Genetically Modified Organisms - World Trade Organization

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Vancouver Model

United Nations The 11th Annual Conference • January 20– 22, 2012

Background GuideWorld Trade Organization



Vancouver Model United Nations

The 11th Annual Conference • January 20– 22, 2012

Dear Delegates,

My name is Livvy Bedord and I will b e serving as your Director in the World rade

Organization during the 2012 VMUN conerence. I am currently a Senior at

Inglemoor High School in Kenmore, Washington. I have been involved in Model

United Nations since I started high school and am currently the President o the

MUN club at my school. I strive to maintain an international ocus that looks

beyond the American ramework I’ve grown up in and I have had nothing but

wonderul experiences in MUN. I hope that I can help create a positive experience

or everyone in the WO and that you’ll come away rom this conerence with a

better understanding o the country you represent and the issues we’ll be ocusing

on.

I’m very excited to see where the discussion and debate will lead as we explore the

issues I’ve selected. I had a wonderul time researching and writing this background

guide and I hope you will all fnd these issues as interesting as I did. Both topics

address very serious questions about how our increasingly globalized world is

going to solve the problems that arise as we become more connected. Te frst

topic, which addresses the negatives o ood aid, is important in understanding how

countries can help each other responsibly and maintain development goals in the

midst o crisis. Te second topic addresses a undamental divide between trade

objectives and human health. In determining a solution delegates must determinethe appropriate boundary between protecting trade and protecting consumers

rom potential dangers.

I hope that you’ll all keep this question in mind while exploring both topics and

preparing your position papers. I look orward to hearing the ideas that will

inevitably come out o your hard work and I can’t wait to meet all o you. I you

have any questions regarding the conerence eel ree to contact me anytime.

Best wishes,

Livvy Bedord

Director, World rade Organization

Hafz Dhanani

Secretary-General

Yeoman LiangDirector-General

Alex LinConerence Director

Zach HauserChie o Sta &

Under-Secretary-GeneralCommittees

Amelia Casey Under-Secretary-General

Committees

Stuart WarrenUnder-Secretary-General

Delegate Aairs

David ChoiUnder-Secretary-General

Inormation echnology

Johnny BrynelsenUnder-Secretary-General

Marketing

Jennier YoonUnder-Secretary-General

Marketing

Azzra MangaljiUnder-Secretary-General

Sponsorship



Vancouver Model United Nations 2012

World Trade Organization

Topic B: Genetically Modifed Organisms and Trade

Introduction

Since the introduction o genetically modifed organisms (GMOs) in the 1990s, controversy has erupted

regarding the saety o oods containing genetically modifed (GM) substances. Biotechnology

corporations and supporters have long heralded GM oods as a panacea, equipped to solve the global

hunger crisis. In contrast, consumers, scientists, and governments around the world have expressed

signifcant concern over the risks to human health and the environment that GM oods may pose. As a

result, several countries have enacted legislation imposing strict regulations on GM oods. Tese

regulations have slowed trade rom GMO-producing countries and elicited strong criticisms rom GMO-

exporting countries. As the presence o GMOs in ood crops continues to increase, it is vital or the WO

to orm a set o international guidelines to determine acceptable regulations or the trade o GMOs that

will allow governments to protect human health and the environment rom potential risks but also

prevent unair restriction o international trade.

Timeline

1979 — Te echnical Barriers to rade (B) Agreement is signed at the end o the okyo Round o

negotiations. Te agreement was also updated during the Uruguay Round and is still an integral part o the

WO regulatory ramework.1

1987 — European Union decides that biotechnology is an area that requires regulation at the community

level as well as the international level. 2

1992 — GM oods are introduced to the market in the United States. Labelling is not required and most

consumers remain unaware o the presence o GM products in their ood.3

January 1, 1995 — Te WO Agreement on Sanitary and Phytosanitary Measures came into eect.4

1995 — In a study by the USDA o Americans living in New Jersey, only 60% o people said they would

consider buying resh GM vegetables i they were labelled as such.5

1996 — Roundup Ready Soybeans are introduced by Monsanto, an agriculture and biotech corporation.6

1997 — More than 60% o Europeans surveyed in a Eurobarometer poll expressed concerns regarding the

saety o GMOs in ood products.7

January 1997 — European Union adopts regulation 285/97 on novel oods, imposing heavy regulations on

the presence o GMOs in oods.8

1 http://www.wto.org/english/tratop_e/tbt_e/tbt_ino_e.htm2 http://www.ppl.nl/bibliographies/wto/fles/5177a.pd 3 http://www.commercialdiplomacy.org/ma_projects/ma_sandblom1.htm4 http://www.wto.org/english/tratop_e/sps_e/spsund_e.htm5 http://ec.europa.eu/agriculture/publi/gmo/gmo.pd 6 http://www.monsanto.com/whoweare/pages/monsanto-history.aspx7 http://ec.europa.eu/agriculture/publi/gmo/gmo.pd







would otherwise be okay or consumption. Vegetarians are also troubled by the implications o animal

genes being used in ruits or vegetables, a process that would cause some vegetarians to reject the resultant

GM produce. Also, changing the genetic structure o a plant or animal may cause changes in nutritional

content, toxicity, allergenicity, and/or antibiotic resistance, all o which have the potential to cause untold

health problems or consumers.

GM oods have become a matter o trade dispute, i.e. a matter under the WO’s purvey, because o the

radically dierent approaches to the regulation o GM products throughout the world. Production o

GMOs is concentrated in fve countries: Argentina, Brazil, Canada, China, and the United States.17 Tese

countries account or roughly 90% o GM crops worldwide, placing the control o biotech in the hands o

a small number o powerul corporations. As a result, small growers may be edged out as only large

corporations capable o producing GMOs are able to compete in an increasingly GMO-dependent

market. As a result, the agriculture market risks becoming more centralized i GM oods continue to

increase in popularity, as they have in the past two decades. In a GMO-dominated uture, the costs o

intellectual property rights associated with the research and development necessary to create viable

GMOs has the potential to edge out small growers, especially in the developing world, who will no longerhave the capital to sustain their arms.18 Intellectual property rights have already proven troublesome or

armers growing Roundup Ready Soybeans, a variety manuactured or herbicide resistance. Te

company, which produces Roundup Ready Soybeans, charges US armers a technology ee or its seeds,

raising the cost considerably. Adding to the controversy, these ees are not leveraged equally amongst

dierent countries. In Argentina, Roundup Ready seeds are sold without the technology ee, leading to

high quantities o cheaper soybeans in Argentina sold at prices that US armers have a dicult time

competing with on the international market.19

rade Disputes

Te reactions to GMOs in ood have been strong and diverse. At one extreme, the European Union

requires mandatory labelling o all oods containing quantities o GMOs above a 1% tolerance level. Atthe other, the United States and Canada require labelling only in cases in which the nutritional

composition or allergenicity o the ood has been altered due to genetic engineering; otherwise, labelling

is voluntary.20 Te EU’s strong anti-GMO policies have been criticized as being harmul to trade. Te

estimated loss to US manuacturers as a result o these regulations is approximately one billion dol lars.21

Crops that are bred to produce the pesticide Bt have been approved or growth in the US; however, these

crops have proven highly controversial and have been rejected by the EU due to concerns regarding

human health. Due to the EU’s rejection o Bt products, several US grain merchandisers reused to buy Bt

corn products rom growers and required certifcations stating that no GM seeds had been used. In turn,

biotech agriculture frms were orced to promise armers that markets would be available or GM crops in

order to secure buyers.22 Te impacts o EU regulations are especially impactul or armers outside o theEU because most EU producers are already GMO-ree and thereore immune to increased regulation. EU

17 http://www.google.com/books?id=rmAr4_SzQv8C18 http://www.unctad.org/en/docs/poditctncd1.en.pd 19 http://nationalaglawcenter.org/assets/bibarticles/hamilton_shaping.pd 20 http://ageconsearch.umn.edu/bitstream/16317/1/tm020106.pd 21 http://www.unctad.org/en/docs/poditctncd1.en.pd 22 http://nationalaglawcenter.org/assets/bibarticles/hamilton_shaping.pd





rejection o GMOs has also been linked to occurrences o surplus dumping in the orm o ood aid. For

example, in 2002 a severe amine in Arica gave the US an opportunity to dump GM ood aid on starving

Arican nations. However, many o these nations reused the shipments o GM ood aid, citing concerns

over human health or the implications or uture agricultural trade with the EU. Te US responded with

heavy criticisms o EU policies, claiming that the EU’s rejection o GM oods had led thousands o people

to starve needlessly. Critics o the US responded by insisting that US reusal to compromise on thecomposition o its ood aid was indicative o a desire to open markets to GM oods rather than provide

humanitarian aid. Te dispute over the trade o GM products continues to cause great tension between

GM supporters and anti-GM countries, particularly the EU and US.23

Te EU has adopted the “precautionary principle” in its approach to the regulation o GM crops. Rather

than waiting or conclusive evidence o health risks while allowing GM oods to enter the market, the EU

has implemented strict regulations or the approval and monitoring o all GM ood products. In contrast,

GM-riendly countries have opted to allow GM products to enter the market with very little regulation

and almost no eorts to engender consumer awareness. As a result, the presence o GMOs in the average

consumer’s diet has increased rapidly in the US, a act largely unknown to the public.

Te dierence in policies can be traced to an underlying dierence o opinion in risk assessment and

management. Countries like the EU base their risk assessments on the process rather than the product;

countries like the US do the opposite. In short, process-based assessments consider the method through

which the product was manuactured in determining whether or not two products are alike. wo diering

processes create two diering products, regardless o the quantifable similarity o the product. In

product-based assessments the concept o “substantive equivalence” is used to determine dierences in

products. As a result, only the end product is considered and regulations are only deemed necessary in

cases in which the end product diers signifcantly rom the non-GM orm. Te process o genetic

engineering is not considered to be inherently dierent rom traditional plant breeding techniques and assuch is not subject to extra regulation.24 Tis undamental dierence highlights the main controversies

associated with the regulating GM oods. In order to develop a regulatory ramework, the WO must

decide which regulatory approach to take regarding GM oods or develop a blend o the two.

On May 13, 2003, the United States, Argentina, Canada, and Egypt requested ormal consultations on the

EU’s moratorium on approvals o new GMOs. Te ban, which had been put in place in 1998, was viewed

as unnecessarily restrictive to trade.25 Tough the EU’s moratorium was ended in January, when a new set

o regulations replaced it, the request has not been withdrawn due to the strictness o the EU’s remaining

policies. Te WO panel in charge o the case released its ocial report on September 29, 2006, ruling in

avour o the US and its co-complainants. Te EU’s actions regarding the regulation o GMOs were ound

to be inconsistent with its obligations under the SPS Agreement. Te EU and US did come to a rough

agreement in regards to the WO’s judgment, however, the EU has retained strong precautionary

23 http://users.humboldt.edu/nzerbe/research/zerbe_eeding.pd 24 https://www.cbd.int/doc/articles/2003/A-00480.pd 25 Ibid .





measures to regulate and monitor GMOs and international standards or the treatment o GMOs are still

needed to prevent uture GMO-related trade disputes.26

Te Controversies o Labelling and racing GMOs

Te labelling o GM oods is a highly controversial aspect o the GMO debate. In some countries,

labelling is mandatory to a 1% tolerance threshold or accidental GM contamination. In others, labelling

is required only in cases in which genetic engineering causes changes in the fnal product. Many

supporters o labelling GMOs cite the consumer’s “right to know” as the basis or imposing universal

labelling requirements on GM oods. Many consumers are uncomortable with the presence o GMOs in

their ood and wish to avoid them or religious, ethical or health concerns. Tese concerns are especially

relevant in cases in which the allergenicity o a product has been changed by genetic engineering.

Labelling would also serve as an easy way to monitor GM oods once they have reached the market and to

pull products that are later ound to pose great risk to the environment or human health. Labelling can all

under two categories: “positive” or “negative” labelling procedures. Under positive labelling procedures

products that contain GM products are labelled, in contrast, under negative labelling procedures only

products that are certifed GM ree are labelled. 27

One argument that has consistently been leveraged against eorts to label GM oods are the high costs and

diculties o separating GM and non-GM oods throughout the production process; costs which

producers, especially in pro-GM countries, cite as prohibitive to labelling. Despite these assertions,

studies have shown that the overall costs o segregating crops can be as little as 0.5% o the sale price. 28

Another limitation o labelling and tracing GM products is the need to routinely test crops to ensure that

GM tolerance levels and content are being respected. Currently two tests exist to determine the existence

o genetic engineering: one locates new DNA while the other locates proteins (produced by the new

DNA) that would not exist in the conventional product.29 Te DNA based testing is much more expensive

and requires more time than the protein based test which can be perormed at relatively low costs in as

little as fve minutes.30 Countries that do not perceive a dierence between GM and non-GM oods areespecial ly opposed to labelling GM products because producers ear that consumers will read GM labels

as an admission o risk, and will go to unnecessary lengths to avoid GM products without scientifc proo

o health risks.

Relevant Actions

echnical Barriers to rade (B) Agreement

Te B Agreement has two purposes. Te frst is to ensure that countries do not use domestic

regulations, product standards, or testing to create unnecessary obstacles to trade; the second is to ensure

that countries also have the right to limit trade in order to achieve legitimate policy goals such as the

protection o the environment or human health. 31 Te agreement creates a dierence between technical

26 http://www.wto.org/english/tratop_e/dispu_e/cases_e/ds291_e.htm27 http://www.ppl.nl/bibliographies/wto/fles/695.pd 28 http://ec.europa.eu/agriculture/publi/gmo/gmo.pd 29 Ibid .30 Ibid .31 http://www.wto.org/english/tratop_e/tbt_e/tbt_e.htm





barriers and standards. echnical barriers are binding laws that require compliance or trade to occur;

mandatory GMO label ling alls under this category. In contrast, standards are non-binding, can be

adopted voluntarily to help acilitate trade, and may be adopted by third parties. Te B agreement

provides procedures, regulations and standards or adopting technical barriers and standards regarding

international trade and also provides processes or ensuring that products meet the standards proposed in

these agreements. Tose who actively support universal GMO labelling argue that GMO labelling shouldall under this agreement and meet the standards o this agreement, and would like to see GMOs argued

under this agreement rather than the SPS agreement.32

Agreement on Sanitary and Phytosanitary Measures (SPS Agreement)

Te SPS agreement determines how governments can impose ood saety and environmental regulations

without adopting measures that unairly protect domestic products against oreign competition.33

Countries are allowed to set their own standards, however, these standards must be based in scientifc act

and can only be extended as ar as necessary to protect animal and plant lie. Members are obligated to

achieve three objectives when developing health and saety regulations. Tey must a) ensure that any

standards that exceed international standards are based on scientifc risk assessment and sucient data, b)

choose the method o regulation that is least restrictive to trade while meeting health objectives, and c)

accept the standards o other countries when it can be shown that the same health objectives are being met

with dierent regulations.34 Te judgment against the EU was made using this agreement on the basis that

the EU’s policies were not based on conclusive scientifc evidence and as such were too trade restrictive.35

Under the SPS agreement, the precautionary principle can be applied or only a l imited amount o time

and only in cases in which the country can prove it is actively seeking scientifc data to back its claims o

risk.36

Cartagena Biosaety Protocol and Codex Alimentarius Commission (CODEX)

Negotiations regarding the Biosaety Protocol were fnally completed on January 29th, 2000. During

negotiations, the regulations o GMOs (reerred to as LMOs in the protocol) were a critical source o debate. Te Protocol provides regulations or the transport o GMOs, including GMOs intended or use as

ood or eed products. Te Protocol also allows or countries to adopt the precautionary principle in their

policies regarding GMOs. However, the relationships between the Protocol and o ther international

agreements, including obligations to the WO, have not been clearly defned. One clause o the Protocol

asserts that countries are not released rom other international obligations by the agreement to the

protocol ; however, the next paragraph contains a clause that claims that the Protocol is not meant to be

subordinated to other international agreements. As a result it is not known how the Biosaety Protocol can

or will be used to justiy trade restrictive actions meant to mitigate the risks o GMOs. Also, there is no

clear orum or international disputes that all under the mandate o the Biosaety Protocol and the WO.37 Te CODEX represents a joint FAO/WHO eort to compile the standards, codes, guidelines and

recommendations or regulating oods. Te CODEX contains guidelines or monitoring the risks o GM

32 http://www.ppl.nl/bibliographies/wto/fles/695.pd 33 http://www.wto.org/english/tratop_e/sps_e/sps_e.htm34 http://www.ppl.nl/bibliographies/wto/fles/695.pd 35 http://www.wto.org/english/tratop_e/dispu_e/cases_e/ds291_e.htm36 http://www.wto.org/english/tratop_e/sps_e/sps_agreement_cbt_e/c8s1p1_e.htm37 http://www.iisd.org/pd/biosaety.pd





oods. Tough the terms o the CODEX are not binding, the CODEX is reerenced in the SPS agreement

and as a result may be reerenced in trade disputes.38

Bloc Positions

Tere is great variability between the types o regulations that each country adheres to. International

standards would greatly simpliy the matter—especially or developing countries, which are oen le inthe middle, unsure o how to balance their needs with the two regulatory extremes in the developed

world. Te table below summarizes the types o regulations used and the countries that adhere to those

types o regulations.39

Te European Union

Te EU has imposed some o the strictest policies regarding the authorization and monitoring o GM

oods. All new GM oods must undergo a lengthy three-step authorization process. First, an

application or admission as a GMO product must be submitted at the national level. In the second

step the application is published and sent to the European Commission and other member states. Te

commission and member states are brieed or a three-month period; the EFSA must provide a

statement within six months. Favourable rulings by the EFSA are accompanied by regulatory

recommendations rom the GMO panel. A decision is prepared by the Commission within three

38 http://www.who.int/oodsaety/publications/biotech/20questions/en/39 http://www.google.com/books?id=rmAr4_SzQv8C





months; the decisions are le open to public comments or thirty days, which are then evaluated or

relevance.40

North America

Te United States, Canada, and other countries in the Americas have adopted a rather relaxed

regulatory approach to GM oods. Te US, or example, has allowed GM oods to enter the market

with very little regulation or labell ing. Most consumers are still unaware o the presence o GMOs in

their diet. However, as awareness o GMOs has grown so have calls or labelling and regulations o

GMOs. For example, b etween 1995 and 1997 the percentage o Americans comortable with GMOs

dropped rom 60% to 42%. Also, 81% o Americans and almost 94% o Canadians have expressed a

desire or labelling o GM products. However, their governments have resisted eorts to make GM

labelling mandatory in response to the concerns o agricultural producers who have criticized

mandatory labelling and crop segregation, which are viewed as costly and unnecessary.41 Te

reluctance to adopt stricter regulations is also based on the view that GM and non-GM crops are “like”

products despite the genetic dierences and should be treated as such.42

AsiaTe reactions to GM oods have varied greatly between Asian countries. However, most have adopted

relatively strict policies regarding the labelling and distribution o GM oods. Some Asian countries,

such as the Philippines, have begun producing GM corn. Others, like Japan have adopted strict

policies like those o the EU and Japanese companies have avoided GM products due to a ear o

public backlash against the use o GMOs.43 China is one o the leading producers o GM products and

has been at the oreront o the biotech industry; however, the Chinese government still maintains

strict regulations regarding GMOs. 44

Developing Countries

Te regulatory decisions o developing countries regarding GM products are oen linked to the

decisions o their international trading partners, especially those in the developed world. Agricultureremains a large source o revenue or the developing world and as such it is vital that developing

countries meet the saety requirements o their trading partners in order to acilitate trade. However,

pressures rom pro-GMO countries may exist to orce developing countries to adopt GM crops.

Regarding biotech developing countries stand to be the biggest benefciaries i biotech is used to

improve the nutritional content o ood, however, i biotech is used to strengthen patent laws armers

in the developing world may ace impossible obstacles to obtain seeds and continue with traditional

arming practices. As a result the agricultural sector in the developing world may all prey to an

agricultural market centralized around a handul o giant biotech frms.45

40 http://ec.europa.eu/ood/ood/biotechnology/harmonisation_o_controls_en.htm41 http://ec.europa.eu/agriculture/publi/gmo/gmo.pd 42 https://www.cbd.int/doc/articles/2003/A-00480.pd 43 <http://www.geneticallymodifedoods.co.uk/international-trade-gm-oods.html>.44 http://www.geneticallymodifedoods.co.uk/international-trade-gm-oods.html45 http://www.unctad.org/en/docs/itcdtab30_en.pd





Possible Solutions

Any international standards or GMOs must take into account the incredible variability o current

national GMO policies. As a result compromise is necessary to ensure that all countries are allowed to

take actions to protect their citizens and biodiversity without unairly limiting trade. Following are

suggestions o measures that could be taken to achieve these goals:

• Measures could be taken to separate non-GM oods rom GM oods and to ensure that GM

oods are labeled at all levels so that the decision to consume GM oods lies at the consumer

level rather than the government level.

• Guidelines could be created or the research that must be done and the type/amount o data

that must be obtained in order to determine whether or not GM ood products are sae or

consumers. Specifc timelines could be adopted that will determine the amount o time given

or research aer which countries that ban GM oods must present conclusive data

confrming the dangers o GM oods or relax regulations on GM imports.

• Also, the dangers o accidental genetic mixing with native crops must be taken into account as

it relates to armers in the third world who have received GM seed rom pro-GM countries

but rely on trade with anti-GM countries.

• Also, the dangers o trade domination and increased dependence o developing nations on

developed nations must be taken into account and measures implemented to prevent such

occurrences.

• Te role o consumer rights should be evaluated to determine the extent to which consumers

have the right to know the biological origins o their ood and how such rights should be

recognized in regards to GM oods.

• It is necessary to determine whether or not the current regulations regarding the trade o

GMO oods alls under the protections o the SPS or B agreement regarding the right o

countries to restrict trade in order to achieve other policy goals.

• Te extent to which the precautionary principle can be used to limit and restrict trade must bedetermined.

• Te protections o SPS or B could be extended to protect restrictions based on

precautionary actions to protect human health. Also, the desires o consumers to protect

themselves rom suspected dangers regarding ood saety could also be taken into account

and placed under the protection o SPS or B guidelines.

• Also, the role o GM oods in ood aid packages against the wishes o recipient countries

should be taken into account and either banned or ethical reasons or supported due to the

lack o conclusive evidence against GM products.

Discussion Questions1. Do consumers have a right to know the process through which their ood was produced? Is

the consumer’s “right to know” a suitable justifcation or trade limiting regulations?

2. How will restrictions to GM technologies, including labeling, aect international trade? How

can these eects be limited? 3. Is “substantive equivalence” a suitable method o determining “like” products? I not, how

should “like” products be determined?





4. Is the precautionary principle a suitable basis or regulating GM oods? o what extent and

or what duration is use o the precautionary principle suitable?

5. How should the WO approach other international agreements, such as the Biosaety

Protocol, that may be interpreted as justiying limitations to the trade o GM products? 6. I international harmonization is not possible to what extend can countries exceed

international regulatory standards in their domestic policies? 7. In the development o GM ood guidelines is there an acceptable amount o GM

contamination in “GM-ree” ood? I so, what is that tolerance level? Glossary

Genetically modifed organisms — Organisms whose genes have been altered to include avourable

traits that do not occur naturally. In contrast to selective breeding, which has been done or centuries

these crosses occur at the DNA level, meaning genes or a avourable trait rom one organism are

inserted into the genome o another organism so that subsequent generations will exhibit the desired

trait. Genes can be taken rom other species (e.g. fsh genes inserted into tomatoes to improve cold

tolerance). Currently, only GM plants have been approved or human use, however GM animalproducts are in the works.

Precautionary principle — A method o policy making based on proactive regulations. Te

precautionary principle is used when there is reason to believe something may be unsae but

insucient data is available to prove the risk. Tese policies are meant as precautions against

unknown risks.

Substantive equivalence — Reers to the act o evaluating products based on the physical dierences

or lack thereo between two products. Te process that went into creating these products is not

considered. Substantive equivalence is the basis or many o the laissez-aire policies o pro-GMO

countries. Because the physical products are considered equivalent labels are not considered

necessary because like-products must be handled the same way.

Additional Resources

http://www.globalissues.org/issue/188/genetically-engineered-ood

Provides a quick summary o the main issues surrounding GM ood.

http://www.who.int/oodsaety/publications/biotech/20questions/en/

Answers some o the basic questions regarding the saety concerns surrounding GM oods.

http://www.wto.org/english/tratop_e/sps_e/sps_agreement_cbt_e/c8s1p1_e.htm

Brie summary o the GMO trade conict rom the perspective o the WO.

http://www.wto.org/english/tratop_e/sps_e/sps_agreement_cbt_e/c8s2p1_e.htm

Brie summary o the uses o the precautionary principle in trade regulations.

http://www.cid.harvard.edu/cidtrade/issues/biotechnology.html

Provides a summary o the current conicts regarding biotechnology.





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