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Volume 14 // Number 2 // Article 3
Risk of Regulation or Regulation of Risk? A De Minimus Framework for Genetically Modified Crops
Tim Durham
Florida Gulf Coast University
John Doucet
Nicholls State University
Lori Unruh Snyder
Purdue University
The precautionary principle places an impractical onus on science to demonstrate the absolute safety of genetically-modified (GM) crops. Conversely, traditionally bred articles receive little, if any, regulatory attention. Procedurally, GM certainly has the potential to create end products with deleterious (and thus regulatory actionable) characteristics. However, such risk is ultimately embodied in the end product and not the methodology, per se. Our proposal emphasizes a trait-based, end product model over the method-centric model. Using a de minimus framework, we propose a pragmatic, science-based rubric to assess GM crops. De minimus is designed to minimize regulatory bottlenecks for articles exhibiting nominal risk commensurate with antecedence, while reserving the amenities of precaution for those with an evidently higher risk index. Although GM may pose unique regulatory challenges, it is important that the regulation of risk not turn into the risk of regulation.
Key words: antecedence, biotechnology, cisgenic, de minimus, genetically modified, precautionary principle, regulation, transgenic.Introduction
The Green Revolution was a watershed moment in agriculture and dramatically improved global food security. Unfortunately, this milestone foreshadowed future environmental costs, specifically, the overuse of pesticides, non-target effects, pest resistance, and environmental degradation.
One tool proposed to remedy these externalities is the use of genetic modification (GM). GM involves the precise transfer of DNA with advantageous traits from one organism to another. Typically these traits are agronomic in nature, though future developments are envisioned to be consumer oriented.
Proponents charge that GM is favorably positioned to be the new standard-bearer of crop improvement. Statistics appear to verify that claim: Since 1996, GM crops under cultivation have increased to over 1 billion hectares (James, 2010).
The adoption of GM is among the most rapid in history. Despite these statistics, the tenor among stakeholders is far from a consensus. Many skeptics are dismissive of the "gene revolution" and believe that such genetic interventions irrevocably alter crop physiology and by proxy, haphazardly introduce novel health and environmental risks. What has ensued is an often acrimonious debate on the appropriate level of regulatory rigor to comprehensively identify, quantify, and manage these risks.
Certainly, scientific and technological strides invariably bring risks to consumers and the environment (Sinclair, 1971-1972). Contemporary risk managers must demonstrate that they are reducing, mitigating, or minimizing a particular risk (Powell, 2000). Historical episodes such as the Starlink corn controversy have eroded trust in science and caused stakeholders to openly question the regulatory apparatus that links science to the consumer (Fox, 2001). In the face of an increasingly anxious and risk-averse populace, is current regulation adequate?
Current Regulation
This question evokes a fundamental difference of opinion between policymakers. In the United States, two doctrines known as familiarity and substantial equivalence prevail. Under these principles, the traits, usage, and field performance (familiarity), as well as biochemical composition (substantial equivalence), are expected to be comparable to their traditionally bred kin (antecedence). In essence, these criteria are performance based, with the characteristics of the end product determining the regulatory treatment. If the end product parallels an existing product that is generally regarded as safe (GRAS), it is deregulated and cleared for commercial planting.
Conversely, the EU policy is more prescriptive. Here it is argued that the GM methodology creates intrinsic novelty prima facie, even if the end traits are identical to those generated through traditional means. In this instance, it is reasoned that the novelty inherent in the generative process justifies additional scrutiny.
Familiarity, substantial equivalence, and antecedence appear to present a relatively straightforward and convenient baseline to evaluate GM crops. In practice, such crops elicit significantly more attention than their traditional counterparts. Curiously, this is readily apparent in the United States, despite the ostensible application of an objective, trait-based assessment.
Thoughts On Reform
From its inception, GM has been the most heavily regulated crop improvement innovation in history. Given a long and successful history of cultivation, the technology appears to be at a crossroads. Many have suggested the time is appropriate for deregulation, though no consensus exists on the mechanism. Vasil (2003) recommended the relaxation and gradual elimination of oversight on GM crops that have met all regulatory requirements and been cultivated for five years. He further suggested that, barring any extraordinary risks, GM crops with previously field-deployed genes should be exempted from regulatory requirements after two years.
A 2009 white paper released by the Czech Academy of Sciences proposed a number of regulatory enhancements, including: (a) the replacement of the precautionary principle (PP) with a science-based standard; (b) an outcome rather than process based evaluative framework; and (c) risk and economic assessments based on parallel technologies, e.g., antecedence (Sehnal & Drobnik, 2009).
In addition, it has been argued that a regulatory distinction (Jacobsen & Nataraja, 2008; Schouten, Krens, & Jacobsen, 2006a, 2006b) should be made between cisgenics, the direct genetic transfer between sexually compatible donors, and transgenics, genetic transfer between taxonomically distant species.
A De Minimus Regulatory Framework
The regulatory encumbrances faced by GM crops are formidable. Despite this, a cursory review of statistics indicates a promising, if deceptive, yield. As of 2005, the US Department of Agriculture's Animal and Plant Health Inspection Service had received 11,600 applications for field trials. These encompassed a number of broadly grouped trait families, including insect resistance, herbicide resistance, improved product quality and agronomic quality, and virus resistance. Of those, nearly 10,700 (92%) had been approved. However, only 63 of 103 petitions for full deregulation were granted (Fernandez-Cornejo & Caswell, 2006). This represents an effective yield of 0.6% of the original field-approved cohort. As of 2010, the number of deregulated articles had marginally increased to 89 (CERA, 2010). A fraction of those have been commercialized. These numbers are dwarfed by output in the traditional breeding sphere, where varieties are cleared with little, if any, regulatory attention. In this regard, they are implicitly granted de minimus status. In effect, the likelihood of harm is deemed so infinitesimally small that regulation would yield no measurable benefit to society.
Bureaucracy represents a significant bottleneck to innovation and diffusion. Indeed, is it widely agreed that the current regulatory climate places an impractical onus on science to demonstrate the absolute safety of GM crops. Despite the novelty of certain traits, it is interesting to note that many of the ascribed risks are entirely reproducible with antecedent methods. This reality necessitates a workable solution to an obvious policy dilemma: the disparate regulatory treatment afforded to GM crops, despite a similar suite of ecological and human health effects.
In this manuscript we synthesize a number of the aforementioned policy reforms with our own. Firstly, regulators should adopt a method-agnostic approach, and focus on relevant ecological and biochemical characters of the end product. Moreover, any risks associated with GM should be assessed relative to their antecedent peers. This demands a performance-based framework to replace the prescriptive, one-size-fits all approach. Moreover, the precautionary principle, as invoked in the current regulatory scheme, is scientifically indefensible. It should be replaced with a flexible de minimus approach, which avoids the allocation of resources to address negligible risks for nominal or nonexistent gains in safety. In addition, we believe that current regulations place an acute overemphasis on hypothetical (and often unmeasurable) risks, while downplaying the advantages. In effect, this accentuates the what-if scenarios of the risk assessment calculus at the expense of demonstrable benefits. It is critical that the latter receives appropriate weight in the decision-making continuum. Indeed, Connor, Glare, and Nap (2003) suggested a regulatory reform that would juxtapose the costs of inaction with the costs of action. We believe that such an inclusion, though difficult to encapsulate in the risk evaluation equation, is a critical consideration.
Technology Assessment, The Precautionary Principle, and De Minimus Risk
Technology assessment (TA) is an interdisciplinary field that focuses on a concrete problem, specific technology, or perceived problem. The ultimate goal of research is to standardize a system that enables regular updating of information on diffusion and adoption of technologies and their impact on environmental outcomes (WARDA-The Africa Rice Center & Consultative Group on International Agricultural Research [CGIAR], 2003). Based on the long-term uncertainty factor, GM is often identified as a problem-induced phenomenon.
With that as a procedural guide, specific risk assessment methodologies broadly attempt to quantify the following three questions: What can go wrong? How likely is it to happen? What are the repercussions if it does happen?
In the policymaking arena, the deliberative approach has its foundations in the precautionary principle. For context, it is helpful to refer to the EU definition, which states that: "In order to protect the environment, a precautionary approach should be widely applied, meaning that where there are threats of serious or irreversible damage to the environment, lack of full scientific certainty should not be used as a reason for postponing cost-effective measures to prevent environmental degradation" (EEA, n.d.).
In some respects, the precautionary principle has merit because it encourages the deconstruction of risk. Conversely, lack of full scientific certainty is frequently used as a pretext for postponing risk, effectively relegating GM to abstract conceptualizations or field trials in perpetuity. Such a doctrinaire posture is self-defeating in practice. Holm and Harris (1999) argue that the PP biases the argument towards irrational caution, even in the presence of contravening evidence.
Interestingly, a rarely invoked secondary EU definition offers explicit leverage in the policy arena, stating that: "The precautionary principle permits a lower level of proof of harm to be used in policy-making whenever the consequences of waiting for higher levels of proof may be very costly and/or irreversible" (EEA, n.d.). This language offers a proviso, explicitly acknowledging that the risk of inaction may far outweighs the risk of action. In essence, if payback exceeds adversity, then a countervailing approach to decision making should be adopted.
The principle of de minimus risk offers a reasonable counterweight to the overly zealous application of the PP. It conveys a simple philosophy: that the regulation of risk should exhibit a standard of congruency and proportionality. In other words, regulatory entities must demonstrate that their approaches are congruent with and proportionate to the problem they seek to address. Speaking on the issue of risk management, Comar (1979) stated that de minimus can "…focus attention on actions that can effectively improve health and welfare and at the same time avoid squandering resources in attempts to reduce small risks while leaving larger ones unattended."
A Working Model
The validity of any technology assessment requires the development of measurement standards to allow for objective and systematic comparisons (Jannsen, 1994). In the absence of direct experience, the most appropriate guide for GM risk assessments are breeding antecedents. As previously discussed, antecedence simply refers to a preexisting modality of crop improvement. Such methods may involve cloning, induced mutagenesis and selection, chromosome doubling, protoplast fusion, grafting, embryo rescue, and microspore culture, among others. According to EU Directive 2001/18/EC (Publications Office of the European Union, 2001), many of these breeding techniques constitute GM sensu lato, though more ubiquitous techniques are explicitly exempted from oversight.
Using antecedence as a risk index, a de minimus framework can be constructed to rapidly evaluate GM crops while exercising regulatory parity with their conventional equivalents. Conceptually, this approval stream is similar to the expedited "reduced risk pesticide" framework promulgated under the US Food Quality Protection Act (FQPA) of 1996.
Candidate assessment is based on five criteria: (a) taxonomic distance (cisgenic or transgenic), (b) antecedence, (c) familiarity, (d) substantial equivalence, and (e) the costs of inaction.
Under our framework, cisgenic crops (Figure 1) are automatically conferred de minimus status. A number of authorities have made a compelling case for their deregulation, reasoning that the end products draw from the same genetic pool and are therefore attainable using conventional breeding methods. No further regulatory intervention is required. The exception would be where customary safety standards exist, such as solanine levels in potatoes.
Figure 1. Proposed framework for the regulation of cisgenic articles. Cisgenics is generally conferred de minimus status, given the intrinsic nature of the genetic material and phenotypic reproducibility with conventional breeding. The process is partitioned into three stages: risk assessment, risk management, and regulatory decision.
Alternatively, transgenics (Figure 2) might introduce truly novel phenotypes with potentially harmful characteristics. In this instance added stringency is justified. If antecedence between a GM and conventional product based on trait family is determined (Table 1), then reciprocity is established, which implies that the end traits (including the expression profile) of the GM crop are conventionally reproducible. In our view, this product then represents an antecedent familiar (Table 1). Both are envisioned to exhibit a near identical suite of ecological effects, equivalent to familiarity. Inclusion in a trait family represents a proof of concept: that the end product has no demonstrable record of ecological harm. In this instance familiarity need not be formally established because field exemplars already exist. However, comparable human health effects are not necessarily implied. Substantial equivalence would need to be assessed separately, based on a biochemical characterization.
Figure 2. Proposed framework for the regulation of transgenic articles. Given the extrinsic nature of the introduced gene(s), evaluation is a composite of multiple factors, including: preexisting gene constructs, antecedence, familiarity, substantial equivalence, and the costs of inaction. When necessary, this framework accommodates a nested conventional evaluation with potential advancement to de minimus standing.
Table 1. A selection of crops, transgenes, and their associated antecedent familiars.
We also propose that GM crops with approved traits be recognized as antecedents exemplar for forthcoming GM products. Bacillus thuringiensis (Bt) pesticidal transgenes would be a suitable example. Independent evaluation of an identical transgenic event in a separate cultivar or species would be duplicative, resource intensive, and uninformative. Since the end product has already been vetted using the existing regulatory framework, substantial equivalence and substantial equivalence would be concurrently established.
Transgenes that introduce altogether novel traits would trigger a traditional risk assessment. The end product would be compared to a non-transgenic variety developed through antecedent methods. Such candidates would be subject to a flexible battery of tests for no more than five years to demonstrate any effects on human health and the environment. A regulatory decision will then be made based on a composite of the observed risks and the costs of inaction.
Three possible outcomes are possible under a de minimus stream: (a) fast-tracked deregulation; (b) fast-tracked deregulation with prescribed risk management measures (such as non-Bt "refuges" to minimize insect resistance); and (c) a nested conventional risk assessment with potential advancement to de minimus standing, with or without prescribed risk management measures.
Comparative Risk Indices
Despite pronouncements to the contrary, current regulatory systems have not effectively reconciled efficiency with the need to be informed by science. Jaffe (2006) reported that the approval window for non-regulated status has slowed considerably from the inaugural class of GM crops, from 8.6 months between 1994 and 2005 to 15.4 months between 2001 and 2005. He further outlined why stakeholders should be concerned with the unhurried pace of approvals despite a familiarity with the technology, no demonstrated evidence of risks from existing products, fewer products to review, and most notably, products with risk profiles comparable to those already reviewed.
Based on a considerable volume of data, there is no reason to believe that GM crops pose a risk any orders of magnitude greater than their antecedents. In fact, recent work by Kogel et al. (2010) suggested that traditional breeding causes more inherent genetic variability than GM. Uwe Sonnewald, a co-author of the paper, writes, "the impact of transgenes is basically limited to their immediate function." In other words, the inserted gene behaved as a good neighbor, with precise and predictable functionality.
With cisgenics, there is considerable capacity to shorten crop development time by avoiding linkage drag, the undesirable genetic baggage that invariably manifests with a traditional breeding program. Such drag can have unanticipated consequences.
Such cannot be said for conventional methods, where undesirable outcomes have been extensively documented. For example, a disease called autogenic necrosis in tomatoes is the result of an incompatible gene bred into the species, essentially causing a condition analogous to an autoimmune reaction. The Lenape potato was found to have elevated levels of toxic glycoalkaloids(Zitnak & Johnston, 1970), an artifact of traits introgressed from wild breeding stock. Batista, Saibo, Lourenco, and Oliveira (2008) found that induced mutagenesis, a standby of conventional breeding, might induce more transcriptomic changes than transgene insertion. Similarly, using various "omic" (transcriptomic, proteomic, and metabolomic) profiling techniques, Ricroch, Berge, and Kuntz (2011) expressed the need to place pair-wise differences between GM crops and their comparators in a wider context of natural variation. Further, naturally-occurring transposable elements are known to hopscotch through genomes with relative abandon.
Interestingly, some proprietary techniques such as targeting induced local lesions in genomes (TILLING) and rapid trait development system (RTDS) deliberately induce genome disruptions as a matter of course. This introduces many genotypic and phenotypic novelties while circumventing the technical definition of GM.
A frequent question raised by GM crops is field performance, particularly their potential for gene escape and invasiveness. This is typified by the incorporation of herbicide resistance (HR) traits. It has been speculated that commingling with weedy relatives would yield hybrid progeny with a distinct fitness advantage. Weeds certainly can benefit from the acquisition of new characters via increased fitness, survival and spread if they inherit HR traits (Ellstrand, 2001). Notwithstanding the limited ecological fitness conferred by resistance to a single herbicide class, it must be recognized that antecedent familiars with HR have already been developed and released into the wider environment (Conner & Field, 1995). In the case of conventionally bred ALS-resistant (HR) canola, plants have coincidentally been found to "pollute" adjacent fields with HR genes via pollen (Rieger, Lamond, Preston, Powles, & Roush, 2002). In this instance, no regulation or special precautions were deemed necessary, despite a comparable risk index.
The intractability of the GM debate is exemplified in a recent US Supreme Court ruling that economic impacts such as reduced yields are tantamount to an environmental harm (Monsanto Co. et al. v. Geertson Seed Farms, 2010). Such rulings are puzzling, as yield drag trade-offs are commonly found in antecedent varieties bred for disease resistance (Brown, 2002). To date, no such principle has been retroactively applied. It is also questionable how the mere threat of gene flow can be used as a pretext for continued regulation, especially when the phenomenon has already been demonstrated in antecedent HR varieties.
Although not necessarily evident, the cost of inaction represents another potential risk for GM crops. For example, the insecticidal properties of Bt have been employed for decades as a formulated spray. GM varieties have been developed with the ability to produce the insecticidal protein in planta, which targets administration to pest herbivory. In addition to eliminating non-target effects, the use of transgenic soybean, canola, cotton, maize, and sugarbeet has been estimated to reduce pesticide use by 352 million kilograms of active ingredient (Brookes & Barfoot, 2010).
Rationale for De Minimus
Most fundamentally, current regulations impede the most routine exchange of genetic material, even when the source gene is from an identical species or of minimal genetic distance. For instance, after analyzing the genome of a wild species, researchers at the University of Wisconsin characterized a gene that confers resistance to potato late blight, Phytophthora infestans (Song et al., 2003). Though the trait could conceivably be bred into the standard variety, other desirable characteristics would be lost. Precision is thus a major consideration for fast-tracking.
Brevity represents a parallel rationale. Kershen (2004) recalled a dialogue with a scientist from Southeast Asia, who inquired whether he was permitted to transfer a disease resistance gene from a landrace of one species to a domesticated version of the same under the Cartagena Protocol on Biosafety (CPB). Such transfers were not permitted under current agreements. As a consequence, the scientist estimated that it would take 15 years to develop, as opposed to 6-7 years with recombinant DNA (rDNA) techniques. He commented that hundreds of thousands of the poorest societies would suffer needlessly.
Ironically, regulatory indecision can instigate the very problems risk managers seek to avoid. Weary of continual approval delays, indignant Indian cotton farmers founded a veritable cottage industry in 2001, and hybridized contraband GM seed with their own locally adapted varieties (Jayaraman, 2004). Although the Indian Genetic Engineering Approval Committee (GEAC) greenlighted Bt cotton in 2002, emboldened farmers continue to defy local authorities.
Current regulations also represent a curious paradox for the most ardent critics of GM. In many instances the costs of biosafety research and development are concentrated in the hands of those with the combined capacity for product development and costly regulatory compliance: private, multinational corporations. Crop improvement efforts are overwhelmingly proprietary and skewed toward agronomic commodities. Crops grown by the poor are effectively ignored. Predictably, it is difficult to justify investments in products with limited returns, particularly when facing indefinite delays for regulatory decisions. As a result, public-good initiatives for orphaned, underutilized, and specialty crops languish under the current framework.
Toward Regulatory Harmonization
The current regulation of GM crops requires a candid renegotiation of acceptable risk, given the broad reproducibility of similar phenotypes in conventionally-bred kin. We believe that the current approach to GM crops is fundamentally flawed, because it relies on inferential and unsubstantiated risk judgments. The current level of regulation is unprecedented: Never before has such excessive regulation been crafted to respond to (as of yet) hypothetical risks.
In particular, the precautionary principle places an impractical onus on science to demonstrate the absolute safety of GM crops. It is likely that no quantity of voluminous data, however unequivocal, will placate critics. Kasanmoentalib (1996) estimated that it would take 10 to 100 generations of data collection and analysis to thoroughly absolve a GM crop of risk. In policymaking, ten generations is a relative eternity. Appropriately, drawing from the TA questions already in practice, Connor et al. (2003) formulated a new risk assessment parameter to consider in policymaking: the costs of inaction.
GM crops are often assumed to have a higher risk index relative to their antecedent peers. Procedurally, the potential certainly exists to create end products with deleterious (and thus regulatory actionable) characteristics. However, such risk is ultimately embodied in the end product and not the generative process, per se. Reasoning that generative novelty alone justifies added oversight unfairly typecasts GM. More importantly, it is a type of a priori judgment, which lacks an empirical basis.
It is important that the regulation of risk not turn into the risk of regulation (Nap, Metz, Escaler, & Connor, 2003). Accordingly, regulatory stringency should be indexed to actual and not hypothetical risk. The de minimus approach represents an appropriate level of protection, while normalizing their regulatory treatment. If risks associated with an antecedent technology are functionally congruent and have been exempt from regulation, then a parallel technology should enjoy a comparable regime.
To date, no conceptual distinction can be made between genetic modifications of plants by classical methods or molecular techniques that introduce a modifying gene product (Anonymous, 1992). Indeed, it is arguable that the term "GM" is merely semantics, that is, a procedural descriptor with little predictive power in characterizing the end product itself. The convergence of traditional and molecular breeding has rendered the term obsolete and made strict procedural-based distinctions and disparate, two-tiered regulations increasingly irrelevant.
De minimus is interrogative, transparent, and operational. It provides a pragmatic, science-based rubric for assessment, decoupling politics and science. Most importantly, it does not impose unnecessary burdens on crop development based on unrealistic assessments of risk.
It is explicitly designed to streamline approval of crops with a nominal risk profile commensurate with antecedence. Underutilized and specialty crops could benefit substantially from such a regime. To date, it has been difficult to ascertain lack of demand or outright market rejection of these crops when regulatory uncertainty renders development uneconomical or unfeasible (Miller & Bradford, 2010).
However, we also recognize that certain transgenic crops may pose unique regulatory challenges. For those crops with an evidently higher risk index, the amenities of precaution would be preserved.
Admittedly, a risk assessment cannot claim to comprehensively identify all contingencies of a given problem. Despite the downstream uncertainties, evidentiary facts point to the safety of GM crops. Therefore, they should not have to undergo a more thorough credentialing based on generative pedigree alone.
Appropriately, it is questionable whether conventionally bred crops should be granted a brand of special policy dispensation based on perceived safety. If anything, policymakers may be remiss in underestimating the dangers of traditional breeding (Gewin, 2002). Certainly very little is known about the potential long-term health effects of any traditional food (WHO & FAO, 2000). According to the US National Research Council, we are in a more enviable position to predict the phenotypic expression of organisms modified by molecular methods (National Research Council, 1989). If the ability to predict phenotypic expression is the de facto vanguard of risk assessment, then GM crops generally represent a significant improvement in that sphere.
The alternative to a de minimus approach is a potentially stymieing policy framework that stresses a system of upregulatory harmonization. Canada has implemented such a system, where novel traits generated by traditional breeding methods such as wide hybridization are regulated alongside transgenic plants (Canadian Plant Biosafety Office, 2002). However, it is doubtful that other countries would exercise the political wherewithal to emulate this model.
To synergize a de minimus framework, we believe that cross-border reciprocity agreements (i.e., clearinghouses) would effectively partition risk assessments among nations. This is a viable mechanism to avoid regulatory duplication. It would also represent a prudent use of scarce regulatory resources, which would allow countries to focus on specific domestic issues that a GM crop might pose. To ensure consistency, it would also be prudent for individual countries to vest oversight in a single body, modeled in principle on New Zealand's Environmental Risk Management Authority (ERMA).
Application of the de minimus principle need not be plant exclusive. We also envision utility in other domains, including transgenic arthropods. An example would be the development of pesticide resistant biocontrol agents. In this case, antecedence represents the selection of pesticide resistant strains. Similarly, phenotypic expression profiles that confer a fitness disadvantage, such as engineered sterility, could also receive a low-risk regulatory treatment.
Although select GM crops may pose unique regulatory challenges, it is important that the regulation of risk not turn into the risk of regulation. Thus, the most appropriate regulatory approach for all GM crops is to evaluate the end product, irrespective of the generative methodology, and assess under a de minimus framework, while futuring the costs of action versus inaction.
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World Health Organization (WHO), Food and Agriculture Organization (FAO). (2000). Safety aspects of genetically modified foods of plant origin (Report of a Joint WHO/FAO Expert Consultation on Foods Derived from Biotechnology). Geneva, Switzerland: Author.
Zitnak, A., & Johnston, G. (1970). Glycoalkaloid content of B5141-6 potatoes. American Potato Journal, 47, 256-260.
The authors would like to thank Dr. Indra Vasil for reviewing a draft of this manuscript. We would also like to thank Trisha Dubina for her graphical expertise.
Suggested citation: Durham, T., Doucet, J., & Snyder, L.U. (2011). Risk of regulation or regulation of risk? A de minimus framework for genetically modified crops. AgBioForum, 14(2), 61-70. Available on the World Wide Web: http://www.agbioforum.org.
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Auberge Le Petit St-André
Commodités et services
- Air conditioning in all units
- Utility room
- Kitchenette in some units
- Establishment only non-smoking
- Internet
- On-site catering: Breakfast
- Reception hall, meeting or congress
- Parking
- TV in all units
- Public transportation
At the Auberge Le Petit St-André you will find an unique comfort and rural and warm ambiance.
This inn offer 8 luxurious rooms with privat bathroom. A breakfast will be offer during your stay and lots of activities will be suggest to give you a memorable stay.
For all reasons, the Auberge Le Petit St-André is the place and is only at 15 minutes from Montreal.
A pleasure to serve you…
18 bedrooms
Breakfast included with the room
Payment accepted
Credit Cards: MasterCard, Visa and American Express; Interac

subset: commoncrawl


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I sit here this morning pondering the idea of friendship while listening to a millennial mix of trance and vocals. The kind of music that purposefully triggers one's heart rate; the kind of music that gets you pumped. I love to play around with what may inspire me and improve my energy, especially while writing. Sometimes I have something to say, something my fear and shame keep me from saying. In these moments I seek connection with energy and focus. Something only afforded me when I'm able to tune out the constant babble in my mind. In these moments, I search and search for the right rhythm and beat to coax the truth out of me. The right bit of inspiration to allow me to overlook how uncomfortable I feel, naked, stripped of all armor and masks. The gentle rhythmic push of the perfect playlist.
Friendship & Codependency
So, I sit and allow the beats to push me as I reflect on my ability, or rather inability to effectually develop friendships. I'm not ignorant, I'm completely aware of the issue, it's a simple one… I, like a great majority of our population, am a card-carrying, expertly-trained codependent. And codependency's a BITCH! I don't remember an age when I wasn't thriving on the high of codependency, though I didn't recognize it as such as a child. Somewhere along the way, I took it upon myself to pick up the problems of the world. First, graciously absconding with my parents' worries, dramas, and glitches for the better part of 40 years. Then by opening the floodgates to bigger more worldly problems; problems I cannot control but still happily try to 'fix' in my codependent mind.
The truth is, I'm exhausted, and I truly want no part of it anymore. I no longer want to attract needy people into my life. This is not to say that I no longer want to serve my Lord and those He puts in my path to serve. No, this is to say, I no longer need to consume my mind, body, and spirit with other people's opinions, manipulations, or dramas. Whatever that may look like, I'm done with it. No longer do I feel the need to seek my own reflection in the eyes of another. Gone are the days of seeking acceptance through servitude. I've shed it all, the desperate need to hide my truth and myself, the need for approval, and the need to carry everyone else's burdens rather than my own.
The Pain of Pruning
There was a time in my life several years ago, when God started stripping me of my friends, but I didn't see it that way then. At the time, I was devastated, and desperate to understand why people were turning their back on me. Turning, running, and judging at the darkest moment of my life. Now I look back and know that God allowed for a necessary pruning in my life, and reasoning beyond that will serve no purpose. I see now that I've never truly been able to manage friendships, especially multiple friendships, simply because I exert too much energy doing so.
In the past, I had a handful of women I considered friends, but honestly, they were all surface level friendships. I never allowed for more than that. I was able and willing to listen to their problems, consoling and comforting to the best of my ability, but I never shared. I was always better at listening than comforting. Hugs and tears made me very uncomfortable and sharing terrified me. I've always been the listener, the fixer, and the master chess player. A short list of perceived responsibilities created to avoid the truth. A set of roles used to protect me from looking within for the true and honest Aubrey.
Abandonment & Insight
People have come and gone in my life, triggering abandonment issues left and right, but these days I just don't care. I realized recently that I've spent more time concerning myself with issues and relationships outside of myself and my immediate family for far too long. I have wasted so much energy trying to be the person 'people needed me to be,' that I never learned how important it is to lean in and love those who are the top priorities in my life. After God, Ed and Tristan are my number one priorities. If we, as a family haven't mastered what is to live and love openly and honestly in our little slice of the world, how are we supposed to navigate the issues and burdens of the outside world? We aren't!
I see now that people will continue to come and go, a necessary part of this beautiful journey, and I accept that. No longer will I feel slighted by the disappearance or disappointment of another, friends and acquaintances alike. I accept that people will walk away, and I will do the same. I will remain forever mindful that I need not seek an abundance of friendships nor acceptance from anyone other than God. The truth is, we cannot know who another is unless we invest the time to do so, which is a double-edged sword of vulnerability and expectation. In the end, there's always a chance that the person you thought you could have a relationship with isn't a good fit in your life. I imagine this to be true of a few people who have walked out of my life, and I get it. We either spend our lives hiding from the pain and anguish of disappointment, or we invest the time and energy in the relationships we see fit. I choose the latter.
A Declaration
No longer will I be dependent on the reflection of me in the eyes of another. Instead, I will forge ahead in this life, reflective of myself within myself, a true reflection of who God created me to be. A warrior who feels deeply, shares openly, and cries easily. A woman who will no longer be silenced and hushed for being too emotional or overly dramatic. A woman with an energy that loves deeply, something she will no longer apologize for. I will no longer hide from the pain and disappointment of this world. Instead, I embrace the journey. I embrace the pain and the beauty of peaks and valleys, the comfort and sadness of love and loss, and the raging waters of change. I embrace it all.
Photo by Tony Webster


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A friend mine sent me this photo of the Archbishop of Quebec, primate of Canada and cardinal of the Roman Church, Gérald Cyprien Lacroix, I.S.P.X., … at a parish function, and who is he sitting with? This is awesome; a prelate who gets it. And, of course it being Quebec, wine on the table with kids!
A pastor getting to know his sheep; a man of God witnessing to the love the Messiah has for children! This is evangelization!


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A malfunctioning fire-suppression system caused a foamy mess on Saturday morning inside - and outside - a hangar at Pearson International Airport.
Police say a foam machine started pumping out fire-suppressing foam at 0840 hrs. By the time it was finished, the fluffy bubbles were stacked as high as 6 metres. Police say the suds also spilled out of the hangar and covered an area the size of 2 to 3 football fields.
"It's quite a scene when it starts blowing around," said Cost. Rachel Gibbs of Peel Regional Police.
Crews were busy cleaning up the mess all morning. They were also hoping for a little help from Mother Nature. "They're going to be trying to vacuum some of the foam," Gibbs said. "And apparently water will also suppress the foam, so if it rains that will be beneficial."
The foam is made up of 98% water, with a 2% chemical solution. A subsequent rainy weekend has dispersed all the exterior suds, while vacuums were no doubt working overtime inside the hangar.


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Guanqin (watch): customer reviews
The clock is an indicator of taste and a status symbol. Guanqin wrist watches are designed for active people who want to control all changes, including time. They are ideal for modern men and meet all their requirements.
Guanqin watches - modern classic
Guanqin Company - Chinese manufacturerwristwatches. This brand appeared relatively recently, but has already gained worldwide popularity. Guanqin - watches, reviews about which are described below, are of good quality and affordable value. The manufacturer uses the best technologies and pays special attention to design, creating original and stylish models.
The watch is made of quality materials using modern manufacturing processes. Guanqin products have good performance. The watch is reliable and durable.
The company produces a wide range of models,which differ in appearance. Each model in its own way is attractive and original. The watch cases are carefully thought out. The dial looks beautiful with straps of stainless steel and corrugated leather.
To give refinement, the manufacturer decorated some models with stones. Most of the Guanqin collection is presented with waterproof watches with different levels of protection.
Given the tastes and needs of men, the company has created models of classic and sport design.
Advantages and disadvantages
The main advantages of Guanqin products:
- Factory production.
- Availability on all watches of an individual serial number.
- Presentable packaging. All watches are sold in the original cardboard box. The set includes a special glass cleaning cloth, a discount card from the manufacturer, a warranty and instructions.
- Modern design. In appearance, watches are not inferior to models of more expensive brands.
- Accurate polishing and processing of the case.
- Sapphire convex glass.
- Beautiful engraving with the manufacturer's logo on the back cover.
- Light factory.
- Smooth movement of arrows.
- Low price.
- Warranty from the manufacturer 1 year.
All these advantages are confirmed by numerous reviews. The hours of Guanqin high marks are put forward.
To the disadvantages of buyers attributed:
- Insufficiently strong glass. After testing the watch for resistance to mechanical damage on the glass there were noticeable scratches.
- On some models, leashes of leatherette are used. They spoil the appearance - the product looks cheap.
- Weak anti-glare of glass.
- Inaccurately glued figures. If you look closely, on the dial of some watches you can see traces of spreading glue.
- They often break down. Some buyers consider the Guanqin brand products to be unreliable. Hours, reviews and comments about which contain descriptions of popular breakdowns, can fail even in the first month of wearing.
Models overview
The company produces different models of wristwatches, which differ in size, shape and design of the dial.
Guanqin watches come in the following types:
- Mechanical clock in the automatic factory. All models have a large round stainless steel case. The strap can be leather or in the form of a metal bracelet. The watch is protected against water and shock. Possible functions - backlight, perpetual calendar, lunar phase, autodata, full calendar.
- Quartz watch. This includes models that operate on batteries. Guanqin (quartz watch), reviews about which are mostly positive, do not differ in performance from mechanical models. The round dial is made of durable waterproof materials. The clock mechanism can have a stopwatch, a full calendar.
According to the style of performance, the manufacturer producesSports models, everyday chronometers and luxury watches. The latter include the watch Guanqin Tourbillon on the automatic mechanism Self-Wind. The model has an unusual design. The case and dial of the watch are decorated with gilded elements. Model Guanqin Tourbillon is available in blue, black and white colors.
Watch Relogio Masculino Guanqin
The feedback of many buyers concerns this model. Relogio Masculino watches look stylish and prestigious.
The peculiarity of the model is the presence of original functions. The chronometer shows the complete calendar and date. The dial is protected by a sapphire crystal.
The watch is produced in dark colors. Leather straps perfectly match with the dial of one shade, which is decorated with golden arrows and numbers.
The diameter of the body is 4 cm. The length of the strap is 24 cm.
The watch is waterproof at a depth of 100 m. The tests confirmed the strength of this model. The housing can withstand frost and mechanical stress.
The clock mechanism functions without delay. The arrows move smoothly and accurately.
Model Relogio Masculino works on batteries.
Cost of Guanqin watches
Practically in every online store you cansee products Guanqin. The watches, which are confirmed by the popularity of the products of this brand, are easy to buy. The manufacturer earned fame thanks to the good quality of watches and their low cost. So, the price for Guanqin products, depending on the model, is from 2.5 to 8 thousand rubles. The average cost of such watches is 3,500 rubles.
For example, simple everyday quartz watches formen cost about 3 thousand rubles. For a multifunctional model with a metal strap, you need to pay a little more than 4 thousand rubles. The price for chronometers of a class lux makes about 7,8 thousand rubles.
Many men after inspecting the products of famous brands choose Guanqin models. Hours, reviews of which contain comments about low-cost models are available to everyone.
Responses of owners of hours
Products Guanqin enjoy special popularity in the domestic market of watches. Men of different social status with confidence acquire models of Chinese production.
Most left positive comments. The hours of Guanqin were attributed many pluses. Customers liked the design of the case and packaging. They also highly appreciated the quality of the products. According to the opinion of the watch's owners, in many respects the products are not inferior to the more famous analogs.
There are customers who did not like the watchmen's firms Guanqin. The reviews concern the strength of the glass and the reliability of the watch movement. It happens that the clock breaks down in the first days after purchase. Some were unhappy with the leatherette straps.


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Hua Jin
Second Violin
Joined the ISO: January 2009
Primary musical studies: Shanghai Conservatory of Music
The ISO "stole" Hua Jin from the Fort Wayne Philharmonic, where she was assistant concertmaster from 2004 to 2009. Prior to being a member of the Fort Wayne Philharmonic, she was associate concertmaster of the Kalamazoo Symphony Orchestra and a regular "sub" with the Detroit Symphony.
"My father is a violinist and conductor, and was music director of Jiamusi Orchestra in Jiamusi, China," Hua says. "I received my first violin lessons from him at the age of four. And at age 12, I was accepted as a violin student by the Central National Conservatory of Music in Beijing and at 15, I won a prize at the Chinese National Youth Violin Competition. I earned my Bachelor of Music degree at Shanghai Conservatory of Music." Hua received second prize at the Beijing Youth Violin Competition, and won the 1982 Gold Prize at the Harbin Music Festival Competition. She appeared as soloist throughout northern China, and in the U.S. with performances of film composer Franz Waxman's "Carmen Fantasy" and "The Lark Ascending" by Ralph Vaughan-Williams.
"In addition to my music performances, I like to play chamber music and teach private violin students," says Hua. "I like teaching. It gives me joy when I see my students progressing and I learn a lot from teaching."
"In preparation for a performance, I like to be absolutely confident that I can re-produce the composer's intent with the piece."
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How to Dig Up a Papaya Tree
Papaya (Carica papaya) reaches 10 to 20 feet tall with a thick trunk that grows up to 16 inches in diameter and a spreading canopy. Despite its tree-like appearance, papaya is a herbaceous plant with a soft, hollow fleshy trunk. Papayas grow fast, gaining 10 feet in the year after planting. The little papaya seedling that looked so promising can quickly take over in the garden but digging up and removing a large papaya is easier than it looks. Just don't try to transplant it, as it doesn't like root disturbance. Papaya grows in U.S. Department of Agriculture plant hardiness zones 9b through 11, and gardeners in cooler climates grow papaya in pots or as a fast-growing annual.
Clear the area and stand away from the falling tree when removing; although papaya plants are lightweight compared to woody trees, a large falling plant can still damage property or people. Cut the papaya tree one to two feet above the soil line using a machete or tree saw.
Dig around the roots using a sharp shovel until the trunk and root ball are lose in the soil.
Lift the root ball out of the soil and discard. Remove as much of the roots as possible and refill the hole with soil.
Things Needed
- Machete or tree saw
- Shovel
- You can cut down the canopy and trunk from a papaya tree and a new tree will sprout from the base. If you want to remove a papaya from the landscape, it's important to take out the roots. However, papaya is not as tenacious as some plants that will sprout from a tiny piece of root left in the ground. As long as you dig out the root ball and most of the roots, the papaya is not likely to come back.
Photo Credits
- Ablestock.com/AbleStock.com/Getty Images


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SEC reporting changes for RICs and BDCs
In August the SEC issued Release No. 33-10532, Disclosure Update and Simplification, which generally is effective for reports filed with the SEC on or after November 5, 2018. Among its many requirements, this Release includes the following reporting changes for registered investment companies (RICs) and business development companies (BDCs):
- Regulation S-X Rule 6-09.3 has been amended to require RICs to present the total, rather than the components, of distributions to shareholders, except for tax return of capital distributions, which should be disclosed separately. The SEC staff has stated that distribution amounts disclosed in the prior-year statement of changes in net assets (SOC) may be retrospectively presented to conform with the current-year presentation resulting from the amended requirements, as long as a footnote is included in the SOC disclosing (a) the reason for changing the prior-year presentation and (b) the disaggregated prior-year distribution amounts. It also is permissible to include in the footnote the prior-year undistributed net investment income.
It should be noted that the amendments to Rule 6-09.3 do not negate the requirement in paragraph 946-205-45-4a of the Financial Accounting Standards Board Accounting Standards Codification to present in the SOC (or disclose in the notes to the financial statements) for multiple class funds dividends and distributions paid to shareholders for each class.
- With respect to distributable earnings of RICs:
˗The requirement in Rule 6-09.7 for parenthetical disclosure of undistributed net investment income in the SOC on a
book basis has been deleted.
˗Rule 6-04.17 has been amended to require presentation of the total, rather than the components, of distributable
earnings on the balance sheet.
- Rule 6-03(c)(1)(i), which permitted the consolidation of financial statements of RICs and BDCs only with the financial statements of subsidiaries that are investment companies, has been deleted because the requirement in U.S. generally accepted accounting principles is broader and additionally requires consolidated financial statements when a reporting entity has a controlling financial interest in another entity.
- BDCs are subject to a new interim reporting requirement for changes in stockholders' equity in accordance with Rule 3-04 for the current and comparative year-to-date periods, with subtotals for each interim period. In a September 25, 2018 Compliance and Disclosure Interpretation (C&DI), the SEC staff addressed the effective date for the interim reporting of changes in stockholders' equity. The effective date guidance in the C&DI only applies to the requirement for interim financial statements and does not apply to any Article 6 amendments.


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Corsair HS70 Wireless Gaming Headset 7.1 Surround Sound + Mic (Carbon)
The HS70 Wireless Gaming Headset provides exceptional comfort, superior sound quality, a fully detachable microphone, and up to 16 hours of battery life. Stay in the game with improved range up to 40ft through low latency, 2.4GHz wireless. Legendary CORSAIR build quality featuring metal construction ensures long-term durability. Specially tuned 50mm neodymium speaker drivers deliver superior sound quality with wide range and accuracy.
Virtual 7.1 surround delivers immersive multi-channel positional audio on PC that puts you in the middle of the action. Low-latency, 2.4Ghz wireless audio with improved range up to 40ft and up to 16 hours of battery life. Optimized unidirectional microphone reduces ambient noise for enhanced voice quality and is easily detached for use on-the-go. Play with the confidence that your microphone and audio drivers have been tested and evaluated for crystal clear communication and outstanding sound.
Plug-and-play compatibility with Sony PlayStation 4 brings wireless stereo audio to your living room. Easy access on-ear volume and mute controls for adjustments on-the-fly. Powerful CORSAIR iCUE software enables custom audio equalizer settings, sidetone control and immersive virtual surround audio.
- Audio CUE Software
- Surround Sound
- Detachable Microphone
- Legendary CORSAIR build quality featuring metal construction
- Plush memory foam and adjustable earcups
- Powerful CORSAIR iCUE software
In The Box
- HS70 Wireless Gaming Headset
- USB wireless transmitter
- USB charging cable, 1.8m
- Warranty Card
Extra Info
- Wireless Type: Radio Frequency 2.4GHz
- Corded/Cordless: Cordless
- Earpiece: Dual Earpiece
- Over Head Support: Yes
- Mute Switch: Yes
- Main Colour: Black
Additional Information
|Battery Life
|16 Hours
|Connection Type
|Cable Length
|2 Year
|Product Code
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As it is, it is hard to bring out some of the dynamic effects in games with traditional photography.... Read more
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Mom says she was harassed for breastfeeding at local gym
CHESTERFIELD COUNTY, Va. -- A Chesterfield mother's Facebook post sparked outrage on social media Friday as dozens of posts appeared on the ACAC Midlothian Facebook page condemning the gym for its alleged treatment of the mom after she breastfed her children there New Year's Eve.
The mom, Jordan Williams, declined to do an on camera interview, but her husband, Edwin Wallace, said his wife sat at the entrance to the kid zone and nursed their two children without covering up.
SEE ALSO: Woman murdered by ISIS for breastfeeding in public
"My child does not breastfeed covered up. They don't like it. They won't do it," Wallace said. "We intend to never step foot in there again."
He said nobody said anything to her then, but when she got home, he said a supervisor called and told her it was not OK to nurse in that area, and she could have nursed in a room, or covered up per gym policy.
"They're harassing us over the fact that we breastfeed our children in public which is legal to do," Wallace said.
Posted by Jordi Williams on Monday, December 7, 2015
In fact, a bill passed last year made it so Virginia mothers could legally breastfeed in any public place.
"It definitely was shocking because legally we are allowed to breastfeed in public," Wallace said.
Wallace said he is in touch with an attorney who helped create the new breastfeeding law in Virginia.
He said together they hope to make the fitness center compliant with the law.
Yesterday I breastfed my sobbing toddler and screaming baby in the drop off/pick up area of ACAC Midlothian's KidZone....Posted by Jordi Williams on Friday, January 1, 2016
CBS 6 reporter Melissa Hipolit reached out to the gym about the alleged incident.
ACAC Midlothian posted the following statement on its Facebook page:
Here are 8 celebrity moms who proudly shared their own breastfeeding photos on Instagram:
"We are sincerely sorry to have upset a mom in our club recently. We pride ourselves on being a club that caters to families, and the last thing we would want to do is upset any family. We support the rights of all mothers to breastfeed their children. There are no policies that prohibit or restrict breastfeeding in our clubs.
In regards to this particular event, at no point was the mother interrupted or asked to refrain from breastfeeding her children. After receiving feedback from members, a team member did call the mom later that day to offer additional options for breastfeeding in the club. In a subsequent conversation, our general manager emphasized that the mother was free to continue breastfeeding in the same spot or anywhere she chose in the club. We tried to have this conversation with great respect and sensitivity. We apologize that we have offended her and many others. We never wanted this mom to feel unwelcome or uncomfortable."
More news:
Chris Brown and his manager respond to assault allegations
Emma Watson 'can't wait' to see Noma Dumezweni as Hermione in 'Potter' play
California grants rare look inside largest death row


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Affiliate membership: Join today
Join today
Join as an affiliate member. Pay a one-off application fee of £137.00 and a subscription fee of £200.00. Your subscription will run to 31 March 2021.
You can also use this form to join and register for the IIA Certificate programme, which costs £3,852 + VAT.
By applying for membership you are agreeing to:
- Abide by the IIA's Code of Professional Conduct including the Code of Ethics
- Comply with the International Standards for the Professional Practice of Internal Auditing
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You will be asked to choose a region. Take a quick look here to see which one you want to be linked to.
Once you've submitted this form you will receive an invoice via email within a day or two. Payment must be received within 30 days of the invoice date.
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We will use your information to deliver your member services and process any other orders or requests you may have. You may update your information and mailing preferences online or by emailing email@example.com
Your privacy is important to us and we will never share your information with any third parties other than our contracted suppliers (for example, to arrange delivery of your member magazine).
For more information on please read our data protection policy
All joining members are subject to our Fair Collection Notice and Privacy Policy.
Terms and conditions
Please read the terms and conditions of membership.


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activewear for women that features empowering messages
Designed for all body types.
Our boutique line of activewear for women features empowering or uplifting messages and is designed to fit all body types.
You'll love the feel of the soft flowy fabrics our shirts are made of and the premium compression fabrics or yoga knit fabrics in our pocket leggings, capris and shorts.
Once you try our clothes on, they will quickly become your favourites!
Who is Asskicker?
Founder, Julie Bateman (Annie Asskicker), is a professional graphic designer and the owner of Bateman Design Group, a boutique creative agency located in Barrie, Ontario.
As a long distance runner for many years before joining a local roller derby league, Julie was often searching for activewear that suited her needs.
Being tall at 5'11" with weight that fluctuates, most brands weren't designed for her body type—so eventually she decided to design a few shirts ... and Asskicker Ink. was born.
Rhonda Leigh Madill
My favourite pair of workout pants/capris.....and I have A LOT!
Melissa Squires
Love love love the shirts I have bought!! Super soft and comfortable!!
Angel Ketchum
Perfect fit, very comfortable material. Wore it to derby practice tonight. Love it!


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Vulcan Gas Company is a beautiful state-of-the-art music venue designed to host today's most cutting-edge music experiences as well as to offer the best setting for a variety of private brand activations and parties.The venue's steampunk-inspired interiors, Funktion-One sound system and state-of-the-art lighting and video projection systems, provide a unique setting to enjoy drinks and cocktails while showcasing top talent from Austin and around the globe. Vulcan Gas Company is approximately 9500 sq feet, spans over 2 floors (with 658 people standing room capacity) and features a green room, catering room, 7 men's & 7 women's bathrooms, 2 large bars and an outdoor terrace. Vulcan Gas Company is also a private event space thoughtfully designed to accommodate a variety of brand activations and private parties.
Accepted credit cards
Mastercard, Visa, American Express


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How to calculate class width.
Group width can be calculated by working out the difference between the upper boundary and lower boundary of a group:
Class Width = Upper Boundary - Lower Boundary
If the frequency table contains discrete data values then this can be a little harder to work out (see example 2)
Class widths can be used when drawing a histogram, as the frequency density is equal to the frequency/class width. They are also useful if you need to use interpolation to find the lower quartile, median and upper quartile.
Example 1 - Continuous data
The frequency table shows the finishing times of 20 athletes that took part in a race. Work out the class widths of all of the groups.
So all you need to do is work out the difference between the upper limit and lower limit of each group. The frequency column is not relevant to the question so it can be ignored.
The lower limit of the first group is 45 and the upper limit is 50, so the class width is 50 - 45 = 5.
The second groups with is 10 (since 60-50 = 10)
The lower boundary of the third group is 60 and the upper boundary is 80, so the width of this group is 80 - 60 = 20.
The final group has a group width of 5 (85 -80)
So the answers are 5, 10, 20 and 5 minutes.
Example 2 Discrete Data
The frequency table shows the ages of a group of students who took part in a school play. Work out the group widths of each age group.
This time the data is discrete, so you have to think carefully where each group starts and ends. Again the frequency column is irrelevant.
The first group 0-4, starts on a lower limit of -0.5 and goes up to an upper limit of 4.5. So the width of this first class is 4.5 - - 0.5 = 5.
The second age range starts on a lower boundary of 4.5 and goes to an upper boundary of 9.5. So the group width is 9.5 - 4.5 = 5.
The third age range begins on a lower limit of 9.5 and goes to an upper limit of 12.5. So this group has a width of 12.5 - 9.5 = 3.
The final age group starts on a lower boundary of 12.5 and goes to an upper boundary of 16.5. So the width of this final group is 16.5 - 12.5 = 4.
So the class widths are 5, 5,3 and 4.
Class Width Summary
So to summarise the class width is the difference between the upper and lower boundary of the group.
If you found this article useful then check out my other math related pages. You will find many mathematical topics from the fields of algebra, number, geometry and statistics. All of these articles have been written in an easy to understand way. You will be shown easy to follow methods for solving simple equations, calculating averages from real life data, solving basic and advanced number problems involving fractions, percentages and ratio.
There will be also many other statistical topics coming up shortly, such as, how to draw a pie-chart and work out the angles, how to draw a stem and leaf diagram and work out the median and range from it, how to draw a cumulative frequency curve and calculate the lower quartile, the upper quartile and the median.
Also, if you found this page useful then don't forget to rate this article or leave a comment. If you have any other questions about this topic then I will try to answer them as soon as possible. Thanks for taking your time to read this article.


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Telmar provides strategic targeting and media planning solutions to advertisers, agencies, media companies, and data suppliers. Over 25,000 users across 100 countries use Telmar systems to analyze thousands of consumer and media data sets to assess target markets, audience reach and frequency, and media performance.
Data sets can be either syndicated data to which rightful access has been granted by the data supplier, or customers' own proprietary data. Telmar provides data integration tools which support fix fusion, ascription, and Telmar's leading real-time data integration technique: MultiBasing™.
We've put together a case study on our MultiBasing methodology that provides examples of Telmar clients who have gained greater insight into:
Fill out the form to the right to download the case study.
"We've recently switched back to Telmar and never looked back, fantastic customer service and easy to use product. They recently showed their value when I was left short staffed and had a long list of queries from a busy commercial team- the support team at Telmar was there to pick up last minute queries and continue business as usual. Thanks so much for helping us out!"
Seema Hope
Research Director
Dennis Publishing
"Telmar is an excellent tool for any data analysis and planning needs. It is not only easy to understand but also flexible enough to add, enhance or change features according to the needs of the markets and the client. But what makes Telmar a good tool to have is the support that we get from their extremely helpful staff. GroupM probably would be one of their tough clients, with our complex agency structure and varied requirements of each agency, but they have worked with us on all points effortlessly to fine tune everything and make the process of loading and using the different databases easy and convenient for us. The best part about their staff is their willingness to genuinely understand our issues and provide a reliable and effective solution to each problem."
Group M Knowledge
"Great training and was a nice little booster for my current skills. We went at our own pace and the trainer was happy to stop and explain things in further detail which we all appreciated. The test at the end was very useful in helping to solidify everything we had learnt."
Charlotte Hansen
Exterion Media
"The Telmar team are great! Their knowledge of the tools, data and media planning world is second to none. Importantly all of this combined with a friendly team who are happy to partner with you and tackle day to day business challenges. What I really like is their persistence to get to get to the answer you need – this is what sets them apart from others."
Amanda Wigginton
Group Customer Strategy Director
Time Inc (UK)
"The Telmar platform seamlessly integrates with a variety of research data that we subscribe to. Having switched to their platform just last year, I can say that they have a very professional on-boarding and training process. Even the most junior members of our team understand how to use the software because of the user-friendly drag and drop platform and intuitive search tools. Its functionality and ease-of-use allows us to quickly and easily pull cross-tab reports and analyze the data. The cross-tab platform combined with their media planning solutions prove to be invaluable tools for gaining insights into our client's customers and creating effective media plans."
Cheryl Tulipana
Associate Media Director
Sullivan Higdon & Sink
"Nobel has worked with Telmar for 10+ years. During that time, we have received responsive, effective, and efficient turnaround on our requests, trainings and needs. We look forward to continued partnership with our representative Kimberly Barrett and the Telmar team."
Trista Countryman
Associate Media Director
"Telmar continues to be a trusted and reputable partner for MediaCom US. They consistently deliver a high level of service and responsiveness. Telmar's continued focus on innovation and efforts to improve their value proposition to us make them an invaluable resource."
Ray Shynn
Head of Insights
MediaCom US
"When we decided to change Bureau after so many years, one of my primary concerns was the logistics involved. How disruptive would it be to shift from what we knew to something different whilst still ensuring day-to-day access for a team full of salespeople? I needn't have worried. Robin, Gary and the team implemented a seamless transition programme that ensured we were fully operational on Telmar by the time our incumbent bureau's license ended. What could have been a major headache was actually remarkably smooth."
Sean Adams
Head of Insight, Commercial
News UK & Ireland
"The transition from IMS to Telmar has been super smooth with excellent training taking place well in advance, and happily not one drama on the day of IMS switch off."
Simon Stanforth
Group Research Director
Starcom Mediavest Group
"Telmar has helped us complete projects in significantly less time than before. The ability to gather and report media metrics on all our markets at once is easy and fast. Being able to gain these same insights on other vendors' inventory has allowed us to be smarter at planning. The system is easy to use and the data is reliable. Just as quickly as we can gather the information we need, we can customize it and export anyway we need it. Telmar is a truly great platform that we are so happy to have."
Erin Bowling
Market Research Analyst
Lamar Advertising Company
"Telmar is a fabulous company to work with, they are innovative in their approach and always open to new ideas. Their customer/client service is second to none and I have always found them to be happy to assist, with a friendly approach and above all an efficient service. I always feel that Telmar takes pride in helping us get the most out of their software. Not only a fantastic product but really so much more…"
Lu Ellis
Research and Systems Director
"The various tools I am able to access and analyze in Telmar enable me to deliver the insights needed to do my job effectively and deliver value to my company and its clients. In addition, the team at Telmar is always a great resource in how to get more from the data."
Susan Cunningham
VP, Director of Research & Consumer Insights
"As a long term industry user & supporter of Telmar, I'm always impressed with their efficient service levels, quality of software but most of all their passion to continually improve & enhance how we look at different data sources – always working to take our industry currencies to the next level."
Craig Harvey
Research Director
IPG Mediabrands, Hong Kong
"Telmar are adept at providing us with effective survey and analytical tools, with strong customer service backup and development ideas."
John Krzyzanowski
Commercial Audiences Manager
"Telmar provides essential media planning support for Empower with its ready access to numerous research studies an its intuitive interface. We particularly value the advanced analytics capabilities like Cluster and Correspondence Mapping, which allow us to investigate data in a more sophisticated way."
Julie Pahutski
SVP, Decision Sciences
Empower MediaMarketing
"As a humanistic and user-friendly tool, Telmar perfectly focus on users' experience and needs flexibly, rather than a cold technology polymers."
Ina Zhao
General Manager, Marketing & Media Research Center
Charm Communication
"The Telmar team are great! Their knowledge of the tools, data and media planning world is second to none. Importantly all of this combined with a friendly team who are happy to partner with you and tackle day to day business challenges. What I really like is their persistence to get to get to the answer you need – this is what sets them apart from others."
Amanda Wigginton
Group Customer Strategy Director
Time Inc (UK)
"Telmar has been our "go-to" data analysis tool since December 2017. The SurveyTime application allows us to generate crosstabs quickly and easily but it is the SurveyUploadertool that really expanded our data capabilities. Being able to upload our proprietary data files to use in SurveyTime was a game changer for us, giving us the ability to manage studies and electronic codebooks in-house, saving time and money on each study. But, the number reason we are thrilled with Telmar is the unparalleled customer service that Jenny provides. No matter the issue, big or small, Jenny responds quickly and has resolved EVERY concern we have encountered with her trademark enthusiasm and dedication."
Kelly Levson, Director of Marketing and Research
Canadian News Media Association (News Media Canada)
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text: The mediation of the balance between vigilance and restraint is a fundamental feature of judicial review of administrative action in the Anglo-Commonwealth. This balance is realised through the modulation of the depth of scrutiny when reviewing the decisions of ministers, public bodies and officials. While variability is ubiquitous, it takes different shapes and forms. Dean R. Knight explores the main shapes and forms employed in judicial review in England, Canada, Australia and New Zealand over the last fifty years. Four schemata are drawn from the case law and taken back to conceptual foundations, exposing their commonality and differences, and each approach is evaluated. This detailed methodology provides a sound basis for decisions and debates about how variability should be brought to individual cases and will be of great value to legal scholars, judges and practitioners interested in judicial review.


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The Dunlop winter SUV tyre range.
The Dunlop tyre range : To explore Dunlop tyres, their prices and ratings, and to compare tyre retailers, select the season and the vehicle type, and then select a product below.
To get prices for Dunlop tyres, enter your tyre dimensions.
All the Dunlop 4x4 Winter and snow tyres
- 4x4 Road tyres
- Grandtrek SJ4
- Grandtrek WT M2
- Grandtrek WT M3
- Winter Sport 5 SUV
All Dunlop tyre categories
Content is provided for informational purposes. It is nonexhaustive and noncontractual. To find out more click here.


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The Jarrah buffet and wine rack is a classic design with a modern twist, featuring raw edge recycled jarrah top and a wine rack in the centre. Compliments many styles of dining settings.
Tags: Australian made, Australian timber, Buffet, Central wheatbelt, custom made, distressed, Femelle, French, handcrafted, hardwood, Jarrah, Kalgoorlie, Merridin, Narembeen, natural edge, Northam, Perth, recycled timber, rustic, solid timber, Solid timber furniture, unique, White, Wine rack, York


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In the past, a big part of what made a sales consultant successful was their capacity to stomach the uncomfortable sales procedure.
These consultants did not mind dealing with all the normal roadblocks from prospects in sales appointments -- roadblocks just like insufficient money and poor timing.
They did not mind dealing with the strain. And make no mistake; there is a whole lot of pressure on everybody involved with the sales process. There is pressure on you to do well during the meeting.
There is pressure on the prospect to come to a decision. And there is pressure on the entire appointment to supply the numbers you are after.
While the conventional method of selling works for a while, it certainly does not work for everybody.
Most sales consultants are not familiar with the old method of selling and looking for a simpler way.
When I started, I was deathly afraid of two things. I was afraid of selling because I didn't want to be rejected.
I was also afraid of asking for money because in our family, we never really talked about money.
Because I feared selling and asking for money, I decided that I'd just get good at marketing.
If I could do that, then the marketing would do all the heavy lifting for me and selling would be easy.
I realized that what I was really after was a way to flip the traditional sales model upside down and take the pressure out of selling.
That's when I added Authority-Selling.
Authority Selling is just one of the amazing selling techniques I use every day. Here's how it works:
In your marketing, your job is to make two things crystal clear to your prospects.
Here are the results you want.
Here's how to get them.
Yes, it's that simple.
In the movie Inception, the main characters get into people's dreams and plant an idea.
This is a great metaphor for what we want to do in our marketing when we're Authority-selling.
We need to facilitate their information gathering and decision making process. We need to get inside their head (figuratively, of course) and set the buying criteria.
You can do this in any type of marketing.
Sending out an email newsletter?
In the email, teach them what to want by stressing the importance of getting the results you offer.
In a video blog, podcast, speech, live event, webinar – or whatever else you use to market – your job is to 'seed the need'. When you've planted that seed, they'll be hot for what you've got.
Now, tell them how to get it.
In every sales appointment there's a prize, and there's someone who wants that prize.
In traditional selling, the prospect (by turning them into a client) is the prize, and you're the one who wants it. You're the hunter, they're the prey.
Unfortunately, that leads to a whole lot of crap on your end! It means you've got to put up with their objections and excuses while they're stalling and negotiating.
This doesn't help you and it doesn't help them.
If you're the needy one when you sign on a client, how well do you think the relationship will go?
We need to reverse the roles.
There's a great book by Oren Klaff called Pitch Anything. In a nutshell, it talks about becoming the prize. You need to become the walking, talking, deal of a lifetime by understanding the cost of not doing business with you.
Think, "What will it cost them if they don't hire me?"
Reversing the roles only truly works if you've taught your prospect what to want in your marketing.
The clearer you can be about the value you'll bring before you ever get to the sales appointment, the easier it is to be in a position of power.
Be the prize.
Most sales consultants walk into a sales appointment trying to impress their prospects.
In Authority-selling, you should go in looking to assess the prospect.
So, you've taught them what to want.
You've seeded the need and you've got them hot for what you're selling.
Your mindset isn't needy because you know you're the prize.
After that, when you're booking a sales appointment, give them some work to do, document key priorities for using technology and have them bring that to the meeting – an audition of sorts.
Once they provide it to you, do a 10-15 minute discussion where you assess their situation.
This isn't just for show. You want to assess what kind of client they'll be. Are they an A-grade client? Or, are they a B, C, or D-grade client?
If they're not A-grade (or at least have A-grade potential) then it's not a good fit for you, and you can move on gracefully. If they are a great fit, then go forward with a sales appointment.
When you get this correct, it transforms your sales appointment process.
In sales appointments, there'll nonetheless be objections.
The only difference is, you are going to be the one raising them.
Could you imagine if you were not the one desperate to get a "Yes" at a sales meeting, and instead the prospect was.
Then you can say, "I only need to ensure we are an excellent fit here.
I am somewhat concerned about X however.
Tell me about this. Are you sure we are a fantastic match?"
This puts you in a place of authority ideally.
P.S. whenever you're ready, here are 3 ways I can help you help grow and scale your IT & MSP business:
- Join our community of ConnectWise users and industry experts here: www.cwboss.com
It's the easiest way to plan ahead for growth, learn helpful tips and join weekly educational workshops.
- Learn how to be the #CWBOSS of your business by joining our weekly workshops here: https://bit.ly/2XmaM6O
Every thursday our CEO & President, Adam Bielanski, hosts a 30 minute workshop around making ConnectWise work for your business
- Work with me and my team privately: If you'd like to work directly with Adam and the team to actually get you out of the weeds and into your flow, schedule a 15 minute Triage call here: https://calendly.com/adambielanski/15min


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Discovering the ultimate in comfort and style, Marta Mitchell visualizes practical spaces starting with the client's wants and needs. With tireless attention to detail, Marta creates unique designs that reflect your untapped artistic vision and desire. Marta has an artistic perspective unlike any other designer.
A student of color and livability, Marta's unique vision and willingness to take risks continue to deliver award winning residential and commercial spaces.
- Bachelors & Associate Degrees in Interior Design
- Certified Color Consultant, CfYH
- Over 25 Years of Experience
- Interior Design services provided throughout the United States & internationally
- Comprehensive services ranging from a single consultation to completed turn-key projects, including concept discovery, selections, project management, purchasing, and installations.
- Resources library and accounts with all major furniture, fabrics, and accessories manufacturers
- Official buyer at all major furniture markets and design centers
- American Society of Interior Design – Excellence in Design Awards (multiple project awards, over many years)
- Women in Business Award (Triad Business Journal)
- Greensboro Rotary Club Member and Paul Harris Fellow Recipient
- Most Admired CEO Award (Triad Business Journal)
- Greensboro Builders Association Member
"I have asked Marta for help on a number of decorating projects over the years and one reason I keep returning to her is her willingness to listen. She always begins a project by soliciting my thoughts and ideas, making me feel like an integral part of the process. She then gives me some specific suggestions based upon what I have told her. When an idea does not seem to be working, Marta is always ready with alternative suggestions. She is also mindful of costs and works well with a budget; she never pushes me to spend more than I have allotted for a project. And I cannot neglect to mention what a wonderful job she does! I never fail to get compliments on how beautiful my house is – and all the credit goes to her."
Annelise Tikkanen, BFA
Interior Designer
Annelise graduated from the University of North Carolina at Greensboro with a BFA in Interior Architecture (CIDA). Her unique approach to design stems from her time living abroad in Manchester, England where she gained a love for eclectic oddities and European flair. Annelise possesses an elite skillset in 3D modeling and rendering that allows clients to get remarkably realistic previews into their future living spaces. Her rich knowledge and unique design eye provide clients with an unparalleled design experience.
When she's not at the office, you can most likely find Annelise sketching strangers at a Greensboro coffee shop or planning her next trip abroad.
Brittany Terry, BFA, LEED Associate, ASID
Interior Designer
Brittany's artistic background and design vision originated from her love of travel and experiencing new cultures. After discovering her rich natural design abilities, she completed her BFA degree in Interior Architecture from the University of North Carolina at Greensboro. Brittany's design abilities keep originality at its core. She thrives on complex space planning projects and adapting to the individual styles of her clients. Brittany is also certified as a LEED Green Associate ("Leadership in Energy and Environmental Design"). When not in the office, Brittany loves finding new local restaurants and is always ready to venture to a new destination, stateside or abroad.
Angela Austin, BFA, ASID
Interior Designer
As a passionate designer, Angela loves to breathe life into spaces by focusing on her client and finding out what inspires them. Her energy, creativity and dedication for each project set the stage to ensure beauty and function seamlessly blend as one. She attributes her ability to mix patterns and colors to her love for travel, art, fashion, and music. Angela completed her BFA degree in Interior Architecture from the University of North Carolina at Greensboro. Upon graduation, she immediately fell into step with the world of design and has years of knowledge designing for residential or commercial spaces.
When not in the office, Angela loves spending time outside, finding new adventures or experiences, and seeking out the best coffee in the area.
Dan Garner, M. Arch, NCIDQ
Interior Designer
Dan wanted to be an architect the moment he opened his first Lego set as a kid and never gave up on his dream. He holds a Master of Architecture degree from the Savannah College of Art and Design. Working as an architect on commercial, residential, institutional, and hospitality projects of all sizes, Dan realized his greater love for interior design. He shifted his focus and completed his NCIDQ certification.
Dan loves really listening to clients and delivering everything they ask for and more. He is passionate about crafting personal designs that are as functional as they are beautiful.
Dan enjoys time with his wife, kids, and dog. He likes getting his hands dirty beautifying his home and yard. He also has a passion for the performing arts and set design.
Ashley Coe, BFA, IIDA
Interior Designer
Ashley's love for design started at a young age watching design shows with her mother. She loves seeing others experience joy as a result of passionate, thoughtful design. Ashley completed her Interior Architecture Degree from the University of North Carolina at Greensboro, and with many years of combined experience in the Commercial, Residential & Furniture Industries, she thrives on using her skills and knowledge to give her clients nothing but the best.
When not in the office you will find Ashley spending time with her husband and their baby girl, likely enjoying the outdoors and watching live music.
Meg Hayes, M. Ed, BA, AA
Office Manager
Meg has spent her professional career in the "Customer Service Industry." For 30 years, she has worked in many settings, ranging from Law Firm Operations Manager, Educational Assistant Director to School Counselor. Her diversity in the workplace makes her an asset in juggling multiple roles here at MMID. She firmly believes that being accessible to clients builds trust and that leads to a high-quality client experience. Meg has her M.Ed from Campbell University, BA: Psychology from UNC Chapel Hill and AA: Liberal Arts from William Peace University, (Peace College).
In her free time, Meg enjoys traveling with her husband to see her three children. She loves spending time with family on the Greenbrier River in WVA, putting her toes in the ocean at Southern Shores on the Outer Banks and taking trail rides with her horse Lucky.
Mandy Witte, BA
Vendor Relations
Mandy graduated from the University of North Carolina at Greensboro, with a degree in Textile Design and Marketing, and a minor in Business Administration. Working in Vendor Relations at MMID combines her passion for creativity, while utilizing her business skills. When Mandy is not in the office, she enjoys spending time with her two kids, Reilly and Ella. Mandy takes pleasure in volunteering at her kid's schools, helping with fundraisers and working in the classroom. She has been involved in the PTA for many years.
Mandy is always searching for her next vacation opportunity, as she loves to travel, Ocean Isle Beach being her favorite. You can find Mandy every weekend cheering on her kids at their soccer games.
Peter Mitchell, MBA
Marketing Manager
Peter assists with marketing, sales and other business support activities. With over 30 years of experience in the marketing field, Peter provides unique insights into our high-level business operations. He earned his MBA from UNC Chapel Hill, and a Strategic Sales and Marketing Degree from the Executive Program at Harvard Business School.
In his free time, Peter enjoys all outdoor activities, including hiking, tennis, and golf.
Rodney Boger
Installations and Deliveries
With 30+ years of experience under his belt, Rodney provides expert level knowledge in deliveries, window treatment installation, furniture & accessories placement, art installation and all other required project services. He is the owner of Boger Installations. Rodney learned his skills from an early age as the sole installer for his family owned drapery workroom. His experience and personality lead to a professional, efficient and optimal project experience for all clients. When not at work, you can find Rodney on the golf course.


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Daniel Morchain is a Policy Advisor with IISD's Resilience Program, leading the National Adaptation Planning (NAP) processes in Colombia and Peru.
Within the Resilience Program, Daniel supports the design and implementation of initiatives that address adaptation to climate change impacts in the context of development. He currently leads the National Adaptation Planning (NAP) processes in Colombia and Peru. Prior to joining IISD, Daniel was a senior adviser in Climate Change Adaptation and Resilience at Oxfam. One of his key roles there was as co-investigator for CARIAA's Adaptation at Scale in Semi-Arid Regions project. A main focus of his work is risk and vulnerability assessment through cross-scalar, participatory and multistakeholder processes. In this context, he developed The Vulnerability and Risk Assessment Toolkit methodology. Through program and project design and implementation, research, research-for-impact and implementation, he supports efficient decision making that aims to deliver fair, sustainable, socially sensitive and gender-transformative outcomes.
All Publications
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Blog - June 19, 2020There are parallels and overlaps between climate justice and racial justice, as well as many lessons the climate movement can learn from this global moment of reckoning.
- Adaptation to Climate Change: Putting people first
Blog - August 27, 2019When we talk about solving the climate crisis, we should have more than just a technical lens; we should also be talking about compassion, grief, fear and hope.
- Monitoring and Evaluation Systems for Adapting to Climate Change Are Only As Good As They Are Usable
Blog - June 25, 2019Monitoring and evaluation systems for climate change adaptation should make it easier for people and decision makers to learn what is working and what is not.