(mis)leading Open Access Myths
(Mis)Leading Open Access Myths
In the evidence presented to the House of Commons Science and Technology
Committee Inquiry into Scientific Publications, many dubious arguments have been
used by traditional publishers to attack the new Open Access publishing model.
Below, BioMed Central responds to some of the most prevalent and most misleading
anti-Open Access arguments.
Page
Myth 1.
The cost of providing Open Access will reduce the availability of funding for
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research
Myth 2.
Access is not a problem – virtually all UK researchers have the access they need
2
Myth 3.
The public can get any article they want from the public library via
3
interlibrary loan
Myth 4.
Patients would be confused if they were to have free access to the
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peer-reviewed medical literature on the web
Myth 5.
It is not fair that industry will benefit from Open Access
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Myth 6.
Open Access threatens scientific integrity due to a conflict of interest resulting
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from charging authors
Myth 7.
Poor countries already have free access to the biomedical literature
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Myth 8.
Traditionally published content is more accessible than Open Access content as
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it is available in printed form
Myth 9.
A high quality journal such as Nature would need to charge authors
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£10,000-£30,000 in order to move to an Open Access model
Myth 10. Publishers need to make huge profits in order to fund innovation
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Myth 11. Publishers need to take copyright to protect the integrity of scientific articles
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www.biomedcentral.com/openaccess
Myth 1.
The cost of providing Open Access will reduce the
availability of funding for research
"There is also the question of the impact on the funding of research by charities, particularly those
without the considerable resources of the Wellcome Trust. The Royal Society, for example, runs number
of funding schemes for scientists. Perhaps the best known is the University Research Fellowships, most of
which are funded by our Parliamentary Grant in Aid (PGA). Our 300 University Research Fellows publish
an average of about four papers per year. Based on an estimate of USD 3,000 fee per article (which we
believe is realistic if the current high standards in publishing are to be maintained) an extra USD3.6M
or £1.96M per year would need to be found to fund our URFs alone. In the absence of an increase to
our PGA we would be forced with the choice of reducing amount of research money funding allocated
to our URFs, reducing in the total number of URFs that we could support or diverting funds from our
other activities to compensate."
Written submission to inquiry, February 2004, Royal Society
Response
It is clear that at an overall macro-economic level, a
Science in their submission to the House of Commons
switch to Open Access publishing would not negatively
inquiry). There is no reason why the cost of Open Access
impact research funding.
publishing should exceed the cost of the current
system, since the fundamental process is the same.
The cost of the present system of biomedical research
In fact, Open Access publishers are leading the way in
publishing, with all its inefficiencies and overly generous
using web technology to reduce costs further, so the cost
profit margins, still only amounts to about 1-2% of
of Open Access publishing to the scientific community
the overall funding for biomedical research (estimate
will be significantly less than the cost of the system that
from the Wellcome Trust, cited by Public Library of it replaces.
Meanwhile, the vastly increased access to research that
is delivered by Open Access will greatly increase the
effectiveness of the research money that is spent, since
all research builds on what has gone before it, and is
needlessly handicapped if access to previous research
is inconvenient, slow, or impossible. In short, funders will
get more "bang for their buck".
At the micro-economic level, there will certainly be
transitions that need to be carefully managed as the
Open Access publishing model grows in economic
significance. e.g. since the total cost of publishing
scientific articles is roughly proportional to the amount
of research to be published, it may well make sense for
the costs of publishing to be incorporated into research
funding grants, rather than being covered by library
budgets. These are important issues, which deserve
attention. But these transitional challenges should not
be allowed to obscure the overall picture which is that
with the Open Access publishing model the scientific
community will pay significantly less, yet receive vastly
more (in terms of access and usability).
www.biomedcentral.com/openaccess
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Myth 2.
Access is not a problem – virtually all UK researchers
have the access they need
"All of us are committed to increasing accessibility of scientific content. I would argue that in the last ten
years we have made a huge contribution to that, and I think 90 per cent worldwide of scientists and 97
per cent in the UK are exceptionally good numbers"
Oral evidence to Inquiry, March 1st 2004, Crispin Davis (CEO, Reed Elsevier)
Response
Elsevier's figure of 97% of researchers in the UK having
Elsevier disguises this by weighting each institution
access to Elsevier content is misleading. As explained in
according to the number of 'researchers' employed, to
the small print of their written submission, this refers to
come up with the 97% figure.
researchers at UK Higher Education institutions only,
many of which have indeed taken out ScienceDirect
More fundamentally, the Higher Education sector is
subscriptions as a part of JISC's "big deal" agreement.
only one of several sectors carrying out biomedical
research in the UK. Much medical research in the UK
However, these researchers do not have access to all
goes on within the NHS. Lack of online access to
ScienceDirect content by any means – the subset of
subscription-only research content within the NHS is a
journals that is accessible varies widely from institution
major problem, as detailed in a separate report.
to institution, meaning that access barriers are frequent-
Similarly, Elsevier's figures conveniently omit
ly a problem, even for researchers.
researchers employed at institutes funded by charities
such as the Wellcome Trust and Cancer Research UK,
The access situation at institutions which focus primarily
and in industry.
on teaching rather than research is particularly bad, but
www.biomedcentral.com/openaccess
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Myth 3.
The public can get any article they want from the
public library via interlibrary loan
"I think the mechanisms are in place for anybody in this room to go into their public library, and for
nothing, through inter-library loan, get access to any article they want"
Oral evidence to inquiry, March 1st 2004, John Jarvis, (Managing Director, Wiley Europe)
"Incidentally, any member of the public can access any of our content by going into a public library and
asking for it. There will be a time gap but they can do that"
Oral evidence to Inquiry, March 1st 2004, Crispin Davis (CEO, Reed Elsevier)
Response
To say that being able to go to the library and request
Practically, the obstacles to obtaining an article via the
an interlibrary loan is a substitute for having Open
interlibrary loan route are so huge that all but the
Access to research articles online is rather like saying
most determined members of the public are put off. For
that carrier pigeon is a substitute for the Internet. Yes –
those who persist, after a time lag that will typically be
both can convey information, but attempting to watch a
several weeks, their article may (if they are lucky) finally
live video stream with data delivered by carrier pigeon
arrive in the form of a photocopy. What the user can do
would be a frustrating business.
with that photocopy is extremely restricted compared to
what they can do with an Open Access article.
• With an online Open Access online article, you can
cut and paste information from the article into an
email. With a photocopy you cannot.
• With an Open Access online article, the license
agreement explicitly allows you to print out as many
copies as you like and distribute them as you see fit.
But if you copy and distribute the article you received
by Interlibrary Loan without seeking appropriate
permission from the publisher, you may well be in
violation of copyright law.
It is also worth noting that an increasing fraction of
public libraries now offer free or low-cost Internet
access, making it even more convenient for the public to
view Open Access research.
www.biomedcentral.com/openaccess
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Myth 4.
Patients would be confused if they were to have free
access to the peer-reviewed medical literature on the web
"Without being pejorative or elitist, I think that is an issue that we should think about very, very careful-
ly, because there are very few members of the public, and very few people in this room, who would want
to read some of this scientific information, and in fact draw wrong conclusions from it […] Speak to peo-
ple in the medical profession, and they will say the last thing they want are people who may have illness-
es reading this information, marching into surgeries and asking things. We need to be careful with this
very, very high-level information."
Oral evidence to inquiry, March 1st 2004, John Jarvis (Managing Director, Wiley Europe)
Response
This position is extremely elitist. It also defies logic.
There is already a vast amount of material on medical
topics available on the Internet, much of which is junk.
Can it really be beneficial for society as a whole that
patients should have access to all the dubious medical
information on the web, but should be denied access to
the scientifically sound, peer-reviewed research articles?
In some cases, to be sure, comprehending a medical
research study can be a demanding task, requiring
additional background reading. But patients suffering
from diseases are understandably motivated to put in
the effort to learn more about their conditions, as the
success of patient advocacy groups in the USA has
shown. Patients absolutely should have the right to
see the results of the medical research that their taxes
have paid for.
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Myth 5.
It is not fair that industry will benefit
from Open Access
"[T]he major industry readers of information, like the pharmaceutical industry, would be in a much bet-
ter position [with the Open Access model] since they do not produce very much in terms of new research
articles. Of course, they purchase a lot for their industry. So companies that do not produce very much
material but read a lot - I will not mention [companies], but this would be wonderful news for them. It
would be wonderful news for the chemical industry and for the pharmaceutical industry, and bad news
for major research institutes like Oxford and Cambridge, Harvard and Yale, and for countries like Britain"
Oral evidence to inquiry, March 1st 2004, John Jarvis (Managing Director, Wiley Europe)
Response
It is peculiar to hear large commercial publishers
of publishing the research that incurs the lion's share of
saying that Open Access would be a very good thing for
the costs (with Internet distribution being very cheap in
the pharmaceutical and other industries, and then
comparison), this is the most logical, sustainable way to
claiming that this is a problem with the Open Access
fund the publication process. In contrast, the current sit-
model. The chemical, biotech and pharmaceutical
uation, in which small universities effectively subsidize
industries play a major role in the UK economy, and so
the cost of publishing the research carried out at rela-
this argues strongly for Open Access.
tively wealthy research centres, is far more inequitable
and unsustainable.
To say that they do not contribute significantly in terms
of publishing research is inaccurate. Industry publishes a
But in any case, the absolute amount of money
significant amount of research itself, and also funds
expended by the research institutions will fall, due to
much research within the academic community that
the far greater efficiency of Open Access publishing.
then goes on to be published.
Furthermore, research institutions that support Open
Access will benefit greatly in terms of kudos and influ-
It is certainly possible that under an Open Access model,
ence, due to the greater accessibility and visibility of
institutions (and countries) that publish a lot of research
their research. These institutions would therefore be
would pay a somewhat higher proportion of the cost of
cutting off their nose to spite their face to oppose Open
publishing than they do currently. Since it is the process
Access on the grounds given above.
www.biomedcentral.com/openaccess
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Myth 6.
Open Access threatens scientific integrity due to a
conflict of interest resulting from charging authors
"The second question that increasingly is being asked is the inherent or potential conflict of interest if a
publisher is receiving money from the author to publish that article. There is an inherent conflict there
in terms of quality, objectivity, refereeing and so on. One of the real strengths of today's model is that
there is no conflict there. We reject well over 50 per cent of all articles submitted. Other journals do that
or even higher. If you are receiving potential payment for every article submitted there is an inherent
conflict of interest that could threaten the quality of the peer review system and so on"
Oral evidence to Inquiry, March 1st 2004, Crispin Davis (CEO, Reed Elsevier)
Response
This canard has been thoroughly debunked elsewhere.
i.e. Elsevier's primary justification for increasing their
The assertion being made is, essentially, that Open
subscription charges (and profits) is that each year they
Access publishers have an incentive to publish dubious
are publishing more articles. In which case, if their own
material, in order to increase their revenue from Article
argument is to be believed, they face the exactly the
Processing Charges. This is a very peculiar accusation for
same conflict of interest as Open Access publishers.
a traditional publisher to make given that in the same
Fortunately, however, no such conflict of interest exists,
evidence session, Elsevier’s hefty annual subscription
for either Open Access or traditional publishers. Any sci-
price increases was justified as follows:
entific journal's success depends on authors choosing to
"On pricing, we have put our prices up over the last
submit their research to it for publication. Authors pub-
five years by between 6.2 per cent and 7.5 per cent a
lish research in order for the value of their findings to be
year, so between six and seven and a half per cent
recognized. The kudos granted by a solid publication
has been the average price increase. During that
record is crucial for scientific career progression. Authors
period the number of new research articles we have
submit their research to journals with a reputation for
published each year has increased by an average of
publishing good science. If a journal had a reputation
three to five per cent a year. […] Against those kinds
for publishing poor science, it would not receive submis-
of increases we think that the price rises of six to
sions. Thus the system is inherently self-correcting.
seven and a half per cent are justified."
It should also be noted that many leading journals (both
Oral evidence to Inquiry, March 1st 2004,
commercial and not-for-profit) already have page
Crispin Davis (CEO, Reed Elsevier)
charges and colour figure charges for authors, in order
to defray expenses and to keep subscription costs
down. Just two examples (of many hundreds) are the
Proceedings of the National Academy of Sciences (USA),
and Genes & Development. So author charges are
hardly an unprecedented experiment.
It is true that commercial publishers have tended in
some cases to remove author charges, and to commen-
surately increase subscription fees, since this suits their
commercial interests in maximizing profits. But it is clear
that author charges pose no fundamental problem to
effective peer review.
www.biomedcentral.com/openaccess
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Myth 7.
Poor countries already have free access to the
biomedical literature
"“…what has happened is that the publishing industry has effectively, with the support of the societies
it publishes for, given free access to poorer countries. There are various schemes, which you will see in
the submissions - HINARI, AGORA for example, which deliver journals without charge to poorer countries;
and that scheme is being enhanced and is lifting up to another level of slightly better-off countries"
Oral evidence to Inquiry, March 1st 2004, Bob Campbell (President, Blackwell Publishing)
Response
HINARI, and its sister initiative, AGORA, are commend-
able initiatives and are undoubtedly warmly welcomed
by researchers working in the eligible countries.
Via these schemes, publishers give some of the
poorest countries free access to some of their journals.
In HINARI, twenty-eight publishers participate, making
a total of more than 2000 journals available for free
to some of the poorest countries (defined as having a
per capita annual income of less than $1000); and at
a deep discount for some slightly less disadvantaged
countries (per capita annual income between $1000
and $3000).
Unfortunately these schemes offer only a partial
solution to the access problems of the developing
world. The list of eligible countries has many notable
omissions. It excludes large low-income countries such
as India, Pakistan and Indonesia, even though these
countries have per capita annual incomes of $735 or
less, and are therefore "low-income" countries accord-
ing to World Bank criteria. Countries such as Brazil and
China (which are "lower-middle income" according to
the World Bank) are also excluded from the eligibility
list, even for discounts.
There is an obvious explanation for these omissions.
These larger countries have significant research pro-
grams, so publishers can generate substantial income
by selling subscriptions to them. It appears that
traditional publishers will only offer Open Access to
the developing world when they can be sure it won't
affect their profits.
It is therefore clear that researchers in developing
countries have a huge amount to gain from greatly
expanded access to the global scientific literature that
Open Access publishing will offer.
Certainly, there are challenges that need to be faced
to ensure that authors in developing countries can pub-
lish in Open Access journals, but these challenges are by
no means insurmountable. Indeed, many low-income
countries have already started their own Open Access
journals. Meanwhile, BioMed Central currently offers a
full waiver of the article processing charge to authors
in low and low-middle income countries. Long term,
the scientific community will certainly find ways to
ensure that scientists in developing countries get the full
benefit of Open Access, both as readers and as authors.
www.biomedcentral.com/openaccess
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Myth 8.
Traditionally published content is more accessible than
Open Access content as it is available in printed form
"We make [our articles] available both in print and on line. In fact, open access would today have the
result of reducing accessibility to scientific research because it is only available on the Internet. In this
country that would exclude some 20-25 per cent of scientists; globally it would exclude over 50 per cent
of scientists. In actual fact, the business model we have today gives the widest possible access."
Oral evidence to Inquiry, March 1st 2004, Crispin Davis (CEO, Reed Elsevier)
"Print is used by many scientists around the world and by global citizens who are the beneficiaries of sci-
entific and medical research. To rely on the Internet alone for distribution, as most Open Access journals
do, risks reducing levels of access among these beneficiaries. 11% of the world’s population uses the
Internet and only 64% of UK citizens have ever been online"
Written submission to Inquiry, February 2004, Elsevier
Response
This claim should perhaps win a prize for audacity. To be
clear: it is not just slightly wrong; it is preposterously
wrong.
Firstly, sending out printed copies of journals to
subscribers who pay for them is in no way in conflict
with the goals of Open Access. Many Open Access
journals (such as PLoS Biology, Journal of Biology and
Genome Biology) have print editions. Wherever there is
a demand for print (from libraries or from individuals)
then print editions are available to those who wish to
pay to receive them, just as with a traditional journal.
But, far more importantly, by Elsevier's own estimate
some 30 million people in the UK (and more than
half a billion people worldwide) use the Internet.
The wonderful thing about Open Access is that any
one of those hundreds of millions of people can print
out copies of any Open Access article, and distribute
them to whomever they want. If you want to get hold
of an Open Access article, there are literally hundreds
of millions potential sources.
We already see the power of this mechanism in action.
In the poorest countries in Africa, those scientists who
are lucky enough to have access to the Internet are
downloading Open Access articles from BioMed
Central's journals (e.g. Malaria Journal), printing them
out in large numbers, and distributing them to their
colleagues in areas the Internet does not yet reach.
They confirm to us that this makes the research vastly
more accessible than research published in traditional
print-only journals.
In contrast, many traditional journals are received in
print by only a few hundred libraries worldwide.
Not only that, the libraries that hold these print copies
are bound by strict rules governing what is and is not
permissible in terms of copying and redistribution.
To argue that these few hundred printed copies provide
greater access to research than making articles openly
accessible online is, frankly, ludicrous.
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Myth 9. A high quality journal such as Nature would need to charge
authors £10,000-£30,000 in order to move to an Open Access model
"Under an author pays model, we estimate the actual cost per paper published would be in the region
of £10-£30,000 depending on the impact of lost advertising"
Letter to Inquiry, January 13th 2004, Richard Charkin (CEO, Macmillan)
"There are many answers because there are many journals for many disciplines, and the impact will be
different depending upon which discipline or which journal you are talking about. In our letter to you,
speaking on behalf of Nature Publishing Group, in the case of Nature itself, the British international jour-
nal, in order to replace our revenues you would have to charge the author somewhere between £10,000
and £30,000 because the costs of editorial design and support are so high. The reason for the big dispar-
ity is how much advertising"
Oral evidence to Inquiry, March 1st 2004, Richard Charkin (CEO, Macmillan)
Response
But even for Nature, the figure of £10,000-£30,000 is
wildly off the mark. The calculation used by Macmillan
Although subsequent media reports failed to mention it,
was as follows:
the quotes above make clear that this figure is only
claimed to apply to Nature – an extremely special case
"Very crudely, £30 million of sales: we get income of
among the tens of thousands of life science journals.
£30 million and we publish 1,000 papers a year. That is
Elsevier's evidence confirmed that, even with the
your [£30,000]."
inefficiencies of publishers' current systems, the cost
Oral evidence to Inquiry, March 1st 2004,
per article for a typical journal is far lower:
Richard Charkin (CEO, Macmillan)
"The cost to publish an article […] ranges from
£30,000 is indeed a lot of money. But Nature clearly
between $3,000 to $10,000 per article […] I would
spends nothing like that on each research article that it
agree with those numbers."
publishes.
Oral evidence to Inquiry, March 1st 2004,
There are several major problems with the calculation
Crispin Davis (CEO, Reed Elsevier)
that was used:
"For Blackwell? […] it worked out at £1,250 per article.
1. A significant fraction of Nature's £30m revenue is
That was the cost of the total system."
spent to commission and produce the non-research-
Oral evidence to Inquiry, March 1st 2004,
article content of the journal (e.g. News & Views
Robert Campbell (President, Blackwell Publishing)
articles, book reviews, commentaries, editorials etc.)
This non-research content would continue to drive
healthy print and online subscription revenue,
even if the research articles were made freely
accessible online. Since the non-research content
(the front-matter) is far more widely read than the
research articles themselves, it is far from clear
whether making the research articles Open Access
would have any negative impact on subscription
revenue. In fact, the opposite can be argued.
2. For the same reason, there is no reason to believe
that Nature's impressive advertising revenue would
suffer dramatically as a result of Open Access,
yet they are assumed to fall to zero in Nature's
calculation.
3. Part of the argument used to justify the high cost
per published article is that Nature rejects more
than 90% of papers submitted, and so has to review
more than 10 papers for every one it publishes, and
has to bear the entire cost of this. Continued ¡
www.biomedcentral.com/openaccess
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"[Nature] publishes fewer than 10% of the research
articles submitted. Economics dictates that high quality
journals like Nature have a high unit cost per paper
published, because for every article published more
than ten have been reviewed and de-selected."
Letter to Inquiry, January 13th 2004,
Richard Charkin (CEO, Macmillan)
This would indeed be expensive, and it is true that
the repeated peer-reviewing of rejected papers as
they trickle down the journal pyramid is one of the
worst inefficiencies of the present system. In fact,
however, Nature is not that profligate and had
already taken steps to address this issue:
"If a paper cannot be accepted by Nature, the authors
are welcome to resubmit to Nature Cell Biology.
Nature will then release referees' comments to the
editors of Nature Cell Biology with the permission of
the authors, allowing a rapid editorial decision.
In cases where the work was felt to be of high
quality, papers can sometimes be accepted without
further review"
From the Nature website
Thus, if a paper is scientifically sound, but is
not exceptional or fashionable enough to appear in
Nature, it may well be submitted and accepted
into one of the next tier of journals in the Nature
stable (Nature Cell Biology, Nature Medicine,
Nature Genetics etc.) without requiring significant
additional editorial work or costs. This is a very
sensible system, and is one that is already in use at
BioMed Central. If an article is rejected for
publication in BioMed Central's top-tier journal,
Journal of Biology, but is judged by the reviewers
and editors to be scientifically sound, the authors
may be offered publication in one of our more
specialist journals. Public Library of Science plans
to operate a similar mechanism as it launches new
journals.
This trickle-down approach benefits authors by
avoiding the delays caused by repeated rounds of
peer-review, and benefits science as a whole by
reducing the cost of the publication process while
maintaining quality.
Taken together, the above factors make it clear that
the actual figure that would be necessary as an author
charge for Nature would most likely be vastly lower
than the suggested figure of £10,000-£30,000. It is even
possible that Nature could operate at a profit while
offering Open Access to research content and making
no author charge whatsoever.
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Myth 10. Publishers need to make huge profits in order
to fund innovation
"In the last seven years we have led the industry and the scientific publishing world to on-line. I think
most people would agree we have pioneered it through ScienceDirect and through the electronic plat-
form. That would not have happened if we did not have the scale to invest what turned out to be in
excess of £200 million to develop the Science Direct on-line platform"
Oral evidence to Inquiry, March 1st 2004, Crispin Davis (CEO, Reed Elsevier)
Response
Elsevier cannot realistically claim to have led the
service, and it will be instantly accessible by all Internet
transition of scientific publishers from print to online –
users world-wide. The result has been an unparalleled
that was done by smaller, more nimble operators
wealth of innovation, which goes far beyond what
such as HighWire Press (which launched the Journal of
proprietary online services had previously achieved.
Biological Chemistry in 1995) and BioMedNet (which
made the Current Opinion series of journals available
Open Access to the scientific literature holds the prom-
online in full text form back in 1994). Of the large
ise of the same benefits for science. Once the majority of
commercial publishers, Academic Press started IDEAL
the scientific literature is Open Access, in the full sense
in 1995, years before ScienceDirect. Similarly, Elsevier's
of being openly re-distributable and re-usable, the
figure of £200 million for the development costs of
entire scientific community will be free to develop
ScienceDirect is more an indication of corporate
and improve techniques to mine and explore that
inefficiency than of innovation.
literature. They will not be constrained by any one
corporate budget or policy, nor by the barriers inherent
Huge investment by a large corporation is not the best
in the current fragmentation of the literature. At this
driver of innovation, especially in the modern connected
point in time we can only imagine what is possible,
world. The explosion of the Internet has shown that
but it is certain that it will dwarf what any one
open platforms are the real spur for innovation.
company might achieve.
The open standards of the Internet mean that anyone
can create a website and offer any imaginable online
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Myth 11. Publishers need to take copyright to protect the
integrity of scientific articles
"If your author's work is then stolen or changed, what publishers can do because of their scale and their
reach is to do something about that. Individual authors would find it very difficult if their article was used
and changed"
Oral evidence to Inquiry, March 1st 2004, John Jarvis (Managing Director, Wiley Europe)
Response
Scientific integrity is protected not by copyright law, but
by the norms, standards and processes of the scientific
community. An article is only "stolen" from an author if
it is mis-attributed. This is fraud, and laws other than
copyright deal with fraud.
It is exceptionally rare for a scientific publisher to use
copyright law to defend the integrity of a scientific
paper on behalf of an author. In fact BioMed Central
knows of no situation where this has happened.
The "scientific integrity" argument simply provides a
convenient excuse, which is used by traditional publish-
ers to attempt to justify their requirement for transfer of
copyright.
Meanwhile, the real reason for copyright transfer is
clear. Publishers regularly use copyright law to protect
the profits they derive by controlling access to the liter-
ature. For example, in ongoing litigation, Elsevier and
Wiley are suing various US photocopying firms for,
amongst other things, including copies of research arti-
cles in student course-packs without paying royalties to
the publisher:
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Sources
• Blackwell Publishing written submission to House of Commons committee (not available online)
• Elsevier written submission to House of Commons committee
• Macmillan letter of evidence sent to House of Commons committee (not available online)
• Royal Society written submission to House of Commons committee
• Quotes from oral testimony are taken from the uncorrected transcript of the House of Commons committee
session that took place on March 1st 2004
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