Concerns on GM cropslearning from Bt cotton

RamanjaneyuluCentre for Sustainable Agriculture

Decisions on GM crops• Environmental Risk Assessment: The process of Genetic transformation

is imprecise hence needs a relevant risk assessment frame work based on the ecological and socio-economic conditions of adoption.

• Relevance of technology: India being a country of small farmers and small farms, the relevance of the technology should be assessed in the conditions and against the available best technologies.

• Transparent and Accountable Regulatory system: The processes adopted by the regulatory system should be transparent and accountable for the decisions being taken in assessing the potential risks.

• Socio-Economic Impact: The socio-economic impact of any technology should be assessed in specific context. This impact assessment should also include the impacts of seed prices and the IPRs involved.

GE is imprecise“Cut & Paste” - Insertion of alien genes for

creating specific traitsOne gene = one trait expression?Gene regulation within genome not fully

understood or replicableTransgene insertion – the process & the

transgene – changes & associated risksTransgene location - can’t be directed and is

unstableUnexpected and unintended traits - Coding

for proteins of unknown functions discovered

Alterations to the toxicity or nutritional value of a cultivar – allergens, toxins, vitamins, anti-oxidants etc. (food safety)

Changes that have ecological implications – BIODIVERSITY, increased outcrossing, effects on beneficial insects, soil organisms, pest resurgence, new diseases etc.

Changes that have implications for food security – stress intolerance & crop failures

GE Science: Unintended consequences

BT COTTON IN INDIALearning from experiences

2002 to 2012

Farmers in AP, Karnataka, Punjab reporting yield decrease in crop grown after Bt cotton

Several complaints Recent paper from IARI Sarkar. et.al,

2008 Transgenic Bt -Cotton Affects Enzyme Activity and Nutrient Availability in a Sub-Tropical Inceptisol

J. Agronomy & Crop Science (2008) ISSN 0931-2250

• similar studies from Australia and China• Susceptibility to drought and heavy

rains • Planning commission report on

Vidharba says ‘Bt cotton not suitable for rainfed areas’

Soil Health

Life of Bt crops: Resistant development

• Bt technology works similar to pesticides

• Toxin present all through the life of the plant hence resistance development is faster

• Government conditionality on maintaining ‘refuge crop’-responsibility of the company

• Monsanto already declared that Pink bollworm developed resistance.

Sheep, goat and cattle morbidity reported from

AP, Maharashtra, Punjab, Haryana after feeding

on bt cotton

Miscarriages reported from Gujarat

2007: Animal Husbandry Department of AP asks

farmers not to graze animals on Bt Cotton – “as

yet unidentified toxin” causing morbidity

AP government writes to centre not to permit the

Bt cotton till proven safe

GEAC was asked to take up a study they no

followup

Biosafety data on Bt brinjal shows possible

problems

Animal morbidity

Sheep/Goats/Cattle reported to have • Anorexia, nasal discharge, cold, cough, • respiratory distress (in some cases)• Occasionally red urine • No Fever

Animal Husbandry Dept.’s AdvisoryMedia Announcement

It has come to our notice that in several blocks of the district, animals are falling sick after grazing on Bt Cotton fields. After harvesting cotton completely from the fields, there is a long

tradition in the district of grazing animals in those cotton fields. However, because Bt Cotton is being grown in large tracts and because of a yet-unidentified toxic material in

these plants, it has come to our notice that animals which are grazing on these fields are exhibiting symptoms like shivers, convulsions, running nose, bloat, bloody diarrhea etc., and

are dying. Therefore, we appeal to farmers not to graze their animals on Bt Cotton fields. We request farmer brethren to please do approach the nearest veterinary doctor and get

treatment, if any animal has grazed on such fields accidentally.

Sd/- M VenkataswamyJoint Director

Animal Husbandry Dept Adilabad.

Dept of Agri Biotechnology, ANGRAU to VBRI – 10/7/06

Dept of Agri Biotechnology, ANGRAU to VBRI – 10/7/06

Letter to GEAC from AH Dept Director, AP Govt. on 9/5/2007

Skin allergies reported by farmers

and agriculture workers while

working in cotton fields during boll

burst stage

2005: JSA – Bt Cotton in India –

human allergies

[Ashish Gupta, Ashish Mandloi &

Amulya Nidhi, 2005: “An Investigation

report on Impact of Bt Cotton on

farmers’ health”]

2007: Dr Manvir Gupta’s pilot study

in Punjab

Human health

Ecological Balance disturbed: increasing pests and diseases

Sucking pestsNew diseases

Studies on Resistance management• Genetic Engineering Appraisal Committee (GEAC) had imposed refugia conditions (

http://envfor.nic.in/divisions/csurv/btcotton/bgnote.pdf). But, the conditions were put without any basis. For example the refuge strategy should be developed only after considering

– the recessive/dominance factor of resistance– the initial frequency of the resistant allele and– the mating behavior of the insect moth. In addition differential plans based on whether

refuge crop is sprayed or unsprayed were never mentioned.• Fakruddin et al (2002) of Dept. of Biotchnology, UAS, Dharwad and Dept. of Entomology,

Collage of Agriculture, Raichur revealed the resistance of H.armigera to Cry1Ac toxin in 11 distinct geographic populations representing the entire South Indian Cotton Ecosystem.

• Kranthi et.al, (2005) reported that the quantitative levels of Cry1Ac and the seasonal decline in expression differed significantly among the eight commercial Bollgard hybrids tested.

• Ranjith et.al (2010) has established that the bollworm, the major cotton pest in India is not only thriving on both the single gene Bt cotton( Cry1Ac) and the double gene Bt cotton (Cry1Ac & Cry2Ab). The authors said that it has been demonstrated that the bollworms not only survive after feeding on Bt cotton plants, they are able to complete their lifecycle and reproduce and create the next generation of resistant pests.

Resistance development • Resistance to Pink Bollworm: In March 2010 Monsanto India

admitted in a press release that Bollgard1, the Bt cotton with the single protein Cry1Ac, has developed resistance to pink bollworm(Pectinophora gossypiella). Resistance was confirmed in four districts in Gujarat - Amreli, Bhavnagar, Junagarh and Rajkot.

• The resistance development in bollgard also has an implication on other varieties and hybrids being developed by public sector institutions in cotton and other crops as well using the same/similar genes.

• The issues of resistance was not discussed either by the company or CICR (which is supposed to have reported on resistance every year) or GEAC (which is supposed to have reviewed the reports) during Bt Brinjal consultations; this clearly amounts to withholding of information.

Pesticide usage remains high

Pesticide Usage, Pest Resistance, New Pests• At farmer level, pesticide usage drops in first two years

but rises back to pre-Bt level• Increased use of low-volume pesticides which require a

much smaller quantity per acre. • Monsanto says bollworm becomes resistant to Bollgard-I• Resistance monitoring studies done at CICR have

demonstrated bollworm resistant• Emergence of secondary pests: susceptibility to sucking

pests, mealy bugs, whiteflies and miscellaneous insects• Pesticide expenditure increases: From Rs 597 crore in

2002 to Rs 791 crore in 2009”.

2000-01

2001-02

2002-03

2003-04

2004-05

2005-06

2006-07

2007-08

2008-09

2009-10

2010-11

2011-120

100

200

300

400

500

600

700

0%

20%

40%

60%

80%

100%

120%

140%

278308 302

399

470 472521

554524 503 517

481

0% 0% 0% 1%6%

18%

41%

62%

84% 85% 85%90%

Increase in Cotton Yield: The Full Picture

Yield in kgs per hectare % area under BT

During Bt Cotton PeriodOnly 2% Increase

Data for % area under BT for 2010-11 and 2011-12 are estimates and for 2005-06 is interpolated

Pre-Bt Cotton Period70% Increase

Reality of Cotton Yields• Maximum yield increase happened by 2004-05 when Bt

cotton was 5.67% of the total cotton area.• In the Bt cotton period, no sustained yield improvement• Dr. Keshav Kranti, Director CICR: “The main issue... is the

stagnation of productivity at an average of 500 kg lint per ha for the past seven years... unaffected by the increase in area of Bt cotton from 5.6% in 2004 to 85% in 2010.”

• Other factors improving the yield (ref Dr.Kranti): – Increased use of better-yielding hybrids (from 40% to 85.5%)– Expansion of irrigated area under cotton– Bringing new lands under Bt cotton– Years of better rainfall and low pest incidence

Some recent findings • In an article in the June 2011 issue of the Journal of Biosciences,

‘Detrimental effect of expression of Bt endotoxin Cry1Ac on in vitro regeneration in vivo growth and development of tobacco and cotton transgenics,' Delhi University scientists reported that the expression of the Cry1Ac endotoxin has detrimental effects on the development of transgenic plants. The plants that showed appreciable CryIAc expression were phenotypically abnormal: they were malformed. This suggests preferential selection is at work while transgenic plants mature: those that express low level of Cry1Ac have better chances of coming through compared with ones expressing appreciable levels of the gene (http://www.ias.ac.in/jbiosci/jun2011/363.pdf).

• A recent study (2011) from Canada published in the Journal ‘Reproductive Toxicology’ has shown that Bt proteins have survived the human digestive system and passed into the blood supply and found in the unborn babies (http://www.ncbi.nlm.nih.gov/pubmed/21338670).

• Contamination of centres of genetic diversity. E.g. Cotton, rice, brinjal –India is centre of origin/diversity

• Unsolicited gene transfer to farmers’/other varieties• Co-existence not possible: e.g organic cotton in India,

LL rice in US, Maize in CIMMYT

Genetic Contamination inevitable

What happened with Bt Bikeneri Narma?• IPRs related to the event never studied • The event BNLA-106 was reported to have been contaminated with

Mon-531 event• 2005: this was communicated to the then Director of CICR• 4th-5th May, 2008: After commercial approval by GEAC samples were

sent for testing to Awasthagen which confirmed presence of Mon-531 in eight of the samples

• 21st May, 2008: a meeting chaired by DDG (crop sciences) concluded that ‘possible presence of Mon-531 is not an issue any more because of the strong molecular evidence produced by Dr. Anand Kumar, NRCPB

• 2009: MAHABEEJ reported that the BN Bt seed was not pure with respect to several traits including Cry1Ac

• December 2009: Meeting chaired by DDG (CS) decides to stop production and commercial sale of BN Bt and Bt NHH-44

Monopolyzing market• Spread often is not measure of success• 11.0 mha, ranks second in the world in production and first in area• In $ 1 billion cotton seed market occupies 60 % by value• Monopolising markets: 95 % controlled by one company

– Seed prices increased from Rs. 450/packet to Rs. 1800/packet. Bt Brinjal was priced at Rs. 50,000/kg

– AP govt MRTP case to reduce seed royalty reduced to Rs. 100/packet– Seed companies questioned the state powers in court

Public sector withdrawl– More than 100 cotton varieties/hybrids were denotified. Last three years

not even 1 kg of seed is sold by any organisation across the country– Non Bt cotton seed withdrawn from market both by public and private

sector

Other important issues

• Relevance of technology and crop choices• Testing against the best pratices• Open air Field trials permitted before

biosafety tests are done• Agronomic trails are not comparing against

the best practices• Conflicts of interest and Corruption

So what we request• Relevance of a particular technology in particular crops should be

assessed first before giving permission for any GM research in the country.

• The biosafety testing protocols needs to be revised as suggested by Dr. Pushpa Bhargava to ensure long term safety

• Ban all the GM field trails till all the systems are put in place and also allow open field trails only after the appropriate biosafety tests are done

• Field trials for agronomic evaluation should be made against the best possible alternatives for the problem for which GM technology is used and after assessing the socio economic and ecological impact of the technology.

• Suggest moratorium of at least 10 years on commercial release of all GM crops till all the systems are in place for independent research and regulation