When a biopharmaceutical is developed, the company will typically apply for a patent, with the European requirements are perceived as more difficult to satisfy. The total number of patents granted for biopharmaceuticals has risen significantly since the 1970s. In 1978 the total patents granted was 30. This had climbed to 15,600 in 1995, and by 2001 there were 34,527 patent applications. Biopharm proponents claim that using plants can offer an easily controllable, safe, and cost-effective method for manufacturing proteins, provided that proper regulatory safeguards are put into place to ensure that no outcrossing can occur. It is also important to note, that the global demand for particular pharmaceutical protein can easily be met from just a few acres of pharma-crop, which can be grown under high containment conditions (e.g. in the greenhouse). Some scientists even think that the term "gardening" is more appropriate than farming. Opponents are concerned that there are too many ways in which contamination of the food supply involved with using staple crops such as beans or rice. Pharming is a portmanteau of farming and "pharmaceutical" and refers to the use of genetic engineering to insert genes that code for useful pharmaceuticals into host animals or plants then make the pharmaceutical product in large quantity, which can then be harvested and used to produce pharmaceuticals. The manufacture of the drug can recover the investment cost for development of the biopharmaceutical. The patent laws in the United States and Europe.