MEMORANDUM SUBMITTED BY ADVANTA SEEDS
UK LTD (G 1)
BACKGROUND ON
ADVANTA SEEDS
UK
1.1 Advanta Seeds UK Limited ("Advanta
UK") is a wholly-owned subsidiary of Advanta BV ("Advanta"),
a company registered in the Netherlands. Advanta is also the holding
company of Advanta Seeds Inc, a company registered in Canada.
1.2 Dr David Buckeridge is responsible for
Advanta's European Operations. The General Manager of Advanta
UK is Mr Mike Ruthven.
1.3 Advanta UK is primarily a plant breeder
using classical methods. It is also involved in the UK Government's
farm-scale field trials of selected GM crops and is fully committed
to the Supply Chain Initiative on Modified Agricultural Crops
(SCIMAC) code of practice. It sells no GM products in Europe.
REQUESTS FOR
ACTION
2.1 It is a matter of serious regret that
these issues, which industry has warned about for some time, have
not been adequately addressed by the regulatory authorities to
date. Early political action to create a comprehensive regulatory
framework would have at best prevented this incident from occurring
or at worst managed public expectations about seed purity and
averted further media hysteria. It is essential that this regulatory
framework be created with no further delay. At a minimum, thresholds
for accidental GM impurity need to be set, standard testing methods
need to be stipulated and results should be analysed by an approved
and consistent statistical method. The regulations should provide
these details.
1. Seed Purity, GM impurity thresholds for
seeds and the lack of regulation
3.1 Seed production is carried out in open
fields and absolute guarantees of seed purity have never been
possible. Since they were first introduced in 1963, seed purity
regulations have successfully kept varietal and other impurities
to a fixed maximum level, usually no more than a few per cent.
The same approach has been taken to the maximum permitted level
of certain GM material (1 per cent) in food labelled as GM-free
under European law. Trace levels of GM impurities will occur now
that various parts of the world have accepted the value and safety
of GMOs. This is universally recognised, including by Michael
Meacher in his recent statements to the House of Commons.
3.2 Under UK and European law, no regulations
currently exist for a maximum accidental GM content for conventional
seed batches, leaving the seed industry in an impossible position.
Seed industry groups have long pressed Government and the European
Commission to establish such regulations. The incident is proof
positive that despite strenuous efforts to maximise seed purity
and despite full compliance with seed purity regulations, seed
can enter the UK market with trace levels of impurity.
3.3 It is worth noting that even though
the problem has been at the centre of media attention since the
middle of May, and known about by Government since the middle
of April (or possibly even earlier, given that the first industry
meeting with the European Commission took place on 11 October
1999 and with the French Government in November 1999), at the
time of writing there are still no regulations at either a national
or EU level.
3.4 Fearing an apparent lack of appreciation
of the timings of harvest and planting, Advanta UK urged the Minister
of Agriculture to take action on threshold regulations when it
was finally granted a meeting with him on 1 June. It is lamentable,
with harvest of Winter Oilseed rape only days away, and planting
of the new crop starting at the beginning of August, that regulatory
guidance is still non-existent.
2. Communications Problems
4.1 From our perspective, the incident also
serves to demonstrate that communication of the facts, allowing
individuals to make informed decisions, is virtually impossible
in our society today. This is especially true where the subject
matter is highly technical. Advanta believes that a lack of understanding
of the basics of agriculture existed in some quarters of the Ministry
and most quarters of the media. Important technical points were
glossed over or misinterpreted.
4.2 After the Government published the issue,
it was impossible to communicate effectively with customers—a
point that convinced Advanta to set up a registration scheme for
farmers at an early stage, as much as anything for the communication
of hard facts on the event. Even then, journalists posing as farmers
plagued our free information phone service, blocking the lines
for genuine callers. In addition, pressure groups deliberately
sought to distort the facts in order to boost their position against
GM.
4.3 It is a pity that many people outside
Government seem more anxious to win the argument than to understand
the facts. We doubt whether it will be possible to frame sensible
and practical legislation in the wake of this event and strongly
suspect that this will lead to a withdrawal of certain products
from the UK market. . . yet another blow to the competitiveness
of UK agriculture.
3. Protecting the Interests of Farmers
5.1 As stated above, as soon as the issue
was made public by MAFF, five weeks after it was brought to their
attention by Advanta, it was clear that farmers would need urgent
advice on the facts of the situation and on how to handle their
crops. In fact, Advanta made this clear to MAFF in a hand delivered
memo (attached at Appendix 2 [not printed]) on 12 May, five days
before the announcement was made. Advanta communicated in writing
to all farmers, routing a standard letter through its merchant
customers (Advanta, in common with most UK seed companies, does
not sell direct to farmers and therefore does not have details
of farmer customers). Advanta received excellent help from its
merchant customers in this process. We also set up a free information
service for farmers to phone and used these combined approaches
to register all crops while we awaited Government advice.
5.2 Many farmers were very concerned about
registering in the first instance. They feared that activists
would vandalise their property and crops. We are still concerned
about being ordered by Government to hand over farmer names and
addresses. Legally, we are advised that to do so without being
ordered would breach data protection rules. We believe this is
an unnecessary step in any event, as all the acreage seems to
be tracked down. At time of writing we have 5,200ha registered
against a total sold of 4,700ha and have even gone to the lengths
of advertising in the national farming press to ensure full coverage.
5.3 The other activity at the top of our
priorities was the marketing options for the crop. Advanta had
several discussions with different food chain partners in the
days preceding the 27 May, when Nick Brown gave his press briefing
about his preference for a "plough-in". Advanta, with
the help of these partners, had devised a scheme to segregate
the crop and harvest it for export. We tried to meet with MAFF
to discuss this, but had no success. After a meeting with Baroness
Hayman was cancelled by MAFF on 23 May, we decided to put the
ideas in writing and faxed them to MAFF that day (attached at
Appendix 8 [not printed]).
5.4 The ideas were still under active consideration
according to the Baroness on 25 May (when she met industry representatives,
but not Advanta). Therefore Mr Brown's statements on 27 May about
his desire for a "plough-in" were a complete surprise.
The briefing he gave was presented as "advice", as he
recognised publicly at the time that he had no power to order
it as he knew the crops posed no threat to human health or the
environment. However, the briefing effectively removed any chance
that the crop could be taken to harvest. When the Minister gave
his "personal view", that it would be best to plough
out the crop, we knew farmers would have no alternative and immediately
decided to pay compensation. Advanta UK is still considering its
legal position with regard to the financial costs of the Minister's
unexpected remarks.
5.5 To be fair in hindsight, we believe
that segregation would have been possible but logistically complicated.
The tiny crop area involved spread across a wide geography would
have made handling and transportation difficult. It still seems
a waste to have ploughed up a crop that presented no risk to health
or the environment. Ironically, the German crop (an even smaller
area) has been segregated and will be used for fuel.
5.6 We presented plans for compensation
to farmers at a meeting with Mr Brown and others on 1 June. We
wrote to farmers immediately explaining that payments would be
calculated by independent advisors and in consultation with farmers
unions. One month later we had agreed settlement rates and the
unions supported these. We continue to work on the logistics of
getting the payments made and acknowledge the key role farmers
unions have played in helping us to tackle this quickly.
4. The Need for Urgent Regulation
6.1 Regulations are needed. Throughout this
issue and indeed from the earliest communications with the European
Commission in October 1999, the industry has pressed for regulations.
As we made clear to the Minister of Agriculture on 1 June (company
minutes of the meeting attached at Appendix 9 [not printed]),
we need to decide on tolerance thresholds (as we have done in
food) and we need clear testing protocols. This is so that farmers
and regulators can be assured that a standard achieved by one
company is directly comparable to that achieved by another. Also,
so that seed companies can know that expensive testing programmes
that they will be forced to implement will be "spot checked"
by governments using similar statistically valid analyses.
6.2 This brings a close analogy to food.
We have listened to reports of food retailers who claim to sell
GM free food. We have no idea what testing methods they use or
whether their sampling techniques are sufficiently robust to substantiate
their claims. We have heard that they test "to the limit
of detection". We see this as extremely misleading to the
public since the products clearly cannot be guaranteed to be GM
free. Once again they are operating in an environment where regulations
lack precision. Presumably because these companies are doing what
the pressure groups want they are not scrutinised with anything
like the same vigour.
5. The issue of thresholds for GM impurities
in Seeds
7.1 If thresholds are to be set we believe
that the question of why we need them should be addressed rationally
(we have already concluded that the current climate makes this
impossible). Nevertheless, as we see it, there is no case for
thresholds based on safety to the environment or health. In this
incident ACRE, FSA and English Nature confirmed this opinion.
7.2 One issue of particular concern was
the risk that the crop could cross-pollinate other rape crops.
Shortly after the Government's announcement of the issue, the
Minister said that the crop was sterile, and this caused consternation.
How could a crop that had cross-pollinated in Canada not do so
in the UK? The Minister was substantively correct. Officials asked
us for a technical answer immediately after his statement so that
response could be put in the Commons library. We replied the same
day, and would be pleased to repeat this explanation to the committee
(diagrams are attached at Appendix 4 [not printed]).
7.3 Advanta believes the decision on acceptable
levels should be an issue of seed quality. This is exactly the
conclusion that we believe the Government reached when it decided
the event in question should be handled by MAFF rather than DETR
(we were informed of this on 9 May). We do believe that there
is also an issue of choice which makes it appropriate to ensure
levels are at a minimum and seed is as pure as possible. In other
words, precisely the same labelling issue we have seen in food.
Consistent with the threshold for GM content
in "GM-free" food, Advanta UK believes the threshold
limit for accidental GM seed impurity in batches of conventional
seed should be 1 per cent. We believe that tests to confirm this
level can be done accurately with a high degree of statistical
certainty, within a timeframe that will allow the turnaround of
seed between harvest and sowing, while at a cost that is affordable
to UK agriculture. We make these points because it is vital for
the UK farming sector, and for ordinary consumers, that whatever
threshold is agreed is reasonable, affordable and consistent for
both authorised and non-authorised genetic events.
7.4 The evidence from Friends of the Earth
in the previous report of this committee amply demonstrates that
sweeping statements are being made in areas of intense technical
complexity. Here they stated that testing could allow the detection
of levels as low as 0.001 per cent. We would like to comment in
our evidence as to why we see 1 per cent as a sensible level.
However, as an example, we have calculated that in order to provide
approaching absolute statistical certainty that an impurity level
was at the 0.001 per cent level in the seed that Advanta is preparing
for sale next year in Europe, we would need to test somewhere
in the order of 9 billion seeds.
7.5 In the attachments (Appendix 6 [not
printed]) we show the sample sizes that are required in order
to give statistically valid test results at various levels of
contamination. If the committee desires, these can be explained
in more detail on 18 July.
6. Can thresholds be achieved?
8.1 We believe that realistic thresholds
can be achieved by the industry, but these may need to take into
account the crop species and hybrid vs non-hybrid seeds. Existing
seed regulations already do this and there is no reason why GM
purity regulations could not do the same. Obviously one of the
key issues will be separation distances and this was a great talking
point in the incident under review. We were surprised at the apparent
inability of Government to answer what we regarded as fairly obvious
reasons for the difference in the separation distances which existed
for the hybrid crops in question and for the SCIMAC trials.
8.2 We have included attachments (Appendix
5 [not printed]) to try to explain the key differences and will
readily reiterate these to the committee. Where GM has been released,
wide separation distances can help to create absolute minimum
levels of GM impurity (as in this case, less than 1 per cent).
They cannot guarantee zero impurities and have never been designed
or claimed to do so.
7. Standard testing processes and protocols
for GM impurity in seeds
9.1 The testing method most commonly used
in the food industry is the Polymerase Chain Reaction (PCR) test,
which is a DNA-based methodology. It was just such a PCR test,
at a government laboratory in Germany, that first brought to light
the incident in question. An alternative test method, which is
also used in Herbicide Tolerant (HT) GM detection, is bio-assays
such as a "blotter test" or a "spray test".
However, these tests take 10-14 days and 3-4 weeks respectively
to produce results, whereas a PCR test can be completed more rapidly.
Seed companies face extremely short turnaround times between harvest
of one crop and the sowing of another (particularly in the UK
with its large percentage of autumn sown crops). For this reason,
Advanta is of the view that the PCR test has to be adopted as
the standard methodology for assessing compliance with regulations
on GM impurity in conventional seed.
9.2 At various times, many commentators
(including independent scientific journals, officials of DETR
and publications from MAFF) have noted the tendency of these tests
to give unreliable results if protocols are not robust. It was
the known frailty of the test that led Advanta initially to be
sceptical about the German results. Only after conducting confirmatory
tests and sending its own scientists to audit the methods and
procedures of alternative labs did it feel confident to accept
the findings.
9.3 Furthermore, another disadvantage of
the PCR method is that it is essentially qualitative, testing
only for the presence or absence of substances that may indicate
GM contamination. Various alternative approaches have been pursued
to allow the quantification of any results that indicate a positive
presence. Advanta believes (after a thorough assessment of these
methods in the course of deciding what it will do for next year's
crop) they can be used to assess the quantity of a GM impurity.
However data will only be valid if seed samples are of an appropriate
size for the threshold level being sought and the test is replicated
so the sample can be shown to be representative of the whole seed
batch. Advanta would be disappointed if the Government had not
already made similar assessments itself, but if not, would be
pleased to share its conclusions in order to speed up the process.
8. UK Chronology and Key Facts
10.1 There has been considerable Parliamentary
interest in the events that occurred leading up to and after Advanta
UK went to the Government for advice and guidance on this issue.
At this stage, Advanta UK believes that time would be more constructively
spent on analysing the regulations and on framing workable rules.
10.2 The event has put our reputation with
our merchant and farmer customers under considerable strain. Our
employees have been physically and mentally exhausted and have
been forced to endure unacceptable levels of stress as a result
of the incident.
10.3 Financially, we will spend several
million pounds in order to settle compensation payments. Now our
priority is twofold:
— to rebuild the relationships with
our customers and the morale of our staff;
— to co-operate in the framing of regulations
by contributing our experience, so that lack of guidance can never
put us in this invidious position again.
10.4 Nonetheless, we understand the committee
may wish to understand the events that occurred. The company believes
that it has broken no laws or regulations and that it has acted
swiftly, openly and responsibly from the moment the incident in
question was first brought to its attention. We have included
a chronology below that is extracted from our detailed files that
we have kept on the whole event. Each entry is supported by written
minutes made at or soon after the date of the meeting or contact.
10.5 This chronology should be read in the
context of four key facts:
(1) The potential problem was highlighted
by industry but the regulatory authorities failed to adapt the
regulatory framework in time to manage the incident in question
adequately.
(2) Less than 1 per cent of the Advanta UK
Spring Oilseed Rape seeds planted in this country contained GM
material. The area of crop with the impurity represents only 1
per cent of the UK rape acreage. The incident in question therefore
constitutes a trace impurity in a tiny fraction of a conventional
UK crop.
(3) Advanta UK, the UK Government and its
advisory bodies (FSA, ACRE and English Nature) are all convinced
that this trace impurity of GM in what is a conventional crop
poses no threat to human health or the environment.
(4) The UK Government has made it clear that
no regulations or laws have been broken at any time by Advanta
UK.
10.6 1998
The affected seed batches were grown during
1998 by Advanta Inc in Alberta, Canada for import to the UK under
the OECD seed certification scheme. For its conventional hybrid
crops, Advanta Inc's minimum separation distance from GM crops
(1,600 metres) is twice the distance required by Canadian law
(800 metres). In reality, the actual separation distance in the
relevant year was never less than five times the legal minimum,
namely 4,000 metres, and this was the de facto minimum separation
distance for Advanta Inc. At no time did Advanta Inc have any
reasonable grounds to suspect that accidental contamination of
its hybrid crops might have occurred.
10.7 1999
As the use of GM crops in North America increased
(in 1998, 35 per cent of Canadian crops were GM, in 1999 the figure
rose to 55 per cent), so in early 1999, on the basis of precaution
rather than any suspicion of possible contamination, Advanta Inc
decided to shift Hyola production to GM free areas such as Montana,
USA, New Brunswick, Canada and New Zealand. As a result, there
is no GM impurity in the 1999 harvest of Spring Oilseed Rape seeds
delivered to Europe.
10.8 2000
Friday 31 March 2000.
Late afternoon, Herr Petersen, agent of Advanta
UK in Germany, received a phone call from German Government official.
10.30 pm, phone message left by Herr Petersen
for Advanta UK about possible, low-level (less than 1 per cent)
GM presence in conventional Hyola 401 Spring Oilseed Rape from
the 1998 harvest, discovered by a laboratory in Freiburg, Germany,
using PCR tests.
Monday 3 April 2000.
Efforts made to obtain further details on harvest
year, lot numbers, etc, to see if UK batches of seed were affected;
discussions about the reliability of the PCR test method; agreement
to halt sales of Hyola 401 in Germany on a precautionary basis.
Tuesday 4 and Wednesday 5 April 2000.
Confirmation that Hyola 401 of 1998 harvest
affected; further tests commissioned from a separate German laboratory
to back up original results on Hyola 401 and to investigate possible
contamination of Hyola 38 and Hyola 330 from the 1998 harvest
because they were grown in the same region of Canada.
Thursday 6 April 2000.
All sales of Hyola 401 from 1998 and 1999 harvests
halted in the UK on a precautionary basis (1999 harvest subsequently
proven to be clear).
Wednesday 12 April 2000.
7.31 pm, new information arrives by e-mail from
Canada on Hyola 38 and Hyola 330 from the 1998 harvest; impurities
detected in preliminary bio-assays.
Thursday 13 April 2000.
Advanta UK meets with its lawyers (advice privileged);
new information from Canada reviewed; decision taken to halt all
sales of Hyola 38 and Hyola 330 from the 1998 harvest.
Friday 14 April 2000.
On legal advice (privileged) and through an
industry body, Advanta UK requests meeting with UK Government;
Advanta UK drafts a press release (attached at Appendix 7 [not
printed]) in anticipation that Government will want to make an
immediate public statement on 17 April.
Monday 17 April 2000.
First meeting between Advanta UK and MAFF and
DETR officials; briefing document tabled (Appendix 1 [not printed]).
Tuesday 18 April 2000.
Advanta UK advised that GM contaminated plants
almost certainly "male sterile"; Advanta UK prepares
a purely reactive press statement, given the advice from DETR
and MAFF officials; FSA calls Advanta UK to follow up the meeting
with DETR and MAFF officials.
Wednesday 19 April 2000.
Advanta UK calls DETR and MAFF to tell them
that the GM contaminated plants are almost certain to be "male
sterile"; DETR says that "Ministers have been informed
about the incident, that eyebrows were raised and that there was
no widespread panic"; MAFF Seeds Division says that there
are "no further issues for it to investigate".
Monday 24 April 2000.
Advanta Inc calls from Canada with the final
test results.
Tuesday 25 April 2000.
Advanta UK advises DETR that about 90 per cent
of the GM contaminated plants were resistant to Roundup and about
10 per cent to Liberty, which tallied with its understanding of
the 1998 Canadian commercial GM crop; the 1999 crop is clear and
the contamination of the 1998 crop is below 1 per cent.
DETR tells Advanta UK that they do not need
any more information from the company, that the Department has
written legal advice that no offence has been committed, that
no further action will be taken, that DETR will write to the European
Commission to request proper regulation and that Michael Meacher
is on holiday all week.
Wednesday 26 April—Monday 8 May 2000.
Series of phone calls, carefully minuted by
Advanta UK, between the company and officials; officials expressed
concern about possible leaks.
Tuesday 9 May 2000.
DETR advises Advanta UK that MAFF is now playing
the lead role; MAFF advises that a press statement will be necessary,
probably on Thursday 18 May, and that a meeting between officials
and industry groups (not Advanta UK) is to be held on Friday 12
May.
Friday 12 May 2000.
Industry representatives meet with officials;
Advanta UK not present but submits a document setting out a series
of questions that Government needs to answer before the matter
enters the public domain (attached at Appendix 2 [not printed]).
Monday 15 May 2000.
Advanta UK's distributor in Sweden discovers
some contaminated seed has been sown there; the distributor informs
the Swedish Government and then Advanta UK; Advanta UK informs
MAFF.
Tuesday 16 May 2000.
Swedish Government issues press release.
Wednesday 17 May 2000.
MAFF issues press release; Advanta informed
about press release one hour in advance of publication.
Thursday 18 May 2000.
Information pack sent to seed merchants who
are Advanta UK customers.
Monday 22 May 2000.
Advanta UK informed that planned meeting with
Baroness Hayman had been postponed; Advanta UK's free information
helpline for farmers set up.
Tuesday 23 May 2000.
Advanta UK proposes an independent panel on
farmer compensation to Baroness Hayman by letter.
Thursday 25 May 2000.
Seed industry and related bodies meet with Baroness
Hayman (Advanta UK not present).
Saturday 27 May 2000.
Nick Brown announces to the media that he wants
a "plough in" (although he recognised publicly at the
time that he had no power to order it as he knew the crops posed
no threat to human health or the environment).
Thursday 1 June 2000.
Advanta UK meets with Nick Brown and Baroness
Hayman; Advanta UK reiterates its compensation proposal (company
minutes of the meeting attached at Appendix 9 [not printed]).
Friday 2 June 2000.
Advanta UK press release announces the compensation
proposal, including the independent panel.
Thursday 8 June 2000.
Opposition Day Debate on the incident in question;
European Commission confirms Area Aid payments available for ploughed-in
crops.
Wednesday 5 July 2000.
Advanta UK issues press release, less than five
weeks after it was set up, announcing that the independent panel
has agreed a compensation package for all farmers affected, with
the agreement of the NFU.
9. Other Key Issues
SEPARATION DISTANCES
11.1 The incident in question raises legitimate
questions about the separation distances that should exist between
GM and conventional crops to prevent unwanted cross-pollination
from the GM plants, particularly in relation to the existing farm-scale
field trials of selected GM crops.
11.2 It must be stressed that many different
factors, of which separation distance is only one, affect whether
cross-pollination will occur in an open field setting. These different
factors include the respective times of flowering of the two crops,
wind direction, species compatibility and the lifespan of the
pollen itself. Nevertheless, given a particular set of circumstances
it is possible to make a rough calculation of the likely separation
distance needed to achieve a given de minimis GM impurity level
in a nearby conventional crop.
11.3 Advanta UK is of the view that it is
correct to keep under review the separation distance in any setting
where cross-pollination between GM plants and conventional plants
is not desired. However, the incident in question is of a very
different nature from the UK Government farm-scale field trials,
and the company has no firm view on the appropriate separation
distances for these trials.
CROP STERILITY
11.4 One of the concerns raised by the incident
in question, before farmers were assured of compensation and began
to plough-in the affected crops, was the theoretical risk of cross-pollination
from the tiny number of GM plants in the affected fields once
these plants had flowered.
11.5 For technical reasons, and assuming
that some of the affected crops had come to flower, the chances
of any of the GM plants becoming fertile and therefore capable
of producing pollen were very small indeed. All of the GM plants
concerned were hybrid specimens and were "male sterile"
plants. They could only have been rendered fertile if a "restorer
gene" in pollen from a crop of the same species had been
transmitted to them. While this possibility can never be ruled
out in an open environment, the chance of this happening was minuscule.
11.6 For further explanation of the technical
aspects of hybrid crop fertility, please see the company's statement
and diagrams, attached at Appendices 3-5 (not printed).
COMPENSATION
11.7 Advanta UK, while not admitting legal
liability for the incident in question, has from the outset been
concerned that its ultimate customers, the farming community,
should receive adequate compensation for any economic losses suffered.
11.8 Advanta UK strongly supported the successful
application to the European Commission for Area Aid payments to
be made to farmers inadvertently growing Spring Oilseed Rape from
contaminated seed despite the affected crops having been ploughed
in. In addition, Advanta UK, with the support of Government and
the National Farmers Union, created an independent panel to advise
on the compensation necessary to supplement the Area Aid payments.
11.9 This panel has now completed its work,
less than five weeks after it was created. Advanta's offer of
compensation has been agreed by the panel and endorsed by the
National Farmers Union as fair and equitable. The sums offered
by Advanta are £337 per hectare south of a line between Carlisle
and Newcastle and £370 per hectare above this line, reflecting
the likely higher yields of Spring Oilseed Rape in Northern England
and Scotland.
ECONOMIC THREAT
TO FARMING
11.10 Although Spring Oilseed Rape is a
small crop in the UK, and the level of contamination was small,
this incident has potentially serious implications for all other
crops. Unless reasonable regulations are put in place to ensure
that GM impurity in conventional crops is kept to a fixed threshold,
and unless reasonable testing processes and protocols are created
for demonstrating that compliance has been achieved, then seed
producers and in turn farmers and ordinary consumers will face
enormous costs and uncertainty.
11.11 In the case of Spring Oilseed Rape,
a failure to tackle the regulatory loophole may mean this seed
not being available at all in the UK.
10 July 2000
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