ALICOM 99/9  |
| ALICOM 99/9 |
Conference on International Food Trade
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Assuring Food Quality and Safety:
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by |
W. Martin Strauss, Ph. D.
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A. Supplier of Goods and Services to Meet Changing Needs
C. Realities Given Population Dynamics, Population Distribution, and Land Areas
1. This paper presents thoughts of a member of the industrial sector relating to food quality and safety legislation within the broad Codex Alimentarius system. The system has provided significant benefits and holds great potential for industry, member nations, and consumers alike by ensuring food quality and safety and facilitating international trade.
2. Speaking of the broad Codex system means not only the Codex Alimentarius formal structure - the committees, Secretariat, and member nations - but also include the parent bodies FAO, WHO, and their expert panels. Also included is the World Trade Organization (WTO) because of the WTO's use of Codex standards in the dispute settlement process. Any one of these organizations and their work provides volumes of material for discussion. With that as background I will provide my thoughts on industry's role in helping achieve the twin objectives of Codex - facilitating trade and ensuring consumer protection.
3. Industry's principle function is to supply goods and services to the markets it serves. Other functions vary dependent on the economic system established in which the industry operates. In fulfilling these functions industry operates within the broad charter granted it by the society that it serves. Within the Codex system, industry participates as an International Non-Governmental Organization or as an advisor to a member government. The food and agricultural industries have a broad responsibility to supply quality, nutritious, and wholesome food and agricultural products to consumers - hence, the sector's interest in Codex.
4. In supplying goods and services, industry must constantly seek new and better ways to meet society's needs. One of the most common ways to meet these needs is to increase productivity and efficiency. Efficiency gains by production or yield increases not only create economic advantages, but rise from society's drive for sustainability. In its simplest form it is a drive to do more with less. When this is properly done a broad array of factors are considered and balanced. Within the Codex system, the key industrial issues relate to the production, processing, packaging, and distribution of safe and wholesome agricultural and foods products.
5. In the food arena, industry produces different forms of food and fiber for distribution. The production and distribution must be done within the constraints placed upon the industry by the relevant national laws and international agreements. Demands for industry's products must be met and met at a fair price. The fair price depends on the constraints placed upon the production and distribution system and by the laws, regulations, and international obligations influencing and guiding the system. The more level the playing field determined by such legislation, the greater the competition. Codex, as a point for harmonization, serves a pivotal role in this regard for industry and consumer alike.
6. Industry's involvement in the Codex system and, separately with FAO and WHO, runs from the farm to the consumer. Guidance is provided throughout the entire production and distribution system by both FAO and WHO.
7. Codex Committees such as Pesticide Residues, Veterinary Drugs, and Food Hygiene within their broad scopes provide guidance at the production stage as well as in the later stages of processing and distribution. Committees such as Food Import Export Certification Systems span the stages at the nexus of production and trade. Other Committees such as Food Additives and Contaminants provide critical guidance to member nations concerning the preparation and finishing of foodstuffs entering commerce. Each of these, and all Codex Committees, contribute to achieve the twin goals of Codex and do their work, in large part, empowered by the data and scientific information provided by industry. This information is either provided to assist the work of the joint expert committees of FAO and WHO, the Codex Committees, or special consultations convened by the parent UN organizations.
8. Population growth and demographic changes must be considered as we look to the future striving to meet the goals the Codex Alimentarius has set for the food industry. Past agricultural production gains occurred despite declines in arable land. Yield increases provided the increased agricultural output1. The UN's Global Assessment of Soil Degradation estimated that the productive capacity of nearly two billion hectares has been seriously degraded.2 The World Bank estimates that 15% of our agricultural land will be lost to urbanization and soil degradation over the next 25 years.3 By 2050 the UN predicts that if current trends continue, the amount of arable land per person in developing countries will decline from 0.3 hectares in 1961 to 0.1 hectares in 2050.4 Recognizing individual nation's desires for food security the needs to enhance production in ways that don't adversely effect the environment and that are sustainable become more obvious and clear.
9. Today there are 1.1 billion farmers. Fifty million live in developed nations while 1.05 billion live in developing countries. Most of the farmers are resource poor - as many as 60% of them - and they produce only 15-20% of the world's food supply. The 15-20% of the food that the resource poor farmers produce represents 80% of the food produced for developing countries where population growth is the greatest.5
10. If new developments that increase productivity are not embraced we are condemning many people to insufficient sustenance and mandating greater environmental degradation while we hamper the food production systems. Current estimates place 1 billion people below the poverty line.6
11. In many ways new technologies in the production and food systems are more important to the developing countries than to the developed nations of the world. The developing countries have larger areas under cultivation and incremental improvements in productivity in their food systems provide greater benefits. Most developing countries have lower yields in the total production and food system than do the developed nations and, as a result, have greater intrinsic capability for improvements. Finally, the developing nations have the most to gain because they have the greatest projected population growths, the greatest need to currently enhance production, and the greatest gap to close to achieve their food security needs. 7
12. New beneficial technologies are developed, tested, and applied throughout the agricultural production and food distribution system. Applications of biotechnology are instructive because they illustrate the philosophical gaps and contentions currently being discussed within the greater Codex system.
13. Historically, science provided new methods to increase production. In the future, germplasm improvements will continue to increase yields. Germplasm improvements and avoiding losses are potential sources of major gains. Avoiding losses due to insect and microbial damage can also provide more because as much as 50% of the produce is, at times, lost.8
14. By way of example, efforts to attain the benefits germplasm improvement provides can be shown by the historical gains mankind has made. Open pollination methods provided little gain during most of our agricultural history. With the advent of double-cross techniques production gains of about 1% per year have been made. The development of single cross techniques provide production gains of 2% per year. 9 The next technique of this continuum is the science of genomics and it provides the most complete opportunities to date to enhance productivity and help meet society's needs for additional food and fiber.
15. The science of genomics refers to the process of identifying the genetic makeup of important living species and this science is being applied to crop plants. The knowledge genomics provides will help us realize the improvements in germplasm needed to provide future productivity gains. Through the use of genomics, not only can production gains be made; but the applied knowledge will empower molecular techniques to address other traits such as: yield, drought tolerance, diseases, plant stresses, quality traits, and plant maturity. The knowledge gained will provide much faster, targeted research and development as well as shorten commercialization timeframes.
16. Concerns have been expressed about the speed and safety of this technology. My company's experience is instructive in this regard. We started research in agricultural biotechnology in 1980. In 1983, my colleagues were the first scientists in the world to improve plant traits using biotechnology. Four years later, after many tests, the plants were allowed to be field tested. Now, eighteen years later we have ten products in the market. In 1998 the global acreage planted in improved varieties through the efforts of biotechnology increased 16.8 million hectares to a total of 27.8 million hectares from the previous year.10 The acreage planted with these improved varieties has more than doubled this past year and the countries where these increases have occurred have cleared the products as being safe for consumption and for the environment.
17. The benefits these crops provide are now not the subject of speculation but are being measured. The use of Roundup Ready® soybeans in combination with no till production methods results in a 5% yield increase, a decrease of foreign matter in the harvest of 33%, a decrease in production costs of 10-20%, decreased erosion of 90%, and decrease fuel usage of 20-40%. 11,12,13, 14,15 Similarly the use of insect resistant varieties of cotton producing the BT toxin that were grown in China, Mexico, and South Africa reduced insecticide sprays by 90-100%. 16
18. These types of benefits are required to meet production increases in sustainable ways. Failure by the Codex system to competently address these types of developments in timely ways empowering their safe adoption will be a significant failure of the system that must be addressed as a matter of priority. Concentrating on the science, not the politics of the day, is the way forward.
19. Another area where rapid scientific progress is being made that is also under active consideration by the Codex system is the area of health claims. As scientific knowledge increases our understanding in this important area Codex guidance to its members is needed. Increasing macro- and micronutrients to provide consumers benefits from foods will be enhanced by Codex's guidance on the elaboration of appropriate standards. Likewise, as new technology must be effectively dealt with by Codex, rigorous, scientifically justified bases for these types of claims must be and are being elaborated to ensure consumer benefit and protection.
20. Health claims are intended to communicate a benefit between a food, nutrient, or other substance contained in a food and a disease or health related condition. These claims are intended to communicate a benefit in the context of the total diet. Claims relate to reduction of risk of developing a disease by making a dietary change rather than curing, treating, preventing, or mitigating a disease.
21. Codex's consideration of the scientific basis to justify such claims is needed. To date, Codex members seem to favor allowing such claims on the basis of scientific consensus from competent authorities. In this case, industry encourages consideration by Codex that significant scientific agreement does not always mean unanimous agreement among experts. A high level of confidence that the claim is valid is the more appropriate criteria. An even better expression would be that there exists reasonable certainty among experts that the claim is valid.
22. Claims should be based on appropriately developed scientific studies that consider outcomes from all available scientific studies. The type of substantiation required should be proportionate to the degree of consumer benefit stated or implied by the claim. This philosophy of scientific "consensus" is worthy for Codex to consider on many of the topics it is currently considering.
23. In recent years, some discussions have attempted to expand Codex's considerations into non-scientific areas. Discussions on topics such as "other legitimate factors" and the Precautionary Principle pose a challenge to the global nature of Codex, consensus, and the scientific principles upon which Codex has been created - to the detriment of all if inappropriate decisions are made. When confidence in the scientific base of Codex erodes all groups involved in the system lose because the organization's goals will not be achieved depriving benefits to all parties.
24. Codex decisions must be global in order to maximize their guidance to member nations and protect the interests of consumers and industry alike. Codex must carefully distinguish what is germane for its consideration versus what considerations and decisions are best left to individual member nations. Because of its international reach Codex's approach to issues and the types of issues it considers should not arbitrarily vary from issue to issue, be different in each FAO region, nor should the approach vary over time. Considerations that are not global and that cannot be scientifically justified may be inappropriate and are best left for individual member nations to consider.
25. Codex members are deeply divided by the consideration of "other legitimate factors" as a working principle. Codex must ensure that the work it undertakes is within the competency of the body. Codex decisions should be made using quantifiable data that is useful in the risk assessment process. Doing so ensures transparency and protects the legitimate interests of all parties. Not doing so facilitates either the establishment of non-tariff trade barriers or constrains the Codex system from elaborating useful standards by raising spurious, non-useful considerations that are outside the scope and competency of the Codex system.
26. Attempts to enshrine the precautionary principle or approach must be handled in a competent way. The risk assessment process is, by its nature, a conservative system. Using undefined principles or approaches to manipulate the system or bias it against scientific considerations applying factors multiple times serves no one. Precaution is justified in the case where data are insufficient but not in the case of uncertainty. Science is always uncertain and these matters are inherently dealt with in the risk assessment process.
27. New and potentially useful philosophies should be encouraged and be thoroughly debated. Innovative considerations and philosophies that initially appear problematic may evolve to provide significant benefits for all concerned. Their consideration must continue and their utility be judged against the scientific basis of the organization. The consideration should proceed in a way that does not inappropriately stall or constrain the important ongoing work of the body.
28. Codex standards serve the member nations, consumers, and industry well but will surely falter when Codex extends its reach into areas beyond its mandate and expertise. Codex succeeds and the member nations are well served because Codex does its job well working within its areas of scientific competency.
29. The use of risk assessment, risk management, and risk communication within Codex is well enshrined. Numerous consultations convened by both FAO and WHO show the importance of melding these disciplines into a system that helps fulfills the objectives Codex has established.
30. The expert committees of FAO and WHO provide critical input for the Codex system relative to the risk assessment process. These Committees serve the interests of all member nations and must continue to be supported and strengthened. The clear advantage offered by the work of these important groups lies in their ability to attract global experts to review and provide the best scientific guidance available relative to food safety. Scientific considerations are the paramount concern and must continue to be. Experts are, and must continue to be chosen based on the transparent record of their individual scientific accomplishment and proven expertise. Doing otherwise seriously weakens the underpinnings and foundations of these key committees.
31. Likewise the work of the majority of Codex Committees focuses on the scientific considerations related to food safety. Committees such as Residues of Veterinary Drugs, Food Additives and Contaminants, and Pesticide Residues have a history of dealing effectively with the risk assessment process and melding their recommendations with appropriate risk management considerations in the guidance they provide for consideration by the Commission.
32. Risk management is ultimately the responsibility of the member nations and many factors other than scientific considerations may enter into these decisions. Again, considerations outside the scope and expertise of Codex must be left to the member nations to avoid setting international standards that are based on factors that are not shared and of no benefit to various regions and members.
33. The use of Codex standards in the dispute settlement process at the WTO has greatly reinforced the importance of the work of Codex. At its essence the use of Codex guidance by WTO is recognition of the history and accomplishments of the body in achieving its missions of facilitating trade and providing needed scientific guidance related to food safety.
34. Rather than being overly concerned about the impact standard setting might have within the WTO, Codex needs to stay on course and fulfill its stated goals. The enviable record that led WTO to recognize the stellar scientific work of the Codex does not commit the dispute panels to rely on Codex. Should Codex guidance deviate from its mission and scientific considerations, the WTO likely would use other available information and studies in its work.
35. Industry considers the combined work of both bodies as being critical. WTO's mission is to ensure that trade flows smoothly, predictably, and as freely as possible. This alignment with the mission of Codex provides the juncture between the two organizations.
36. Achieving these joint goals requires Codex to set compositional, quality and safety standards based on the best technical information available. Doing so allows it to continue to champion the interests of all in making progress toward assuring food safety and consumer protection.
37. Achieving the twin goals of safety and trade will never be easy but are worthy goals because striving to achieve the goals moves us all towards a more prosperous, peaceful world, with increased opportunities in our ever increasingly connected economic world. Trade barriers not only forestall economic development opportunities but their erection inevitably encourages development of barriers in other sectors and ultimately between nations.
38. These concerns are critical for developed and developing nations alike. Agricultural and food trade are fundamental economic sectors and drivers for other national economic opportunities. Failure to advance a sound, scientifically based trading system, in all likelihood, disproportionally disadvantages developing economies because they lack the elasticity that developed nation's economies enjoy. By recognizing and using the scientific considerations of the Codex, WTO seeks to create and maintain a system where legitimate market forces drive the trading system within the confines of the SPS and TBT Agreements.
39. From an industrial standpoint key provisions of the work of WTO include the concepts of transparency and consistency. Both concepts are fundamental to ensuring that the rules of trade foster opportunity and that the rules are predictable. Predictability is also a key concern for industry. Without it planning cannot occur and innovation greatly suffers. Industry welcomes meritorious regulation but encourages the elaboration of standards that are transparent, predictable, and scientifically rigorous.
40. To achieve these goals it is important that once legitimate objectives have been elaborated by member nations that the standards put in place deal as specifically as possible with those objectives. The measures taken should minimize unwarranted trade impacts and intrusions to fair trade.
41. The need for these principles is heightened at the present time. As the pressures increase globally related to economic development, food production, and food security, it is critical that we concentrate on the scientific considerations within Codex. The upcoming round of the WTO Agricultural Ministerials must ensure that new technologies meeting quality and safety standards not be discriminated against. Such developments must be assured fair and equal market access based solely on sound scientific considerations. To achieve this objective, the SPS Agreement must not be weakened, but must affirm its scientific base.
42. FAO and WHO have and will continue to make significant contributions to the food production, distribution, and processing systems globally apart from their efforts with the Codex. It is also clear that as budget constraints and needs increase, the ability to fashion collaborations with the food and agricultural industries can meet multiple, shared objectives.
43. Through innovative programs technology transfer can be accelerated and the sharing of best practices in food and agricultural sectors enhanced. Where applicable legislation is lacking, FAO and WHO advocacy for competent food control legislation can be critical. The discussions within Codex on equivalency are directly germane to this and important for member nations, consumers, and industry alike.
44. Equally important are opportunities to enhance and speed up the adoption of Codex standards by member nations. Meeting this obligation would go a long way towards harmonizing for the benefit of all.
45. FAO has a key and critical role because of both its charter and its expertise. Food security, production, and the needs to enhance quality, safety, and productivity of this fundamental economic sector (agriculture) are critical components to meeting our collective current and future needs.
46. The Director-General of FAO indicated at FAO's 50th anniversary that these needs would be met by increasing production yields and by providing more efficient distribution of agricultural and food products.17 This must be done against the backdrop of an annual population increase of 86 million people in a world where 800 million are currently malnourished.18
47. Historically, agricultural production has increased at a greater rate than population growth. Acceptance of new technologies for production and processing will be needed to continue to help meet the needs of food and fiber in the future. Farm mechanization, irrigation, and the use of fertilizers, and pesticides provided additional productivity in the past.
48. Continued development is critically important to the developing countries, not only towards achieving greater agricultural productivity, but also in avoiding losses. Loss estimates range as high as 50% due to spoilage or contamination which, at times, results from the inability to process the food. Quality issues need to be addressed throughout the production, processing, and distribution system. FAO plays a huge role in these areas as well.
49. Technology has always been a driver in the food sector. Methods that improve handling, separation, evaporation, dehydration, and heating have and will continue to make major contributions. New technologies are poised to provide benefits as well. These include irradiation, biotechnology, nutrient enhancement/fortification, and high pressure processing. Systems such as HACCP and in line processing controls will help achieve these safety and quality goals.
50. Safety issues include both chemical and microbial consideration. These considerations are taken into account within the Codex as committees consider Good Veterinary Practice, Good Agricultural Practice, and Good Manufacturing Practice.
51. FAO's unique and critical role ranges from production of raw and basic agricultural commodities to the table. Accordingly, FAO's span and expertise encompasses production methodology, storage, shipment, distribution, processing, safety, and preservation of finished goods. This span places FAO in a challenging and critical position having great impact on the agricultural and food systems industries. Each of these areas shares common ground, markets, and the interest of industry. FAO has played a fundamental role by assisting developing countries to establish food regulatory systems based on Codex standards. Not only has it led to improved opportunities for exports, but also, to improved quality of domestically consumed products.
52. Ways to enhance industrial involvement, implemented in appropriate ways, will provide short term and long term benefits for all. Industry's desire to meet global market needs provides the impetus for collaborations. Progress can be achieved by structuring programs that improve market access and also address national needs for economic growth.
53. Industry can provide economic support for programs and empower technology transfer to facilitate best practices use and development. Industry can and will take a long term view of development opportunities when the goals of Codex and WTO are center stage but will shy away from investments and challenges that are constrained by technical barriers, lack of transparency, or economic forces that are misapplied against innovation. Only through joint collaborative efforts which address the needs of all can progress be made as rapidly as possible and be done in a sustainable way.
54. The areas in greatest need for technology transfer and the application of best practices present the most complexities in achieving these goals because their markets may be small and the economies may be weak. Key to surmounting these problems and achieving the goals are the prospects for economic growth to empower development.
55. Achieving the goals means abandoning spurious discussions that masquerade issues for what they are not. Codex asks that the economic impact of standards be openly discussed. This should be done, but not under the rubric of disguised safety allegations. Failing to keep the debate honest can damage the prospects of nations seeking harmonization. A strong stance must be taken against this type of abuse by each relevant international organization.
56. The WHO shares the potential expressed for FAO and WTO in its ability to impact the basic needs for food and fiber but adds its considerable expertise in the prevention and response to diseases that afflict humankind. Central to our discussion is the area of food borne disease, the effects of malnutrition, and the critical needs of the malnourished.
57. The costs to our societies of failing to responsibly deal with these matters is magnified many fold in terms of human suffering, failure to deal with our responsibilities to others, and the economic and global costs to us all.
58. The setting of competent and scientifically defensible standards will help provide the economic and social capital for mutual advancement. Failure to provide fair, transparent, focused and scientifically justified standards will prevent the system from reaching its full potential and result in obstructions to collaborative efforts between many sectors. As all of these needs are global, so too are the needs for global standards. Standards need to be elaborated and applied in a way to facilitate safety, trade and consumer protection using the international mechanisms provided by FAO and WHO through the Codex Alimentarius.
59. There has been great discussion within the Codex about considerations of factors other than science in the elaboration of guidance provided by Codex. Science is the best and may sometimes be the only common denominator related to global application of transparent standards. Other factors are considered within Codex but are all quantifiable and applicable to the risk assessment process.
60. Industry fully supports the Four Principles of Science adopted by the Commission and encourages Codex to maintain a strict reliance of scientific considerations to ensure that its future work continues to address the needs of and reflect the opinions of all regions of the world. We also would like to see governments use the fourth principle more often, rather than depriving all countries of the opportunity to standardize products which may be locally controversial.
61. One concern and observation about the workings of Codex stems from the recognition that mechanisms must be put in place that facilitate the participation, interaction, and discussion of key issues with many more countries. All too often Codex decisions are taken by 40-50 member nations when 165 countries now belong to the organization.
62. There is a gap between the developed and developing nations that needs to be closed to ensure broader representation and participation at many meetings and on many issues. Technological advances can ease the costs of trying to meet these needs. Mechanisms to enhance financial support should be considered for countries that lack the resources to fully participate.
63. The reality of the system is that few developing countries have the opportunity to consistently participate in the deliberations while the policy discussions and gap grows between key trading blocs. Greater participation, new perspectives, and reasserting the emphasis on scientific considerations rather than on socially and politically correct arguments is required and needs to be addressed as a matter of priority.
64. Because trading blocs and political interests are pressing Codex to validate their national perspectives on standards, at times in direct opposition to the underlying scientific considerations that should form the basis for the work of Codex, delays and non-adoption of standards is becoming more commonplace. Issues and products that are controversial for various reasons face a decade or more within the Codex process. During this time products are in use by member nations who are denied the benefits of competent Codex guidance. Calls to avoid dealing with the tough issues must be rejected. Efforts should be increased to find common ground.
65. During recent years delegations have expressed concerns that the new compounds being considered by both the pesticide committee and the veterinary drug committee are decreasing while many more monographs are removed from the Codex due to lack of industry support for the compounds. With the scientific basis for Codex decisions under assault, industry is rightfully concerned about the rules for review and consideration. Industry seeks predictable, scientific rigor - not politics and changing considerations as the issue of the day in one region or another fluctuates. Science should be the currency of discussion not other factors which are not shared by all Codex members.
66. This approach is being taken to validate national and regional social and political interests. Recognizing that the WTO looks to Codex for guidance to settle disputes, such an approach may appear rational. By making Codex mirror a country's own standards it insulates itself from WTO sanctions. That may work in the short run but it undermines the benefits of the Codex system and will compromise the technical integrity of the system. As that occurs WTO will likely use other technical input to guide its decisions and all Codex members will suffer because needed guidance becomes less available.
67. Building on the past successes of Codex can be made much easier if all countries continue to concentrate on the competencies of the body and make appropriate use of the significant technical expertise afforded the system through the Codex committees and the expert panels.
68. By adhering to its mission the greater Codex system will continue to set standards based on analytical sciences that are protective of the public health. Actions will not be unduly hampered by arguments outside the areas of competency or for reasons that are not germane to the international body. By concentrating on recommendations of JECFA and JMPR these results will more easily be accomplished.
69. In taking these types of actions Codex will encourage a scientific basis for equivalency among its members and this will smooth the way for improved trade. The continuing efforts of WHO and FAO under these circumstances, will provide opportunities for capacity building, technology transfer, shared learnings, and best practices that will raise production, self reliance, and facilitate the ability of the member nations to more fully participate in Codex in a meaningful and independent way. This will be possible because greater common interests will prevail based on best available science using the best available technology.
70. Industry should :
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2. W. Bender and M. Smith, "Population, Food, and Nutrition," Population Reference Bureau (PBR), Washington, D.C. 1997, p. 3.
3. Environmentally and Socially Sustainable Development Studies and Monographs," Bioengineering of Crops: Report of the World Bank Panel on Transgenic Crops," Series No. 23, The World Bank, Washington, D.C. ,1997, pp.4-5.
4. See: United Nations Populations Fund (UNFPA). "Population and Sustainable Development - Five Years After RIO," UNFPA, New York, 1997, pp. 1-36.
5. Spillane, Charles, "Recent Developments in Biotechnology as they Relate to Plant Genetic Resources for Food and Agriculture," Background Study Paper #9, Commission on Genetic Resources for Food and Agriculture, Food and Agriculture Organization of the United Nations, April 1999, p. 5.
6. Ibid., p. 5.
7. James, Clive, "Global Review of Commercialized Transgenic Crops: 1998," International Service for the Acquisitions of Agri-Biotech Applications, Ithaca, NY, p. v.
8. Horman, Ian, "The Food and Drink Industry: A Constant Need, A Constant Challenge," Message from the Director General of the United Nations Food and Agriculture Organization, CIAA and GMA, 1995, p. 7.
9. Crosbie, Theodore M., and Lamkey, Kendall, Manuscript in Preparation, p. 7.
10. James, Clive, "Global Review of Commercialized Transgenic Crops: 1998," International Service for the Acquisitions of Agri-Biotech Applications, Ithaca, NY, pp. iii.
11. Conservation Technology Information Center (CTIC), "14 Benefits for U.S. Farmers and Environment through Conservation Tillage," West Lafayette, IN, 1997
12. Baker, D.B., "Herbicide Concentrations in Ohio's Drinking Water Supplies: A quantitative assessment." In D.L. Weigmann (ed.), Pesticides in the Next Decade: The Challenges Ahead, Virginia Water Resources Center and VPI, Blacksburg, VA, 1990
13. Baker, J.L., J.M. Laflen and H.P. Johnson, "Effect of Tillage System on Pesticides in Runoff from Small Watersheds," Transactions, American Society of Agricultural Engineers, 1978, 22: 554-559.
14. Baker, J.L., and J.M. Laflen, "Runoff Losses of Surface-Applied Herbicides as Affected by Wheel Tracks and Incorporation," Journal of Environmental Quality, 1979, 8:607-607.
15. "Sustainability and the Roundup Ready® Soybean System: An Analysis of Economic and Environmental Issues," Monsanto Backgrounder, St. Louis, March 1998.
16. Grower Surveys, Post-Harvest, 1998.
17. Horman, Ian, "The Food and Drink Industry: A Constant Need, A Constant Challenge," Message from the Director General of the United Nations Food and Agriculture Organization, CIAA and GMA, 1995.
18. Horman, Ian, "The Food and Drink Industry: A Constant Need, A Constant Challenge," Message from the Director General of the United Nations Food and Agriculture Organization, CIAA and GMA, 1995.