On October 15, 2009, Jairam Ramesh, Union Minister of State (Independent Charge) for Environment and Forests, stunned India and the world by calling for a review of Bt brinjal and opening himself to a process of public consultation that had not been seen in India. As a Minister in the Central government, he found himself at the receiving end of the angst felt by many, who accused him of being insincere, of being even a Monsanto agent. The dust and ‘heat’ of these consultations had the right mix for the wide media coverage they attracted. What remain relatively unknown are the scientific responses to the Bt brinjal Expert Committee (E.C.) II Report that were submitted to him.

On February 9, 2010, when Jairam Ramesh announced his decision to impose a moratorium on Bt brinjal, he referred to the necessity for caution and precaution, citing the relevance of the precautionary principle to the case of Bt brinjal, and said: “I believe the approach outlined… is both responsible to science and responsive to society.”

At home and abroad, Jairam Ramesh has received plaudits for demonstrating courage, unseen in a politician in recent years, East or West. He has, furthermore, restored a badly dented national image accorded us by a thoroughly unscientific, inaccurate and even corrupt report by the national regulator and its committee, marred by a huge conflict of interest.

Sharad Pawar, Minister of Agriculture, and Prithviraj Chavan, Minister of Science and Technology (which houses the Department of Biotechnology, or DBT) openly opposed him, taking a pro-Bt brinjal and pro-GM crops policy stance. In this they cited erroneous claims about GE (genetically engineered) crops, unsupported by science. Their position demonstrates, unambiguously, the serious disinformation that has beset our leaders in government. Why is this and how has it happened? This matter is the subject of a letter written to Prime Minister Manmohan Singh by 17 eminent and independent academic scientists on February 8.

The regulation and risk assessment of GM crops must address two questions. First, what is the degree of enforcement and commitment to keeping India safe? And second, what is required to regulate this hazardous technology before the environmental release of any GMO [genetically modified organism]? The need for extreme caution arises from the fact that once released into the environment, these organisms cannot be recalled. Yet, we have a most complacent pro-industry process: a safety dossier prepared by Monsanto with no regulatory oversight and no capability in place to conduct independent studies.

The regulators’ E.C. II Report states unequivocally that the “success” with Bt cotton is the basis of their confidence to introduce Bt brinjal, based on yield, performance and the proven safety of the same Bt gene (Cry 1 Ac) that has been engineered into Bt brinjal. Given the fact that the Genetic Engineering Approval Committee (GEAC) has not undertaken as an absolute necessity a comprehensive, independent and fully participative review (with stakeholders) of every aspect of Bt cotton, such a claim cannot be made. India is unlikely to buck the trend (in performance) in other countries. Current performance yields suggest mixed results. We have reports of declining yields because of insect resistance to the Bt toxin and insect shifts (examples, Gujarat and Punjab in 2007). It is a teasing observation that according to figures of the Cotton Corporation of India, Madhya Pradesh shows that in the pre-Bt cotton period, yield of non-GM cotton in the State was higher than that after the introduction of Bt cotton.

Responding to Jairam Ramesh’s invitation, Keshav Kranthi, Director of the Central Institute of Cotton Research (CICR) and a leading Indian entomologist, wrote that the rapid adoption of GM cotton by farmers across the country had coincided with the rise of hitherto unknown insect pests, increased pesticide application by farmers and declining cotton productivity over the past three years. It would be a wise decision by the government to undertake rigorous analyses, State by State, of agronomic and economic gains/losses in an independent and transparent process of inquiry, without inputs from Monsanto.

The next stage of inquiry is whether we need a particular GM crop. For this, the correct comparisons of agricultural models are essential. What is required is a systematic, in-depth investigation of Bt brinjal yields in alternative agro-biotechnologies, in partnership with farmers and civil society. This was not carried out with Bt brinjal.

A growing body of peer-reviewed literature is witness to the potential of modern organic or near-organic farming (a sophisticated mix of modern science and older practices that have been shown to work and be sustainable), integrated pest management (IPM), non-pesticidal management (NPM) and marker-assisted selection (MAS). Poor farmers on bad land do not practise modern organic farming: they do not have the ability to do so in many cases under the current circumstances. The correct comparisons may not be mono-crop cultures using external inputs of chemical fertilizers and insecticidal sprays. Yet, this is the false approach to a proper comparative model adopted by our regulators, and now to justify the approval of Bt brinjal by claiming heavy pest damage, of up to 60 per cent, by the fruit and shoot borer. Have they forgotten that IPM is a part of the country’s stated agriculture policy? The evidence is that it is effective. These highly productive methods are needed to produce enough food without converting uncultivated land – such as forests, which are important for biodiversity and slowing climate change – into crop fields. They build deep, rich soils that hold water, sequester carbon, and resist erosion. And they do not poison the air, drinking water and fisheries with fertilizers and toxic pesticides.

Some have dismissed the promise of these methods. Amongst them is United States State Department Science Adviser Nina V. Fedoroff, who in recent interviews characterised organic agriculture as some kind of retreat to a quaint past. She and others characterise organic farming and similar systems as inherently unproductive, sometimes suggesting that such methods are capable of supporting only about half the current global population.

Nina Fedoroff’s view is at odds with the latest science and represents a status quo kind of thinking. Industrial agriculture is a major contributor of heat-trapping emissions and a major cause of so-called dead zones such as the one in the Gulf of Mexico. And industrial agriculture is ultimately its own worst enemy, as it causes massive degradation of the very soil that is vital to farming. This kind of agriculture is unsustainable (Gurian Sherman).

Safety factor
As for the safety of the Bt gene, again, no such claim is possible. Indeed, it is a dangerous and irresponsible assertion because cotton is essentially an animal feed unlike Bt brinjal. And, the Bt gene has never been approved as safe in any Bt food/feed crop anywhere. To put it politely, truth appears to be a casualty. If it were not so serious, it would indeed be funny that the GEAC did not even know that Bt brinjal expresses a fusion (more than one, in this case two) gene. At first the GEAC denied it, and then, when Gilles Seralini, the pesticide and animal feeding studies expert, pointed to it chapter and verse of Monsanto’s Dossier, it tried to downplay the fact by saying that the difference of one protein was insignificant. The GEAC made an elementary error because neither is there only a one amino acid difference (seven in fact), but even one is significant.

To set the record straight and contrast it from the hype and falsehood emanating from the GM lobby that includes Monsanto; Nina Fedoroff, who arrived in India the day before Jairam Ramesh’s announcement to lobby the cause of Bt brinjal on behalf of which country it is not clear; and the Indian regulators, the DBT and the GEAC and the Indian Council for Agricultural Research (ICAR), who are now clearly seen to be a part of this lobby, it is enlightening to separate fact from fiction and read what some internationally eminent scientists wrote to Jairam Ramesh.


Yields
It must be clearly understood that currently no GM crop is engineered to increase yield. The United Nations’ International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD) is the IPCC (Intergovernmental Panel on Climate Change) equivalent in agriculture, the definitive road map for agriculture for the next 50 years. Authored by 400 scientists and signed by 60 countries, including India, it took four years to complete. In its published conclusions in 2008, it sees no role for GM crops to feed the world and states that there is no evidence that GM crops increase yield. Instead it recommends applying low-input agro-ecological farming practices, whose use in the developing world has produced dramatic increases in yields and food security.

The pro-GM U.S. Department of Agriculture (USDA) says: “Currently available GM crops do not increase the yield potential.... In fact, yield may even decrease if the varieties used to carry the herbicide tolerant or insect-resistant genes are not the highest yielding cultivars….” Perhaps the biggest issue raised by these results is how to explain the rapid adoption of GE crops when farm financial impacts appear to be mixed or even negative.

“The intrinsic yields of corn and soybeans did rise during the twentieth century, but not as a result of GE traits. Rather, they were due to successes in traditional breeding.... Cutting through the rhetoric, overall pesticide use (herbicides, insecticides and fungicides) has not been reduced through GE. Insect-resistant GE crops have reduced overall insecticide use somewhat, but on balance GE crops have not reduced our dependence on pesticides…. It makes little sense to support genetic engineering at the expense of technologies that have proven to substantially increase yields, especially in developing countries… these include modern, conventional plant breeding methods, sustainable and organic farming and other sophisticated farming practices that do not require farmers to pay significant upfront costs….” (Union of Concerned Scientists, Doug Gurian Sherman.)


The Bt gene is toxic
A search of the scientific literature on the Bt transgene reveals plenty of evidence of harm, leading to various immunity problems: “There is no scientific basis for claiming that Bt crops are ‘proven safe to eat’” (Pusztai). David Schubert of the prestigious Salk Institute says: “There are at least four mechanisms by which the introduction of the Bt toxin into Bt brinjal can cause harm.

These include
(1) the random insertion of the Bt gene into the plant DNA and the resulting unintended consequences;
(2) alterations in crop metabolism by the Bt protein that results in new, equally unintended and potentially toxic products;
(3) the direct toxicity of the Bt protein; and
(4) an immune response elicited by the Bt protein. There are scientifically documented examples of all four toxic mechanisms for Bt crops.”

The U.S. Environmental Protection Agency (EPA) recommended extensive safety testing of Bt crops but there is no required safety testing for GE food crops in the U.S. and, therefore, this was never done (Schubert). In India, there is documented evidence of toxic effects in animals grazing in harvested Bt cotton fields, and human allergies too. The E.C. II Report claims that these have been thoroughly investigated and have no substance. Yet, documents received under the Right to Information Act squarely refute these claims. This is a serious falsification of the truth. No investigation of any depth, leave alone of scientific rigour, has been conducted to ascertain the safety of the Bt gene in Bt cotton and the reason for the animal deaths. We quite simply have not done the studies. Moreover, we do not have the means to test for allergenic reactions to Bt toxins.


Long-Term Testing

Testing for long-term toxic effects, which include problems such as slow-growing cancers, requires more than 90-day rat-feeding studies to reveal problems that may arise and are only detectable in the long term. Yet, our regulators do not require such testing, nor do they require other techniques that similarly reveal ‘unintended’ effects, because they are too expensive or would take too long. Given that a food crop like Bt brinjal, once commercially released, will contaminate (there is no doubt about this, no matter the protestations of the regulator and Monsanto) our immense diversity in brinjal – upwards of 2,500 varieties because we are a centre of origin of brinjal – the willingness of our regulators to risk public health is very strange and certainly unconscionable. The question is, whose interests are they serving, and why? Yet, every independent scientist and the Director General of the Indian Council of Medical Research (ICMR), with one voice, accept that long-term testing is de rigueur.

Prof. Jack Heinemann in his critique of the E.C. II Report and Monsanto’s Dossier says: “In my opinion, the dossier and the subsequent E.C. II Report fail to meet fundamental and even routine hazard assessment standards for molecular characterisation. Since this is the starting point of any risk assessment, the downstream effects on the analysis can be significant. Many of the analyses that were undertaken seem to have been half-efforts, with shortcuts taken and then retrospectively justified using non-validated or incorrect assumptions. All scientific studies that form part of a safety evaluation must involve a comparator.… It is impossible to determine if these rules were followed in the dossier for Bt brinjal.”