and that trade war which could undermine everything he has presented today?”
“May I associate myself with the comments and sentiments that have been expressed to the families of Betty Boothroyd and DCI Caldwell? The people of Northern Ireland have been through so much. This is a welcome opportunity to make progress, but, as the Prime Minister no doubt knows, clearing up the mess that other people make can be a never-ending job. The House of Lords is currently debating a Bill that will delete more than 60 areas of regulation that are not covered by the protocol. That is a process that the EU has already said will start a trade war if it goes through and that the Northern Ireland Human Rights Commission says undermines the Good Friday agreement. It covers issues such as electrical safety, food standards and farming standards.”
“I look forward to what the Minister has to say and to hearing how we might take the issue forward.”
“I am sure the Minister will argue that they are not quite at the level they need to be. I completely understand that; this is a first attempt to flag the issue. If the Minister can suggest other ways to set out in law the fact that we need consistency and that we want to close the loophole, I would be very open to that, but the Bill will not do all the things we want unless we are clear that it does not matter that a person thinks it is reasonable to grab a woman by her breasts to express their sexual interest in her—most other people would not. This Bill is about those commonplace forms of public harassment—24,000 women every single day experience harassment—and it needs to be tightened up. I hope Committee members understand where I am coming from with these amendments, and I hope they will find common cause across the House.”
“The Crown Prosecution Service guidance says: “In determining whether the defendant ought to know that the course of conduct amounts to harassment, the question to be considered is whether a reasonable person in possession of the same information would think the course of conduct amounted to harassment of the other.” It is important to clarify, in relation to the Bill, that in public order offences a judge can give what is called an oblique direction to a jury, so they can say: “This concept of reasonableness is not necessarily right.” That is there as a precedent, but reasonableness is not defined in every single case. There is a risk that if we do not clarify that we want those same protections and the same questions in this Bill, that will create a legal loophole. My amendments are about that.”
“I recognise that the Bill does not specify gender, and that is important, but we know from the 11 police forces that are defining misogyny as a hate crime and recording the gender of victims that the victims are overwhelmingly—80% to 90%—women. We do not want victims to be put on trial about whether their response—their statement that such behaviour was not acceptable—is reasonable, because that would bring into play the very simple concept of whether anybody else would think it is reasonable. That concept exists in other harassment legislation—not just the Protection from Harassment Act 1997, but the Serious Organised Crime and Police Act 2005.”
“Don’t abuse me”—will become a legal defence, because in contrast with other pieces of harassment legislation, there is no provision that says someone ought to know their behaviour is unreasonable in the definition of intent in the Public Order Act. My amendments will do something very simple. They will introduce the concept of “ought to know” that is contained in other pieces of harassment legislation. I hope the Minister recognises that that will help to create consistency in how we define harassment in law. More importantly, none of us wants to see those women who are brave enough to come forward under this legislation and say, “This person did this to me” be put on trial about whether they can take a joke. Nine times out of 10, that person will be a man.”
“I was just trying to chat you up.” “Can’t you take a joke, love?” “It’s a compliment.” “Don’t get your knickers in a twist!” We have all heard those phrases when we said to somebody, “Stop.” We have all had the experience of somebody feeling they are entitled to touch us and harass us because they think their behaviour is reasonable. These amendments speak to a simple point. Most men in this country know how to approach a woman if they find her attractive. They do not feel the need to touch her breasts or her bottom or to harass her and abuse her, but some do. If we do not close this legal loophole, a commonplace experience for women—being challenged when they speak up for themselves and say, “No, don’t touch me in this way. Don’t speak to me in this way. Don’t harass me.”
“The Protection from Harassment Act 1997 refers to conduct that “occurs in circumstances where it would appear to a reasonable person that it would amount to harassment of that person.” In contrast, public order offences simply allow the perpetrator to define whether they thought their behaviour was reasonable. Every woman in this room will recognise the challenge that that presents, because I wager that all of them have probably experienced unwanted touching and unwanted behaviour. I pay tribute to the Clerks, who have been fantastic in working with me on how we address that challenge. Let us put it in the simplest phrases: “Cheer up, love!”
“My amendment are probing amendments, but I hope that by the time we get to Report, the questions they raise can be answered by the Government, because this is not a partisan issue; I think that Members across the House recognise the point I am making. Public order offences are based on the concept of intent—did someone intend to harass somebody? They therefore give the person who is accused of it a defence that says, “Well, I thought my behaviour was reasonable.” The concept of reasonable behaviour is contained in other pieces of harassment legislation, but in that legislation it is also defined by whether someone ought to know it was reasonable.”
“What this legislation does that is so powerful is to say, “No, actually, it is not women’s job to protect themselves; it is society’s job to stop the people doing this.” The amendments I have tabled speak to that culture and the challenge we face in getting this right. As the right hon. Member for Tunbridge Wells said, this is based on public order offences. There are other pieces of harassment legislation, which I am sure many people are familiar with. I had the fortune in a previous lifetime to work on some of them, which is why, on reading the Bill, I was concerned to identify some of the challenges with using the public order offence. I hope the Minister recognises that I want us to get the legislation right.”
“We talk about people being handsy, and we talk about “creepy”, but all these behaviours are criminal. What this legislation does is so powerful, because it says that the criminal offences that have been so much a part of women’s daily experience of public life should be acted on. For many of us who have campaigned on the issue for years, one of the biggest frustrations has been being told that we could not act on these things, because if we did, so many people would be prosecuted that the system could not cope, so it was up to women to take the abuse and find ways of minimising it and protecting themselves, carrying their keys in their hand and making sure they were alert at all times when they were in public, rather than us stopping it.”
“New clause 3 and amendment 5, which I tabled, and new clause 1, tabled by the right hon. Member for Romsey and Southampton North but not selected for debate as it was not in scope, all get at the same point about ensuring we take this opportunity we finally have to recognise in law the fact that misogyny is driving crimes against women and to act on it. I was thinking about some of the euphemisms we use and the things that are part of the culture we grow up in. We become so used to the fact that women are at risk and face harassment and abuse on a daily basis that we minimise it. I remember when I was younger being very concerned about somebody I was told had “deserts disease”, because I did not understand what it meant, until somebody explained to me that they meant wandering palms.”
“It struck me how important it is that we do not give into those who say that this is too complicated an issue to make progress on. The honest truth about being a woman is that you learn to live in fear. You learn in our society and our culture to be half aware of what is going on around you at all times, because you know that there is danger out there. When I look at my little daughter and think about what is to come, I know why this legislation is so important. I wager that everybody who has young children in their life thinks about these issues. In particular, tackling the public harassment that women face on a daily basis is long overdue, and many of us in this place have worked on it. That is why it is so important that we take the opportunity to get this right, because they come along so rarely.”
“It is a pleasure to serve under your chairmanship, Sir Gary, and to continue to work on the Bill. I thank the right hon. Member for Tunbridge Wells for his diligence on this legislation. Many of us feel very passionately about the issue, and we are grateful for his commitment and the work he has done to bring so many people together around what has historically been quite a difficult issue to make progress on. I was watching my three-year-old daughter gambolling down the street the other day. “Gambolling” is the right word; she was in a party dress, half dancing and half singing, and she was joyful. She was walking down the same street that I walk down when coming home from work, with my keys in my hand, looking around, nervous about who else might be on the street.”
“That may be the way to do it, in the same way that this offence-plus also brings in the concept of discounting whether sexual gratification was part of the process. There will clearly be a point at which somebody decides whether it is a 4A or 4B offence, and that seems to be the point at which we could be clearer about the intent and whether somebody reasonable would know about it. We could put that in the Bill to give directions to judges and magistrates about how to interpret “reasonableness”, which is what I think we are all looking to get to. I hope that that is a helpful intervention to clarify where I think there is space to marry the two different types of legislation together.”
“I thank the Minister for her time looking at this, because I have spent many hours doing so. I pay tribute to the Clerks, who were incredibly patient as we worked through the almost circular logic of when intent comes into this offence, partly because it is not a new offence; it is a kind of offence-plus, which is where some of the challenges about the decision on intent could be. With the Government’s support on Report, we could learn lessons from other protections from harassment and other harassment legislation about the reasonableness test and where it comes in. I know that that would get support from the Opposition and the Minister’s colleagues, and it could clarify the point at which a defendant could claim reasonableness.”
“I hope we can clarify that it is not about whether something is serious and it is not about whether someone has intent; it is specifically about this concept of who decides whether behaviour is reasonable, so someone can mount a reasonableness defence. I am sure that young man would argue until he was blue in the face that I just could not take a compliment. That was not a compliment. It was harassment. It was intimidating and it was scary, and it is exactly the sort of behaviour the Bill is designed to capture—but he would have that defence unless we close the loophole. That is what we are getting at.”
“The difficulty with this legislation as it is currently constructed is that he could say in court, “My behaviour was reasonable—I thought it was reasonable.” In other forms of harassment legislation, that concept of reasonableness could be tested by whether anybody else would think it reasonable, but that would not come into play here, because of this difference in how we define what harassment is in different pieces of legislation. This is not about whether we could prove intent per se; it is the gap between how we define harassment in other forms of legislation as opposed to under public order offences, because they are about the first time somebody has contact with somebody. I know the Minister said she and the officials will look at this. I hope they will.”
“The Minister is being very generous in giving way. A few years ago, when I left Parliament late at night and I walked up the steps to go to the underground, a young man—I was probably old enough to be his mother—walked up behind me, and slid his arms around my neck and then slowly round my breasts. He was trying to persuade me that I wanted to go to the Red Lion pub with him. I was very clear that that was not acceptable and I was not going to go. He followed me all the way down the street and I had to be quite physical to get him off me. In that instance, he believed his intent was to charm and seduce me. He thought that that was an acceptable way to approach somebody.”
“For the magistrates who deal with these cases, it is even more important that we are clear that if somebody says, “I just thought that if I slapped her bottom, she would notice me,” that is not reasonable, because in today’s era slapping somebody’s bottom is not the best way to get their attention or express interest in them. Because we are dealing with that first form of contact, we have to match in this legislation the way in which we have talked about what is reasonable in other legislation. Otherwise, the cultural barriers that we are trying to get through will come into play even more, because they will fill the vacuum that a course of conduct would otherwise fill.”
“In thinking about how to get this right, perhaps it would also be helpful to clarify that other forms of harassment legislation look for a course of conduct because they generally cover experiences in which we think somebody might have had a number of interactions with their victim. In this case, however, we are talking about the first time that people interact with people. The challenge is whether those ideas about “boys will be boys” and the clumsy attempts at trying to get somebody’s attention become even more part of the discussion about whether it was harassment.”
“I am not going to press it this time, Sir Gary, but I do want to be clear that there is an issue that needs resolution. I withdraw on the basis that something will come back on Report—”
“There is a simple problem here. For some families, having childcare is the difference between being able to work or not. What should those families do with a child that is perhaps between the ages of six months and two years when there is no support at all? A six-month-old baby could be left in a cupboard at work, I guess, if that is the logic behind this. By the time they are one year old and they are crawling and walking around, that is not feasible, yet the subsidies kick in only at two years old. It makes no sense at all.”
“During the pandemic, when we were patting parents on the back but investing in potholes, the message from those mums was, “Up with this we will no longer put.” In my final 15 seconds, I want to let Ministers know that “This Mum Votes” is not just the name of a campaign; it is a statement of intent. If we do not get this right, mums and dads around this country will not forgive the political party that has yet again put childcare in the box marked “Too difficult to deal with”. Children who deserve the best future need us now to stop messing around and start investing.”
“It certainly does not work when we tinker around with ratios or when the Secretary of State for Work and Pensions sends a letter to women who are out of work, telling them they really ought to think about going back. What works is investing early. The £2.8 billion that is sitting unused and unclaimed in the Treasury’s coffers, just for the tax-free childcare system, could be spent right now on childcare. It could be invested in getting early years right so that in the next five to 10 years we will have a universal system that matches those of our economic competitors. I say thank you to Pregnant Then Screwed and Mother Pukka—to the people who have refused to let politicians take the issue off the agenda.”
“It needs investment to get us to a point at which there is a return. There is no area of economic policy in which investing leads to saving so clearly as in childcare, yet in this country we still act as if it were an optional add-on to an economy that is already struggling with productivity issues. The fact that there are 5,500 fewer providers than a couple of years ago attests to how the system is not working for anybody. It does not work for the industry: these wonderful people caring for our children are professionals, so we should value their professionalism rather than playing it down. It does not work for the mums and dads who are looking at astronomical costs. It does not work for our economy.”
“I do not think that is just because the system itself is completely bonkers; it is because so many families who want the help the most cannot afford to stay in childcare to the point where it is subsidised. Of course childcare should kick in when a child is born, so we need to reform our maternity provision, but we also need to look at provision for children from six months on. We need the system to be universal, because that is when it pays for itself. The evidence from other countries makes it incredibly clear that it can help more families to stay in work, and it can help more women to keep their career and keep their caring commitments. Some 85% of providers of childcare in this country are operating at a loss. This is not an industry that needs us to tinker around the edges.”
“That is why I encourage the Minister to support the amendment that is being supported by Conservative colleagues of hers in the Lords right now, to make sure that we treat childcare as infrastructure and that local authorities are able to invest in it. Over the last five years, only 0.06% of developer contributions have been spent on childcare—that is just £1 in every £1,167 spent —yet we all know that when we build new flats, we are going to bring in new families. What are we supposed to do with them? I encourage the Minister to take up the point made by the hon. Member for Stroud about the eight separate schemes. Of course, there is money there that could be better spent. I think of the 1.4 million children who are eligible for 20% off their childcare via the tax system but for whom it is not claimed.”
“That is the argument we need to take to the Treasury. With the greatest respect to the Minister, who I have no doubt is doing that, I want to see Treasury Ministers here, explaining why we are not investing in economic infrastructure—because that is what childcare is. Just as good roads get people to work, so too does good childcare. Yet, too often, we act in this country as if the opposite is true; as though we are doing mums a favour by providing childcare, giving them a couple of hours to go to baby yoga, rather than recognising that it is about how families balance their different commitments.”
“The very simple question we all need to ask ourselves is: at what age do we think children start learning? When I look at my 18 month-old son and what he can do with an iPad, I know that it is very early on. We invest in children because they are our future, and yet our system does not reflect that thinking. We cannot solve the cost of living crisis unless we solve the cost of childcare. As we know, multiple families are now spending more on childcare than on their rent or mortgages. The number of women in this country who are economically inactive because of caring responsibilities is increasing; it has risen by 53,000 in the last year alone. Those women cannot get the decent childcare they need to be able to make it work for their families, and the economic impact of having them out of work is felt by us all.”
“Nowhere else do we think that if people are not struggling and having a miserable time—unless they are incredibly wealthy and have multiple nannies and people to stay at home with them—they are doing it wrong. Let us change that; let us have a different debate in this place. Let us come together across political parties to say that is it not enough to keep talking about this and worrying about extra hours here and there. I agree with the hon. Member for Stroud (Siobhan Baillie) opposite that tinkering around the edges will not do. It is time for a fundamental rethink of how we do childcare in this country, not least because of the impact on children themselves. That was pointed out by my hon. Friend the Member for Brentford and Isleworth (Ruth Cadbury), who secured this debate, for which I thank her.”
“Thank you for coming in at short notice to chair this debate, Ms Fovargue. It is hugely appreciated, I suspect, by the thousands, if not millions, of mums who are just fed up. Because we are: we are fed up. For generations, we have debated this issue in Parliament as though people are talking Klingon—as though it is something that is beyond our reach or our capacity to resolve. I think the dads are pretty fed up, too, because they are not getting to be with their kids. Outside this place, that is the norm: parents want to spend time with their children and find ways of working that allow them to do so. Our childcare system, unlike those in many other countries, militates against that. There is no other area of public policy where we accept—nay, celebrate—the idea that there will be a struggle and a juggle.”
“On that point, I think the Minister is starting to talk about one of the challenges: where money has been set aside for childcare, but has not been spent. She spoke earlier about the not-100% take up from those who are entitled. Since the scheme began to give parents 20% off their childcare costs, an average of £2 billion to £3 billion a year has gone unclaimed. Given that it started in 2017, we are talking about a possible £17 billion that could go into tackling these challenges with the cost of childcare. Before she sits down, what conversations has the Minister had with the Treasury about getting our £17 billion of tax that parents have paid into the system back, so we can put it into paying those who care for our children properly?”
“This is harassment and terrorism on our doorstep, and it needs to be dealt with properly. What on earth is he doing to prosecute these people?”
“The truth is that this is not the first time we have seen violence and intimidation directed towards refugees in these hotels. Indeed, the hon. Member for Boston and Skegness (Matt Warman) outlined his fear of a further protest coming this weekend. Hope not Hate has documented hundreds of incidents involving Patriotic Alternative, Britain First and so-called migrant hunters. The Minister says the Home Office reports to the police incidents that it feels may breach the Public Order Act 1986, perhaps in the same way it is monitoring these lawyers, yet nothing is happening. He says these groups are being monitored closely. For the avoidance of doubt, will he set out the threshold for prosecution? This will keep happening until we are clear that free speech does not involve 50% of participants in the conversation being in fear of their life.”
“The Minister seems to be walking away from the question of what role Brexit has played in this economic outlook. I can understand why, since half his own constituents think Brexit was a mistake. The benefits of Brexit seem to be like a toddler’s imaginary friend—Ministers keep talking about them, but only they can see them. The Prime Minister’s spokesman today told us we are now seeing “significant benefits from Brexit.” Will the Minister set the record straight? Can he explain to the small businesses in our constituencies, which used to be able to export with ease to the European Union, a single market where they now face a better deal than they did before?”
“Everybody agrees that leaseholders should not carry the can for these dangerous buildings, but the problem is in the delivery. I have been contacted by many constituents, including those on Planetree Path in Walthamstow, who cannot turn to their developer because it has gone bust, and whose freeholders claim to be too small to be liable. In the absence of anybody to hold to account, these residents have already had to scrape together £10,000 to pay for the surveys and reviews required before a single change can be contemplated to make safe the buildings in which they live. Can the Secretary of State confirm that those residents will be able to reclaim those costs from the building safety fund? How will that happen so the Government can make good on their pledge that leaseholders will not pay the costs?”
“Member now use his authority as the Minister responsible to require these companies to have a duty to prevent human trafficking and modern slavery? Will he finally make sure that, for all the money they are making out of this, they do something to protect these children? It is on his watch that these children are going missing, and it was on his watch that he missed out that requirement from the contract.”
“The Minister says that safeguarding these children is a priority for him. He will know that since October last year, I have been asking to see the safeguarding requirements that he has placed on the private companies involved in running these hotels for both unaccompanied and accompanied children. I understand now why he was so reluctant to give that information: when I finally used a freedom of information request to get it, there was no mention at all of requiring these private companies, which are making millions of pounds running these places, to do anything about modern slavery or human trafficking—not one word. Let us be clear. It does not matter whether these children are Albanian, Syrian, Pakistani or Iranian. It does not matter whether they are boys or girls. They are children. Will the right hon.”
“The challenge here for the Minister is that the original allegations arose in July of last year, publicly. Indeed, there was subsequent evidence that lawyers were instructed to try to suppress those allegations, well before any appointment was made by his political party, or indeed by the Prime Minister. The Minister talks about allegations arising this weekend. Whose due diligence was lacking: was it the Cabinet Office’s, was it the Conservative office’s, or are we just not being told the whole truth in this matter?”
“The hon. Member for Rochford and Southend East (Sir James Duddridge) talked about statutory instrument Committees. I think all of us have sat on statutory instrument Committees, where we know that it is a question of like it or lump it when it comes to what is being proposed. Under this Bill, Ministers will have powers over key issues that our constituents care about. The Minister talks about the dashboard and admits that it still needs to be updated. As a matter of good democratic practice, will she give us, here and now, today, the exact number of laws covered by this Bill, so Members of this House can at least have some sense of the task that they are voting for? If she cannot tell us how many laws are covered, it is definitely not clear to us how any of us can influence them.”
“Does he agree that, if Ministers have made up their minds on some things but not others, they should be honest with the British public that they are asking us to give them the power to make that decision and take it away from this place? That is not taking back control.”
“I think everybody agrees that, as we have left the European Union, we need to look at the foundation of the laws that we have in this country. One challenge of this legislation is that, because we do not know precisely what laws are covered, we do not know the laws that we need to look at. Does my hon. Friend agree that people are concerned not because the law says “Europe” on it, but because it is about things such as maternity rights and employment rights? [Interruption.] The Minister is chuntering from a sedentary position. She needs to talk to her colleagues who, when we have asked about these explicit regulations and whether they are going to retain, replace or revoke them, have said that they do not know. They do know on other legislation.”
“We also have to hope that our colleagues in the other place will make it clear that we can have influence—and not just in like-it-or-lump-it statutory instrument Committees; don’t kid anybody who has sat on one that they are a good or effective version of parliamentary scrutiny—and that we can speak up for our constituents. It may feel like cold cup of sick territory when we see something with the word “Europe” in it, but with all the rights and regulations up for deletion under the Bill, I promise that our constituents will not forgive us if we do not stand up for parliamentary sovereignty and support amendment 36.”
“The Minister ought to talk to her colleague the Minister for Food, Farming and Fisheries, who wrote back to me clearly saying that the Government were reviewing that. That is the problem: Conservative Members may trust their Government colleagues to do the right thing, in the same way that they might trust a 17-year-old when they ask for the keys to a Porsche “just to polish it”, but those of us who have been here and seen Governments of different colours, and the temptation that comes with ministerial power, know that the point about taking back control was parliamentary sovereignty. That starts with knowing what we are being asked to hand over: we are being asked to hand over oversight of an unknown number of laws. That is what amendment 36 asks for clarity on.”
“Those are surely things that Ministers would want to put beyond reach, so nobody could say that they might be revoked or accidentally lost down the back of the ministerial sofa, along with the 800 sets of regulations that have no ministerial leads and are quite likely to get lost in the process. The problem I have is that Ministers are clear that there are some regulations that they are going to revoke and some they are going to keep. So they do know what they want to do with the power that Members are going to hand them; they just do not want to be honest about it. Why do they know that they want to keep the regulations on bird flu, but not those on maternity and paternity leave?”
“Frankly, Back Benchers of any political party should be worried about the precedent set by legislation that allows the Government to give themselves an enabling power without defining its limitations. That is before we even get on to who makes the decision about what happens next. Ministers want to tell me that I am scaremongering when I raise concerns about how they will use these powers—they say, “Of course we wouldn’t get rid of these laws.” Well, let us have a look at that scaremongering. I have been tabling parliamentary questions to try to understand what will happen to rights that all our constituents care about, such as paid annual leave, bathing water quality, sharps rules in hospitals, consumer protection from unfair trading, food hygiene and toy safety legislation.”