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(June/July)
* * * * * * * * * |
"GENES, BEANS AND GREENS: A TASTE OF THE GENETICALLY MODIFIED FOODS DEBATE, PART I" (June-July 2004 Essay) *This initial piece for summer 2004 was an attempt at something new: an interactive essay. Although it can be read as is, links are embedded at various points in the article. By clicking the link you can read more about the particular topic being discussed, then return to the essay. (The links are included for informations purposes only. No guarantees are made as to the accuracy of the materials presented on the sites, although every effort has been made to search out reliable and respected sources of information.) Please note: some links have changed since 2004 or are no longer in existence. Where it is possible, they have be updated to reflect the changes. Changes which have been made are not included in the body of the text but are noted in the "Links List" at the bottom of the page. Footnotes and a bibliography are also included at the end for anyone wishing to learn more about the subject. The materials represented here are only a small fraction of what is available on this very complicated issue. The glossary link below has been provided as a reference for use as needed. Click here to reach the glossary. Frankenfoods. It's a word designed to strike fear in the hearts (or stomachs!) of consumers about the foods they eat. It may conjure up images of scientists tinkering away in labs, busy creating plants or organisms like none anyone has ever known. It's also a word which has been used to describe and categorize the products of genetic engineering, or plants of modern agricultural biotechnology. It is not a word, however, which does anything to explain the subject or shed light on the debate concerning genetically modified (GM) food. Consider the following: last year about 80% of the soybeans and 40% of the corn grown in the U.S. were grown from GM, or transgenic, seeds.(n1) Perhaps you're thinking, "Well, I don't eat tofu or drink soymilk, and I don't eat that much corn, so what does this have to do with me?" A quick trip down the grocery store aisles can answer that question easily. Pick up a bottle of salad dressing, a jar of pasta sauce, or many varieties of packaged desserts and crackers. What are some of the ingredients on the label? Soybean oil or soy flour. Some of your favorite sports/energy bars or cereals? Soy protein. Soft drinks and some juices? Corn syrup. By some estimates as much as "70% of the human food products in the marketplace"(n2) today contain some ingredients made from transgenic crops. [To view a diagram of the edible uses of soybeans, click here.] From the first wide-scale planting of GM crops in 1996(n3), their cultivation has skyrocketed. By 2002, 145 million acres of GM soybeans, corn, canola and cotton were grown in 16 countries,(n4) by far the greatest percentage in the United States. As the products of agricultural biotechnology have surged, so has the debate concerning their safety, regulation, risks and benefits, alternatives and future uses. So just what is it that everybody's talking about? The Genes: A Primer on Modern Agricultural Biotechnology Now take a walk over to the produce section of the grocery store. In recent years the bins have been filled with new, interesting items such as golden kiwi, broccoflower (a cross between cauliflower and broccoli), and pluots, plumcots and apriums (crosses between plums and apricots). These, however, are not products of modern genetic engineering. They are the outcome of the same type of conventional plant breeding that has been taking place for hundreds or thousands of years and has produced much of the food eaten today. Pick up an ear of corn, though. Look at it, touch it, smell it. If it was grown from genetically modified seeds, you would have no way of knowing, for there is no difference in outward appearance between the current types of GM corn and its non-GM counterparts. The corn, soybeans, cotton and canola mentioned earlier are all products of a much different process. That process involves altering the microscopic building blocks of a plant's genes. What are genes? A textbook definition of a gene is that it "is a section of a threadlike molecule called deoxyribonucleic acid, or DNA. DNA, the hereditary material that passes from one generation to the next, dictates the inherent properties of a species. Each cell in an organism has one or two sets of the basic DNA complement, called a genome. The genome itself is made up of one or more extremely long molecules of DNA that are called chromosomes."(n5). [If you would like to learn more about DNA and genes, click here.] If you took that ear of corn to a geneticist, he or she could determine whether or not it was genetically modified much in the same way a doctor might handle a paternity test, or the police might analyze DNA evidence from a crime scene. These soy, corn and other crops being discussed are all the products of what is called modern agricultural biotechnology. In general, the term "biotechnology" refers to "any technique that uses living organisms or substances from those organisms to make or modify a product for a practical purpose."(n6). This broad definition can also include processes like fermentation or pasteurization. Modern agricultural biotechnology, the products of which are the subject of debate, has a more specific definition. The process "includes a range of tools that scientists employ to understand and manipulate the genetic make-up of organisms for use in the production or processing of agricultural products"(n7), many of which end up in the food on grocery store shelves. [To go to a basic introduction to biotechnology, available in both English and Spanish, click here.] The soybeans and corn discussed so far are called transgenic because scientists created them by taking genetic material from one species, such as bacteria, and inserting the material into the genome of another species, such as soy. One aspect of the debate centers around objections to the technology itself based on moral, religious, or evolutionary grounds. Some feel it is "an area [which] should be left to nature rather than man,"(n8) since it entails "crossing lines that divide living organisms, which involves making irreversible permanent changes for future generations."(n9) The Pew Initiave on Food and Biotechnology has held a panel discussion on the subject which they called "Playing God or Doing God's Work?" To learn more about the outcomes of that discussion, click here. Also, to view a longer, more detailed report on the social and ethical issues surrounding biotech crops, click here. To return to the top of the page, click here.
"Bangkok, Thailand" © 1985 Dorothy A. Birsic The Beans: Products of Modern Agricultural Biotechnology In order to understand the rationale behind some of the earliest (i.e. first generation or first wave) transgenic crops, it is first necessary to understand a bit about modern commercial farming, generally referred to as agribusiness. Today's agribusiness is heavily dependent on chemical fertilizers, pesticides and herbicides for achieving high yields from the crops that are sown. In some cases, since 1945, it has taken a "ten-fold increase in pesticide use to achieve the higher output."(n10). In addition, "a crop's susceptibility to attack by pathogens and animal pests increases with yield."(n11). Many of the companies which supply farmers with the chemicals used to treat their crops are also ones developing genetically modified seeds for farmers to plant in their fields. In part due to the working of modern agribusiness, by 2000 approximately three quarters of all genetically modified crop traits which had been tested in developed countries were designed to make plants (soybeans, corn, cotton, etc.) either resistant to insects, tolerant of herbicides, or both (referred to as "stacked" traits).(n12) How exactly is this done? If you don't mind a little bit of
scientific detail, it's fairly easily explained. Take insect-resistant
crops to begin with. Although the seeds for the crops have trademarked
names based on the company that developed them, they are generally
referred to as Bt soy, Bt corn and Bt cotton. This is because a gene from
the soil bacterium Bacillus thuringensis has been inserted into the
plant genome. "The bacteria, [once a part of the growing plant], produces
a protein that is toxic to certain Lepidopteran insects (ones that go
through a caterpillar stage)," especially one called a corn borer.(n13) It is toxic
because it "creates a protein that bonds to specific receptors in the
midgut of sensitive insects but does not affect mammals or insects that
lack those receptors, [and] is harmless to humans, fish, wildlife and
beneficial insects."(n14) "It is a
novel approach to controlling insects because it is produced throughout
the plant for its entire life. Therefore, the insecticide is more
effective than conventional and biological insecticides because it cannot
be washed off by rain or broken down by other factors."(n15)
Herbicide tolerant crops also have trademarked names which
most often reflect the identity of the company that developed the seeds.
Two examples of this are Roundup Ready® Soybeans (Monsanto) and LibertyLink® Corn (BayerCropScience). These
types of plants are the most widely-adopted transgenic crops and "were
developed to survive the application of specific herbicides that
previously would have destroyed the crop along with the targeted weeds."(n16) Roundup is
a common herbicide found even in local home improvement stores. The active
ingredient in Roundup is glyphosate, and it kills plants "by interfering
with the function of an enzyme called EPSP synthase."(n17) Roundup
Ready® plants are made to tolerate the herbicide; humans do not possess
the EPSP synthase enzyme so they cannot be harmed by it."(n18) [To view a
list of transgenic products on the market now and within the next six
years, click
here.] This first wave or first generation of transgenic crops has
primarily benefitted farmers, and they are some of the biggest proponents
of the technologies. To understand a bit more about their perspective, click here. The benefits of the
second and third generation, or next waves of biotech crops, should be
more visible to consumers,(n19) but also
potentially more contentious and controversial. They include things such
as "improved" fruits and vegetables, and "edible vaccines" grown in crops
such as bananas and potatoes.(n20) These will
be discussed at greater length in next month's essay. It is important to
note here that although transgenic crops may provide benefits, there are
also potential environmental and human health risks associated with their
cultivation. The ultimate custodian of the public safety when it comes to
monitoring and regulating their approval and use is the federal
government. The discussion will turn briefly to a look at the risks
associated with GM food products and the government controls that allow
them to eventually become part of the nation's food supply. Regulation
and Risk The material covered up to now is undoubtedly a lot of
information to digest (no pun intended). Perhaps you're thinking to
yourself that you want to go out to the kitchen and get something to eat
or drink before continuing. Please do. While you're on your way, take a
look at some of the labels on the food items in your pantry or
refrigerator. Unless you've purchased something from a company that
voluntarily notes whether or not their products contain GMOs, you have no
way of knowing if anything you're eating has come from a transgenic crop.
Compare this to a law which took effect throughout the European Union (EU)
in April of this year. The EU law states that "Any food or feed
containing, consisting of or produced from genetically modified organisms
(GMOs) will need to be labelled in a way that indicates it contains GMOs.
For GMOs that are currently approved in the EU, . . . levels of up to 0.9%
will be permitted without the need for labelling. GMOs that have received
neither EU approval nor a favorable risk evaluation will be forbidden. The
labelling requirements do not apply to food products for which the
manufacturing process commenced before April 18, 2004."(n21) Voluntary labelling in the U.S. versus mandatory labelling
in the E.U.? Why the difference? Differences across the Atlantic may be
due to many factors, but partly to matters of philosophy (when it comes to
assessing risk) and practice (when it comes to labelling). The
philosophical framework behind much of the decision-making in the U.S. on
GM products is a doctrine called "substantial equivalence." The principle
was originally developed by international organizations such as the World
Health Organization (WHO), the Food and Agriculture Organization of the
United Nations (FAO) and the OECD. "The underlying concept is the
requirement that any safety assessment should show that a genetically
modified variety [of plant, in this case] is as safe as its traditional
counterparts [substantially equivalent] through a consideration of a wide
range of both intended and unintended effects. This involves consideration
of a wide range of information including agronomic properties, phenotypic
changes, and . . . data on critical nutrients and toxicants."(n22) The more prevalent doctrine in Europe is known as the
"precautionary principle." Although there are several definitions of the
term, it is essence is a belief [that] there is an obligation to be
certain that our actions (or . . . chemicals, food ingredients or
technologies) do not cause harm or potential harm to people."(n23) The
differences between the two play out in the assessment of risk and
uncertainty over the effects of a new substance or technology. "The
utilitarian/science model as used in the U.S. would have it that if the
probability of harm is judged to be low and it the genetically modified
foodstuffs are of some social benefit, then the introduction or use of
those substances is 'safe.' A strict application of the precautionary
approach says that if there remains any uncertainty or the extremely
remote possibility of a disaster, prudence and ethics demand the
substance/technology in question not be permitted."(n24) Application
of the principle in the EU, especially as it applies to food labelling,
may reflect the notion that people should be allowed to " exercise their
autonomy to be able to choose not to consume or be exposed to possibly
risky substances."(n25) Photograph © 2011 Dorothy A. Birsic As a contrast to this, in "North America, regulators and
companies agree that mandatory labels should be reserved for those
products carrying a documented health risk or substantial change in
nutritional composition. If the GM products are 'substantially equivalent'
to conventional counterparts, companies argue, the GM label would be
'misleading,'"(n26) since they
have already been determined to be 'safe.' So who makes the decisions in the United States when it
comes to these products? In the U.S., three agencies share responsibility
for regulating the products of modern agricultural biotechnology.
The
Animal and Plant Health Inspection Service (APHIS) of the USDA
regulates the field testing and commercial sale of agricultural
bioengineered plants.(n27) The
Environmental Protection Agency (EPA) is responsible for regulating
pesticides, including what they call the "plant incorporated
protectants", or insecticidal properties, of transgenic plants.(n28) The Food
and Drug Administration (FDA) regulates the safety of foods and the
safety and efficacy of pharmaceuticals and animal feeds, as well as
elements of labelling.(n29) The three agencies together
maintain the U.S. Regulatory Agencies Unified Biotechnology Website. Click here to visit the site and
learn more about the regulatory process for GMOs in the United States.
Also, to view a searchable database of legislation concerning all aspects
of GMOs which have been introduced in the state and federal legislatures,
click
here. Throughout history, new technologies have brought with
them risks and benefits, intended and unintended consequences. The debate
on GM plants cannot be fully understood without looking at some of the
specific risks associated with modern agricultural biotechnology, risks
both to the environment and to human health. These risks include:
Gene flow
(pollen from GM plants finding its way into native plants producing new
plants with adverse or unintended effects) Emergence of
new forms of resistance and secondary pest or weed problems Recombination of the viruses or bacteria [from the GM plants]
to produce new pathogens Direct and
indirect effects of new [plant-based] toxins Changes in
farm practices leading to changes in biodiversity.(n30) These five risks are classified
as risks to the environment. The two primary risks to human health which
have been identified to date are: 1) the new substances in transgenic
crops might cause allergenic or immune system reactions, and 2) antibiotic
resistance that might be transferred to humans from organisms used in
developing the GM crops (antibiotic resistance marker genes).(n31) It is
important to note here that no adverse effects on human health (from
genetically modified foods) have been reported.(n32) However, it
has also been suggested that "there could, in theory, be long-term effects
on human health that have not yet been detected because GM foods have been
available for less than ten years."(n33) [To view
these issues in greater detail, you can click here to link
to a 2002 report entitled Benefits and Risks of Food Biotechnology.
The report also contains extensive information about transgenic plants in
California.] The
issues of risks versus benefits, and how those risks versus benefits
should be handled in the interest of mankind, are significant portions of
the overall debate on GM food and modern biotechnology in general. As much
as been said about proponents of the technologies such as some farmers,
industry organizations, scientists, agribusiness companies and others,
there are also very vocal opponents to GM foods. To return to the top of the
page, click
here. The Greens:
Organics and Environmentalists Few consumers may realize that there is a family of
products which by definition and by law must be free of GMOs. These are
organic products. Although some major grocery stores have begun devoting
small portions of their produce sections to organics, for many the term
still conjures up images of the social and political movements of the
1960s and 1970s. Sales of organic products, however, have been increasing
at about 20% per year, from about $1 billion in 1993 to about $13 billion
in 2003.(n34) What exactly is organic farming? The organic farming
philosophy centers "on practices designed to improve the richness and
stability of the soil by restoring its organic matter and avoiding
synthetic fertilizers, pesticides and herbicides."(n35) A goal of
this type of agricultural practice is "to optimize the health and
productivity of interdependent communities of soil life, plants, animals
and people."(n36) [Click
here to read more about organic farming and organic
products.] Congress passed the Organic Foods Production Act (OFPA)
back in 1990. Its objective was to ensure consumers that foods labelled
"organic" met a defined set of production criteria,(n37) which now
has come to specifically exclude GM products. (These are deemed to be
incompatible with the practices of organic farming.) The Act established
the National Organic Program (NOP) within the USDA, and NOP regulations
require that all food labelled as organic originate from farms or handling
operations certified by a state or private entity that has been accredited
by the USDA. [For further information on the NOP and organic standards, click here.] The
pictures below depict two of the types of labels which can be found on
organic products. The one on the left is the official seal of the USDA.
This seal may only appear on foods which consist of at least 95%
organically produced ingredients. The words "organic" or "100% organic"
may also appear on the labels of such items. Processed foods containing at
least 70% organic ingredients may use the phrase "made with organic
ingredients," but not the seal. All other products may not use word
"organic" on the main display portion of the label. The label on the right (image courtesy of QAI) is from one
of the certification agencies accredited by the USDA. Organizations such
as this one, Quality Assurance International (QAI), verify that growers,
processors and handlers of organic products meet all applicable standards,
statues and regulations.(n38) Both of the
seals may appear on products marked "organic" or "100% organic." Anyone
intentionally violating the label laws may be fined up to $10,000;
operators whose gross agricultural income from organic sales is less than
$5,000 is exempt from them. The full text of laws governing growers can be
found in the Code of Federal Regulations, 7 CFR Subchapter M, Part
205. In general, organic farming is part of the much broader
organic movement. The organic movement also "encompasses such tenets as
animal welfare, energy efficiency, social justice and the simple agrarian
ideals of small farms growing produce for local communities."(n39) As such,
the movement finds close kin in many environmental organizations. Some of
the largest of these organizations have taken the most prominent and
visible stands against transgenic products. To read some of their
positions on the debate, click on the links below. Where possible, direct
links have been made to the pages stating positions on agricultural
biotechnology and/or GM foods. The Campaign (to label GM foods) How can the debate and all these issues play out? This year a California county, Mendocino County, became the first in the nation to pass a local ballot measure concerning genetically modified organisms. The measure specifically prohibits the cultivation of GM crops within the county. To view the text of that measure, click here.
Photograph "Nepalese Rice Paddies" © 1985 Dorothy A. Birsic Conclusion and a Look Ahead to Part 2 "Plants are remarkable in their capacity to synthesize a variety of organic substances, such as vitamins, sugars, starches and amino acids. As many as 80,000 different substances are synthesized in plants, including macronutrients and micronutrients significant to human health."(n40) In Part 1, much of the "mechanics" of the debate on modern agricultural biotechnology have been discussed. Part 2, coming next month, will look at what modern agricultural biotechnology might look like in the future. Vitamin-enhanced rice and plant-based medicines (nutraceuticals) are just two of the products in the GM pipeline of tomorrow. Also, no discussion of the GM food debate would be complete without looking at the hopes for transgenic crops as a solution to hunger in the third world. The "debate" will continue next month. . . Hope you'll be back! A special thanks to Norman E. Ellstrand, Professor of Genetics and Director of the Biotechnology Impact Center, Alan McHughen, Biotechnology Specialist and Plant Geneticist, and Carl Cranor, Professor of Philosophy, all of the University of California Riverside, for their insight and input during the writing of this essay. To return to the top of the page, click here. FOOTNOTES - The following are the footnotes indicated in the text in parentheses with the letter "n" and a number. If you click the asterisk at the end of the footnote, it will take you back to the paragraph where you left off. n1 - United States Department of Agriculture (USDA), National Agricultural Statistics Service (NASS), Acreage Report, Washington D.C., June 2003, pp. 24-25(*) n2 - California Council on Science and Technology, Benefits and Risks of Food Biotechnology, Sacramento, 2002, p. 5 (*) n3 - USDA, Economic Research Service, Economic Issues in Agricultural Biotechnology, AIB-762, Washington D.C., February 2001, p. 4 (*) n4 - James, Dr. Clive, ISAAA, Global Status of Biotech Crops in 2002, in Council for Biotechnology Information, Good Ideas are Growing: Plant Biotechnology, Washington D.C., 2003, p. 4 (*) n5 - Griffiths, Anthony, Miller, Jeffrey H., Suzuki, David T., Lewontin, Richard C., and Gelbart, William M. An Introduction to Genetic Analysis, 5th Edition, W.H. Freeman and Company: New York, 1993, p. 2 (*) n6 - On-line document. United Nations, Food and Agriculture Organization (FAO), The State of Food And Agriculture: 2003-2004, www.fao.org/docrep/006/Y5160e/y5160e07.htm, Chapter 2, p. 1 (*) n8 - Kirby, Sarah L. "Genetically Modified Foods. More Reason to Label Than Not." 6 Drake Journal of Agricultural Law 351, Fall 2001. p. (*) n10 - Degregori, Thomas R. Agriculture and Modern Technology: A Defense. Ames, Iowa: Iowa State University Press, 2001, p. 143 (*) n12 - Huang, Jikun, Pray, Carl, and Rozelle, Scott, "Enhancing the Crops to Feed the Poor," Nature 418, August 8, 2002, p. 681 (*) n13 - Fernandez-Cornejo, Jorge, and McBride, William D., USDA, Economic Research Service, Adoption of Bioengineered Crops, AER-810, May 2002, p. 4 (*) n14 - Monsanto, Key Facts About Food and Feed Safety: The Products of Plant Biotechnology, company brochure #00499185, p. 3 (*) n15 - Fernandez-Cornejo and McBride, p. 4 (*) n17 - Lurquin, Paul F. High Tech Harvest: Understanding Genetically Modified Food Plants, Boulder, CO: Westview Press, 2002, p. 99 (*) n19 - www.document. www.bio/org/speeches/pubs/er/food.asp (*) n20 - Pretty, Jules. ":The Rapid Emergence of Genetic Modification in World Agriculture: Contested Risks and Benefits," Environmental Conservation, 28 (3) p. 251. (*) n21 - Craddock, Neville. "Flies in the Soup: European GM Labelling Legislation," Nature Biotechnology, Vol. 22, No. 4, April 2004, p. 384 (*) n22 - Tomlinson, Nick, "The Concept of Substantial Equivalence," in Ruse, Michael and Castle, David, eds. Genetically Modified Foods, New York: Prometheus Books, 2002, p. 204 (*) n23 - Burkhardt, Jeffrey, Thompson, Paul B., and Peterson, Tana Rae, "The First European Congress on Agricultural and Food Ethics and Follow-Up Workshop on Ethics and Food Biotechnology. A U.S. Perspective," Agriculture and Human Values, Vol. 17, No. 4, December 2000, p. 329 (*) n26 - McHughen, Alan. Pandora's Picnic Basket, Oxford: Oxford University Press, 2000, p. 203 (*) n27 - California Council on Science and Technology, p. 102 (*) n32 - www document. Krebs, John. "Chairman's Report," The OECD Edinburgh Conference on the Scientific and Health Aspects of GM Foods," 2000, www.OECD.org/dataoecd/34/30/2097312.pdf (*) n34 - Federal Register, National Organic Program, Amendments to the National List of Allowed and Prohibited Substances, Vol. 68, No. 211, October 31, 2003, p. 61989 (*) n35 - MacIlwain, Colin. "Organic: Is It the Future of Farming?" Nature 428, April 22, 2004, p. 792 (*) n36 - Klonsky, Karen. "Forces Impacting the Production of Organic Foods," Agriculture and Human Values, Vol. 17, No. 3, September 2000, p. 235 (*) n39 - Gewin, Virginia. "Organic FAQs," Nature 428, April 22, 2004, p. 796 (*) n40 - Dandekar, Abhaya M. and Gutterson, Neal. "Genetic Engineering to Improve Quality, Productivity and Value of Crops," California Agriculture, July-August 2000, p. 50 (*) To return to the top of the page, click here. The list of links
included in the essay is as follows*:
Glossary
- www.fao.org/biotech/index_glossary.asp Uses of
Soy - www.soystats.com/2003/edibleuses.htm. ( Also: www.soystats.com will
take you to a page from which you can link to a number of different years.) DNA -
www.dnafromthebeginning.org Biotech
Tutorial - www.dupont.com/biotech/intro/quick.html. ( No exact replacement has been found for this link. Try
www2.dupont.com/Biotechnology/en_US/intro/index.html.) Pew
Initiative - pewagbiotech.org/events/0726/. ( The Pewagbiotech site is not longer in existence. All references to
Pewagbiotech will take you to www.pewtrusts.org/our_work_detail.aspx?id=442.) Social/Ethical Implications -
www.nuffieldbioethics.org/publications/pp_0000000009.asp. (This link now takes you to the organization's general
publications page.) Products
on Market - www.bio.org/er/agri_products. (The main site, www.bio.org is still
in existence, but the page is not.) Farmers'
Perspective - www.tomorrowsbounty.org. ( This site no longer exists.) U.S.
Government Unified Biotech Website - http://usbiotechreg.nbii.gov Legislation Tracker -
www.pewagbiotech.org/resources/factsheets/legislation. ( The Pewagbiotech site is not longer in existence. All references to
Pewagbiotech will take you to www.pewtrusts.org/our_work_detail.aspx?id=442.) CCST
Report - www.ccst.us/ccst/pubs/gmf/gmf01.html Organic
Farming - www.sciencedaily.com/encyclopedia/organic_farming. (Go to www.sciencedaily.com and search on "Organic
Farming.") National
Organic Program - www.ams.usda.gov/nop Greenpeace USA -
www.greenpeaceusa.org/campaigns/intro?campaign_id=503428. (Try
www.greenpeace.org/us/campaigns/genetic_engineering.) Sierra
Club - www.sierraclub.org/biotech Friends
of the Earth - www.foe.org/camps/comm/safefood/index.html. (Try www.foe.org.) The
Campaign - www.thecampaign.org Mendocino
GMO - internal website document reference *Some of the links have changed since 2004, and some are no longer in existence. Where possible, they have been updated to reflect the changes. To return to the top of the page, click here. To return to the essay archives, click here.
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2004 Essays -
Part I (June/July)
