A study published in 2010 by scientists at the University of Arkansas, North Dakota State University, California State University and the US Environmental Protection Agency showed that about 83 percent of wild or weedy canola tested contained genetically modified herbicide resistance genes.[42][43][44] According to the researchers, the lack of reports in the US suggests inadequate oversight and monitoring protocols are in place in the US.[45] The development of weeds resistant to glyphosate, the most commonly applied herbicide, could mean that farmers must return to more labour-intensive methods to control weeds, use more dangerous herbicides or till the soil (so increasing then risk of erosion).[46] A 2010 report by the National Academy of Sciences stated that the advent of glyphosate-herbicide resistant weeds could cause the genetically engineered crops to lose their effectiveness unless farmers also use other established weed management strategies.[47][48] In Australia, some of a 2010 planting of Monsanto's Roundup-Ready (RR) canola blew across a neighboring organic farm.[49] The organic farm lost its organic certification and the organic farmer sued the GM farmer - so far without success.[49] The certifier called it "contamination" and in the 2014 judgement the judge called it an "incursion" and rejected claims for nuisance, negligence and damages.[49]