Daniel Zeichner
MP for Cambridge · Labour · United Kingdom
“I recall, as a shadow Minister, visiting a major institution in the country and sending the management into panic when I asked them where the bus stop was to get back to the station.”
“My hon. Friend is absolutely right about the location of bus stops. I am so frustrated when I have taken the train to Cambridge, arrive at the station, see the bus, but have to walk 200 yards around the platform, come out of the station and walk 200 yards back to the bus stop, to find the bus has gone.”
“Devolution and local government reorganisation are different things. To be honest, they should probably be considered separately, but they have become so interlinked and intertwined in this debate that it is impossible to do so. If we are to have a stronger devolution settlement, it is right to spend more time getting it right.”
“I commend the Secretary of State and his team for their determination and resolve in the transfer to renewables. In the extraordinary and unprecedented weather that we are having at the moment I can assure the House that some shade would be really welcome in parts of the east of England.”
“I commend all the hard work that has gone into both the road map and the profitability review by the civil servants, the ministerial team and so many people across the sector, including Baroness Batters.”
“On that point about speculative building, I appreciate that the hon. Gentleman is probably not a fan of big, bold projects of this kind, but does he agree that there is a very good example just down the road in Cambridge?”
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“That would attract considerable support across the House. Question put , That the amendment be made.”
“The right hon. Gentleman is making my life much more difficult and I am going to have to be horrid to him again. Yes, in one sense, he is correct, but that is the challenge. Throughout this, if we do not find ways, whether in trade agreements or whatever, to protect—and it is protect—our higher standards against lower standards, we are lost entirely. That will be a recurring theme throughout this debate. I do not think it is beyond the wit of hon. Members to find a way of doing that. The right hon. Gentleman may disagree with me, and that will probably be a fundamental point of difference. I have two final points to make: first, I do not think it is fair to offload the responsibility entirely on to consumers. We should take the lead. Secondly, we need to take the lead on making sure that we can protect our higher standards.”
“My hon. Friend the Member for Bristol East has raised a very important point. The lunchtime reading of the ELMS policy discussion document prefigures further discussion on this. It is a shame that we were not able to have our earlier discussion in the light of some of these points. To a number of us, on first reading, tier 1 does not look sufficiently ambitious, in many cases, and it feeds exactly into my hon. Friend’s point that there is a worry that we will not get the environmental gains that we thought we would. That will be of concern to many. I wonder if the Minister could clarify that point.”
“I appreciate why trying to get the balance correct is a difficult dilemma, but it is crucial that we do so. We are not satisfied, frankly, that we are getting the clarity that is required. We understand that this is a framework Bill, but much more detail is required to give certainty, so—I may be speaking on behalf of my colleagues here—we would like to push the amendment to the vote.”
“Precisely for the reasons that my hon. Friend has explained, we will support the amendment. We need to include many more people in the system and to make it far more likely that they will be able to benefit from it.”
“I echo my hon. Friend’s comments. It is important that small farms are not left out of this legislation. As she said, in the evidence sessions we heard compelling evidence from the Landworkers Alliance that farmers on smaller holdings have been much disadvantaged to date by the current payments system due to the 5 hectare threshold, which cuts those with less than 5 hectares out of the system for getting payments. I was surprised to hear that 85% of its membership had never been able to get support for their work. We know why: back in the previous iteration of discussions, there was concern that small firms would not be subject to cross-compliance. That is my understanding. That was possibly a reasonable position to take, although I suggest that the answer to that is that there should be proper and appropriate checking and verification.”
“Although that may cause disagreement, that is what we are here to resolve. I do not think that the Opposition will be able to support the amendment.”
“I was intrigued to discover the direction in which the amendment would take us; I probably should have known in advance. It gives me an opportunity to have a genuine disagreement with the right hon. Member, because I think many of our constituents would be astonished at the idea of sporting shooting being considered a public good, in terms of putting public money in, although I recognise that for some Members that would be legitimate. Again, it points to the whole new world that has been opened up by taking the pot of money that used to go directly to farmers based on area. We are now facing up to some really quite hard decisions about the kind of world in which we want to live. I have to say to the right hon. Member that for many constituents, I suspect in my seat and many others, it would not seem an appropriate use of public money.”
“I understand why the Department wants maximum flexibility, but we want some action, because we have been waiting a long time for these promises. In fact, I think on the last day of the last Parliament, at DEFRA questions, the Minister in the Lords promised action, so when are we going to get some action on banning peat burning?”
“I think I have demonstrated that that is not entirely the case because, as we look into the detail, we find tweaks and changes. I am not sure that we understand what the exact impact will be on the way in which the schemes will work, but it is our duty to at least ask. I hope that we get clarification on some of that. Who knows? We may at some point get the long-awaited policy paper on how the new systems will work, which I think was promised for the Second Reading and Committee stages. If it turns up in the middle of the night it will be no help to many of us, but we look forward to it with relish.”
“We do not know how the currency will go this year, but it will make a significant difference and the provisions have, obviously, been taken out. In a number of places, I do not understand why articles have been retained: 30 to 39, 65 to 66, and 79 to 91. Within those, there are references to “Member States”. I suspect that they should have been taken out, but I may be misreading them. Article 46 includes a reference to article 42, which seems to have been deleted. Article 97 goes to the heart of the claim year issue and the complexities around January. Again, some detail would be welcome. It is not clear to me why in Regulation (EU) No. 907/2014 articles 3 and 4 have survived, nor why in Regulation (EU) No. 908/2014 articles 16 to 24 and 45 to 57 have survived. We are told that nothing has changed, and that this is the status quo.”
“There is no reason to believe that there is any desire to weaken them, but as I read the legislation it potentially will do so. Moving on to Regulation (EU) No. 1306/2013, article 9 talks about certification bodies. I think that this matter has been controversial in the past. Again, I seek clarification from the Minister on where the Government think that we are going. It looks to me like a potential change. Articles 12 to 15 on farm advisory systems are effectively deleted, which seems significant. I would welcome some reflections on the impact of that. Article 29 is a detailed account of how the exchange rate issues would have been dealt with, which are of course potentially very important for people.”
“The EU tries to define the agricultural practices that are beneficial for the environment and the climate, with a series of details in annex IX. I return to my point about who will check all of that. It seems that we are potentially now checking our own homework. Turning to the second instrument, which amends Regulation (EU) No. 639/2014, it is not entirely clear to me why articles 62, 63 and 72 have been left in, and there are one or two articles where the “Member States” amendment does not seem to have been made: articles 16.2 and 33. In article 45, I do not see the logic in detailing the list of pollen and nectar-rich species when land is lying fallow. There may be a reason, but it is not clear to me. Perhaps more significantly, article 45.5 changes—I would say weakens—the rules on governing the sizes of buffer strips.”
“If she is unable to reply today, I would be perfectly happy with a written reply later. I do not understand why the article 28 provision on windfall profit has been deleted. There are many paragraphs on the regional and national reserves. The term “regional reserves” is not to be understood in the way that many of us would understand it. I ask the Minister for some details on the reserves and how they will be used in the future. It does not seem entirely clear. The point I am making throughout my remarks is that, although the top-level message is that nothing changes, as we dig down into the detail we begin to find that it is not quite as straightforward as it seems. In article 43, which is an important set of paragraphs, the EU sets out something not dissimilar from the work that we will do going forward.”
“In the more pernickety points that I will get to in a moment, I will point out some areas that do not make sense to me, where those changes have not been made. Those may, of course, be minor drafting errors, or there may be reasons for them. It would be useful to tease out why those decisions have been made. I suspect that we will come back to the active farmer debate another day, possibly even tomorrow. However, I ask today why we are deleting the reference to granting payments to airports, rail, water services and sports areas in article 9.2 of Regulation (EU) No. 1307/2013, and replacing it with a much more general provision. I believe it has been discussed in the past, but some clarification would be helpful. I do not expect the Minister to know the answer to all my questions instantly.”
“Interestingly, it also talks about the ability to transfer funds between what, in EU jargon, are described as “the first and second pillars”. Broadly speaking, that means the opportunity to put more money into environmental goods, which is exactly what we want to do. It is striking that in England, when the Government had the opportunity to exercise their full discretion to move to 15%, they chose not to do so. Without reopening past debates, it is worth noting in passing that we have not exercised the full flexibilities that were available to us. As the Minister has said, many of the changes made by the SIs are simply changes to wording. I am sure it would be wonderful to do a replace all, changing “member state” to “relevant authority” and so on, but alas, it is never that simple.”
“1307/2013—I apologise to Members who do not have the full details at their fingertips, because this will possibly be a little tricky, but that regulation is the legislation that SI 91 amends. I have to say, I have had a crash course in learning how the CAP works; in a previous life, I used to do local government finance, and would joke that the only thing that was more complicated was the CAP. I have come to regret that particular line now. What struck me about Regulation (EU) No. 1307/2013, which was the EU’s attempt to improve the CAP last time around, was just how much of what the EU was trying to do was the same as what we are now trying to do. The preamble talks about the absolute necessity of reducing administrative burdens, and about tackling abuse.”
“I seek some reassurance regarding that. It is also striking that we are now outside the EU crisis reserve. To laypeople, that would look remarkably like moving out of an insurance system and into an uninsured position. Of course, we may well think that that is fine because we have the full weight of the Treasury behind us, but the basic point is that if we are part of something bigger, we are pooling the risk. Obviously, we hope that reserve is not needed, and some of the money is on the way to coming back to us, which is fine. However, we should at least be aware of what we are doing. I will now move on to the detail, beginning by looking at Regulation (EU) No.”
“Turning to annex 2 of that memorandum and looking at the detail of the SIs and the pieces of EU law that they amend, further concerns arise—again, some of this will be discussed in detail later. The Minister made this point tangentially in her introduction, but basically, we will withdraw a level of scrutiny from the whole process by taking out the EU level. Many people, of course, will be delighted by that—they will be cheering—but huge sums of public money are involved here, and we need to be sure that appropriate mechanisms are in place to replicate some of that scrutiny, although not necessarily the bits we do not like. The Minister may be confident that those mechanisms are in place, but not everyone has total confidence in the Rural Payments Agency, or feels it has the necessary resources in place to do this extra job.”
“A potential infringement on 31 January may well be treated differently on 1 or 2 February. That could well be quite complicated; all I observe is that it would be good times for lawyers. This was supposed to be about giving certainty, but as Labour warned on Second Reading, some of this may be difficult to sort out quickly, and by the middle of this year farmers will be wanting to make decisions for next year. As we have said, we worry that far from giving certainty, this process will carry on for some time yet. In paragraph 7.8 of the explanatory memorandum, there is a glorious phrase: “The Government remains committed to beginning ambitious agricultural reforms”. I am sure that will reassure lots of people. “Remaining committed to beginning” is hardly encouraging.”
“I suspect we will talk much further about that in the coming weeks. We learn in paragraph 6.6 that the regulations are laid under powers in the 2020 Act, which basically provided for the Secretary of State to do what is necessary to make this stuff work. One wonders how many more measures will be needed to sort out what is a considerably complicated set of proposals. If one was beginning to think it could not get any worse, paragraph 6.8 points out the further difficulty—I will return to this in my detailed account—that different rules apply for January. Until exit day, EU law applied, but retained EU law relates to the whole of the claim year, including January. This may not be for today, but at some point it may be helpful for the Minister to explain how anybody is going to be able to work out exactly how this works.”
“In paragraph 2.9 it describes the regulations as the “appropriate legislative ‘fixes’”, which “will maintain a status quo position”. Of course, on Second Reading of the Direct Payments to Farmers (Legislative Continuity) Act 2020, the Opposition pointed out exactly that: the first act after exit day was to keep the status quo. We understand why that was necessary—because of the unfortunate delays in bringing forward legislation—but all of these measures would be unnecessary if we already had the Agriculture Bill in place. We do not have to go much further through the explanatory memorandum to find yet more problems. In paragraph 6.3 the dreaded concept of equivalence pops up, when we are made aware that we need to maintain equivalence to continue to benefit from state aid exemption rules.”
“I was also struck by some rather understated humour that emerged at some points, particularly in the explanatory memorandum that accompanies these regulations. If you do not mind, Ms Nokes, I intend to go through points raised in it before going into the detail of the regulations. Those who have read the explanatory memorandum will notice how it quickly becomes a complicated explanation, particularly of how this legislation interacts with EU retained law. By the time one gets to paragraph 2.5, one reads: “As a result, existing law would either be unclear or would not function effectively.” That it could be unclear is potentially an understatement, but we will try to develop clarity, as that is why we are here. The memorandum goes on to talk about the danger of potentially “inoperable provisions”.”
“It is a pleasure to serve with you in the Chair, Ms Nokes. It is also a pleasure to welcome the Minister to her place. I am sure we will spend many happy hours together discussing these points in the coming weeks. She is well placed to do so as a farmer and an experienced lawyer, and I am sure that she enjoyed as much as I did spending the recess reading EU regulations 1307/2013, 639/2014 and so on. For those hon. Members who are hoping that our sitting will be quick, I am afraid I did read those regulations, and I would not want all that time to be wasted. It struck me that things do not seem entirely oven-ready or “got done” at this point; it will take a little time. However, I must pay tribute to those who drafted the regulations before us, who, quite frankly, must have the patience of saints.”
“Dr Fenwick: In clause 36, which relates to organic products, subsection (5) makes it clear that it is possible to restrict or prohibit the import of organic products. That will be legislated for once the Bill becomes an Act. We would have expected an equivalent paragraph or provision relating to other production standards to have been incorporated in the Bill. It is there for organic, yet it is not there for all these other issues and in particular the key issue that John raised—our environmental and climate change obligations.”
“Obviously, it would be a disaster if that were then undercut by food production systems that are illegal in the United Kingdom, so we would be deeply concerned about the opportunity there and we would like to see that much more strongly identified in the Bill and ruled on. We welcome the comments that a number of you made during the Second Reading debate. Also, Liz Truss, International Trade Secretary, said last week: “In addition, nothing in any agreement will undermine the Government’s commitment to tackling climate change.” —[ Official Report , 6 February 2020; Vol. 671, c. 15WS.] We lead the world with our commitment to net zero by 2040, so we look to that being honoured. That is an absolutely key statement to us going forward.”
“Q Good morning, Mr Stringer, and good wishes to those on the Government side who may have a nervous day ahead—we wish you well. My question is one that we have put to other witnesses before. We are obviously very concerned about the potential threat to farmers if food is imported that was produced to lower health and welfare standards. What is your view on that and what do you think could be done about it in the Welsh context? John Davies: We have a very clear vision and ambition to lead the world in producing the most climate-friendly food, and that is to be realised with proper policy and proper support going forward.”
“The other big element of soil health that has been neglected by the environmental side as much as by the farming side, is biodiversity in soil. I assume that is as simple as the fact that it is below the ground, and therefore you do not see it. I heard an interesting statistic the other day: in a typical sheep field, the weight of creatures underneath the field far exceeds that of the animals on the surface, whether as simple as worms or down to bacterial and fungi. The problem is that, because we do not see it, it is not that immediately obvious to us. It becomes obvious through things such as feeding birds in the winter—the number of lapwings on the fields. If there are no invertebrates in the fields, there will not be birds above them. Getting back to a sense of the biodiversity of soil will be a good way to re-engage with it.”
“Q Since the earlier iteration of the Agriculture Bill, there has been wide acknowledgment that we face a climate crisis. As part of that, although clearly different in different parts of the country, there is a crisis around our soil, is there not? Could you say a little about how intense that is? Gareth Morgan: There is a soils crisis, which is expressed in a number of different ways. It is probably slightly alarmist to talk about a certain number of years of soils left, which is quite graphic and gets people engaged in the topic, but that will be different in different places. Soil can regenerate, so we should not look at it as a one-way trajectory of decline; we know ways in which soil can be recovered. The decline in organic matter in soil is a key dimension of that crisis.”
“We urgently need to find a way to address that, because the tsunami of change that is about to hit farming in this country will not be able to withstand that, so we have to find a way of addressing that issue. I do not think that should be used as an excuse for not starting to tackle some of these big crises, such as the soil crisis. It would be useful in the Bill, for example, for the food security provision to talk about things such as soil as part of food security. At the minute, it is very focused on economic factors. If we do not sustain the simple biological and physical nature of farming over this period, we will not have food security. That is one place where it would be useful to put this in the Bill.”
“Q I guess many of us would say that there is a need for urgency, but farmers find themselves caught in the middle, don’t they? There is pressure to change—the Bill is part of that change—but is there not a danger that if we have food imported to lower standards, that will put farmers under even more economic pressure? Gareth Morgan: I absolutely agree with the latter point. We may come on to the issue of trade equality later in the discussion, I imagine. There is simply no point in us exporting our production by forcing up standards here when we are importing products that are produced to low environmental and climate-change standards from other places.”
“A number of groups have put forward potential amendments to the Bill to try to address some of that, and that also needs to be reflected in the trade Bills. Just ignoring it, as is being done at the minute, is not satisfactory for our farmers or our environment.”
“Q What would you like to see put into the Bill, in terms of the imported food standards issue? Gareth Morgan: I do not think anyone has found a simple solution to this, other than a protectionist model, which is what we are trying to get away from. The most interesting example I have heard is talk from Dieter Helm at the Natural Capital Committee about some kind of carbon border adjustment. It would seem ridiculous for us to import products from countries that are not signed up to the Paris treaty and may be subsidising fossil fuels for their farmers in order that they can produce cheaply, and for those products to be on the market in this country, going against products that properly factor in the carbon price. It is not going to be easy to get around, but we cannot duck it.”
“Equally, it is the place where the national food strategy would fit in to say that food is more than just a market transaction for consumers.”
“The reason for putting down a marker on public health was to say that food and farming are not just about a commercial transaction; it is of huge national importance whether people have secure and healthy food supplies and access to the right sort of food and whether the farmer is able to get a just return from the market. Some of those things are touched on in the Bill, but it almost feels like there needs to be something right at the front of the Bill to say what all this is for, as opposed to, “What should we pay farmers for and how?” It feels a bit too fast. That does not necessarily have to come in the Bill, but it has to come somewhere, to our mind. Again, that is where we would say that a presumption in favour of a move to a more agroecological way of thinking about farming probably would sit.”
“We have “Health and Harmony”, which sets out a good, new, broad trajectory for agriculture, and we have quite a technical, nitty-gritty enabling Bill here in terms of saying, “Here are the tools that can be deployed to achieve things.” At the moment there is not anything knitting all that together to say, “What are food and farming for? Do we have any sense of what the right model might be?” I suspect that is perhaps a bit of a legacy from having had the CAP, which was a prescriptive and sometimes flawed model of European farming. We have almost moved away from that to being afraid to say we have any preferences at all. We have a series of tools and a broad aspiration that farming should be good for the environment, and then the market does the rest.”
“Q Two questions: first, in some of your evidence you have suggested that there should be a public health aim within the Bill, and I wondered whether you could tell us a little more about how you think that might work. Secondly— you have touched on this a bit in some of your contribution—who do you think is best-placed and qualified to negotiate and administer the new environmental land management schemes? Are there any potential conflicts of interest in that set-up? Gareth Morgan: Taking the first point, it does feel that there is still a gap in the policy and legislative architecture in agriculture.”
“Q You said a little about the environmental land management schemes, but who is best placed to administer and deliver those? Gareth Morgan: I would tread very warily in that minefield.”
“That will have significant impacts on the agricultural industry itself, but also, more importantly, on the wider issues around rural communities and the environment and habitats that Scottish agriculture underpins with its extensive grazing systems and so on.”
“George Burgess: I suspect you will find a very large measure of agreement at this table. The Scottish Government are very concerned at the prospect that future trade agreements could allow for a dilution of standards. Jonnie Hall: It is also worth adding that the produce of Scotland—commodities is the wrong word—is not about, “Stack it high, sell it low.” We are not going to compete on world markets. We are not a volume producer. We are based on the authenticity and the provenance of our product, and the welfare standards and environmental standards behind that. If we expose Scottish agriculture to cheaper imports of substandard production methods and so on, we will blow large sections of Scottish agriculture out of the water.”
“Q Good afternoon. I think Mr Clarke alluded to this point briefly earlier, but I will ask all of you, as I have asked most of the witnesses: what effect do you think allowing imports of food produced to lower environmental welfare and health standards will have on Scottish consumers and producers and, most of all, on the Scottish environment? Alan Clarke: It would be a disaster for the Scottish red meat industry. The Scots were pioneers of quality assurance. Scotland was the first country in the world to set up whole of life, whole of supply chain quality assurance, and that gives a unique selling point to our world-class products of Scotch beef PGI, Scotch lamb PGI and specially selected pork. For any diluted product to come to market and be able to compete directly—as far as I am concerned, that has no place on the supermarket shelves.”
“Our worry and concern is that a lot of the discussions from outside of the Government appear to be about common frameworks, but we are unsighted on that. We are not seeing what common frameworks might look like. More important to me is the governance of those common frameworks going forward. Like or loathe the European Commission, at least it acted as some sort of referee when it came to compliance with regulation, standards and so on across member states and within the UK. If we are going to preserve the internal UK market, as Alan Clarke has pointed out is so important to Scottish agriculture, we need to ensure that we are all playing to the same rulebook on a whole range of issues. We are unsighted on an awful lot of that. We are still trying to flush out of Governments—plural—the actions and discussions that are going on.”
“Q Paragraph 21 of the written evidence from NFU Scotland touches on the complicated question of the governance of common frameworks. We had the same discussion with representatives from Wales this morning. How do you see a way forward on that? It seems that divergence is inevitable at some point, and yet it needs to be managed. Jonnie Hall: It is quite clear, in many ways, in the sense that the development and delivery of agricultural schemes and policy, in terms of what outcomes we want to achieve from managing our land in an agricultural sense, should absolutely be devolved, and is today. However, when you are looking at the operation of the internal UK market, we need to be able to operate to the same rules in a very transparent and open way across the United Kingdom.”
“Until you get to that level of extensification, you are really removing huge numbers of species and a huge amount of potential carbon storage that would otherwise be there. In this country, we suffer grievously from what I call “agricultural sprawl”—large areas of land used to produce small amounts of food. It gets to the point at which, for instance, sheep farming in the uplands, according to my estimates, occupies roughly 4 million hectares—almost as much land as all our arable and horticultural production put together—yet produces roughly 1% of our food by calories and roughly 2% by protein. That is a remarkably wasteful use of land, which could be much better used for carbon storage through regeneration and rewilding, and for the great resuscitation of ecosystems and the recovery of our very put-upon wild species.”
“Q Good afternoon. Since the Bill was introduced a couple of years ago, the world has moved on in some ways. There is greater awareness of the challenge that we face, and the Government have conceded that there is a climate emergency. Do you think that the Bill is up to the task and, if you started with a blank sheet of paper, what would you do? George Monbiot: One of my aims would be to reduce the area of land used for agriculture. All agriculture is a radical simplification of ecosystems, until you get to the point at which it is so extensive that it is not really agriculture. The Knepp Castle Estate, for example, is a wonderful example of rewilding, but I worked out that if we were to universalise that across much of the UK, we would need to cut our meat consumption by about 99.5%—that is not a great example of agriculture.”
“We have so often fudged the issue, the classic example being the world heritage bid in the Lake district, where they were assumed to be one and the same. It is always resolved in favour of farming, because farming is assumed to be good for ecosystems, but in the great majority of cases it is not—the best thing to do for an ecosystem is to withdraw farming from it. But because we do not acknowledge that there is a conflict, we do not produce a balance that ever favours wildlife.”
“Q I have one additional question that has not come up very much. We talk about public goods and public money, but should there be some public voice in all this, for any decisions about what goes on locally? Where are the people in all this? George Monbiot: That is a very good question. The Bill discusses both natural heritage and cultural heritage. Both are very important values and neither should be dismissed, but there is an assumption in a great deal of rural thinking in Britain that they are one and the same. We have to acknowledge that they are often in direct conflict. Maintaining sheep on the land is highly damaging to ecosystems, but getting rid of sheep farmers can be highly damaging to local cultures and languages. We have to see that a balance should be struck.”
“We are really talking not just about standards now, but the standards we should adopt in the future, both in the UK and in what we would expect other countries to adopt if we are going to import food from them.”
“As I say in the written evidence, we now have this vexed question of viable but non-culturable—VBNC—bacteria. When looking at some of the published data, it is very difficult to take that into account, but the work that we and other labs have done is now telling us that we cannot ignore it. We have published our work on chlorine treatment, but we have also looked at what happens when you stress a pathogen such as listeria by depriving it of nutrients. For example, in a factory where you are washing down with tap water, the listeria can still survive, and in those conditions it can become this VBNC form. If all you are doing is regular swabbing and then reporting, you could say, “Our factory is clear of listeria.” In fact, if we used the more modern methods, that might be found to be not true.”
“For example, in the USA, they report on infections, some of which are assumed from the evidence they have available. If you look at the reporting of the numbers of pathogens in American produce, such as poultry, they report it in terms of the answer to the question, “Does the food contain more than”—for example—“400 counts of a pathogen per gram of food?” In the UK, the Food Standards Agency reports in terms of “low”, “medium” or “high”. National surveys such as sampling from supermarkets, for example, show that 50% of poultry have very low numbers of pathogens such as a salmonella; only about 5% or 6% have food samples with over 1,000 counts of a pathogen. By those criteria, UK foods appear to be safer—but, I must stress, according to those criteria.”