 In 1983, environmental groups and protesters delayed the field tests of the genetically modified ice-minus strain of "P. syringae" with legal challenges.In this case, the plaintiff argued both for mandatory labeling on the basis of consumer demand, and that GMO foods should undergo the same testing requirements as food additives because they are "materially changed" and have potentially unidentified health risks.The plaintiff also alleged that the FDA did not follow the Administrative Procedures Act in formulating and disseminating its policy on GMO's.