1.URGENT RETHINK NEEDED OVER GOLDEN RICE - Dr Md Shahjahan Ali, Professor, Department of Agricultural Chemistry, Bangladesh Agricultural University.
2.INDIA'S NATIONAL BIOTECH DEVELOPMENT STRATEGY: Need for Radical Overhaul - Dr Suman Sahai, convenor, Gene Campaign, New Delhi.
3.HARVEST OF DISCONTENT - Murder of the Magic Seeds - India's Seeds Bill

GMO and biological pollution
Dr Md Shahjahan Ali
The Daily Star, 6 May 2005

excerpts: Months back a renowned columnist cautioned us about the danger of cultivation of golden rice in Bangladesh and its direct impact on our environment.

...Scientists have learned very quickly to isolate, analyse, clone and engineer the particular gene or genes and study their property. This along with other modern biology like tissue culture, protoplast culture and fusion have ushered a new era of modern science namely biotechnology with tremendous potentialities.

...plantation crops have always suffered from a lack of breeding attention. Very little attention has been paid for the identification of improved lines and their breeding. The new technologies should be a supplement rather than an alternative to the old practices.

...the cultivation of golden rice starts immediately in our country... this golden rice imported from IRRI may cause deformity of other varieties of rice. It is a matter of great concern to us that if this variety starts polluting environment it would be very difficult to take remedial measure and a time will come when our country will face a serious crisis with production of other cereal crops.

But it seems very surprising that Dr. Mahboob Hossain, head of the department of social science of IRRI, Philippines has been taking initiative to introduce GMO in agricultural sector in our country. This is also a matter of astonishment to note that neither IRRI nor CPD has taken research on biodiversity based on production system considering environment and ecology. The reason lies on the inability of our farmer to pay them for this purpose. Dr Mahboob has categorically admitted that there may be perceived risk in GMO then the question arises why he is interested in what brings no good for us.

It should be very specifically clear to all why GMO is considered dangerous. There are lots of reasons behind it. First there is possibility of extinction of animals. Secondly during induction of gene of one organism to other this may pollute the whole environmental system which is called biological pollution. In other words the gene which is not supposed to be present in a particular animal may pollute it with the presence of peculiar characteristics which are not at all desirable.

It is, therefore, urgently felt that before the introduction of such variety of rice for cultivation, the authorities concerned kindly think over the matter again and again and take effective steps considering the fate of the poor farmers of Bangladesh.

Dr Md Shahjahan Ali is Professor, Department of Agricultural Chemistry, Bangladesh Agricultural University.

Suman Sahai

EXCERPT: The draft report makes an assertion that the existing regulatory system is sound and adequate. It also states that "there is consensus" that existing legislation is efficient, when nothing could be further from the truth. There is certainly no consensus on the efficiency of the legislation nor the guidelines derived from it.

None of the suggestions made in other places, including the Swaminathan Committee Task Force Report, for overhauling the regulatory system to make it more technically competent, transparent and accountable have been taken on board. India's regulatory system for biotechnology has been criticized by a large number of stakeholders as being ad hoc, lacking in the technical skills required and without adequate provisions to deal with violations and unexpected situations.

At a national stakeholder consultation organized by Gene Campaign in 2003, there was an almost unanimous view that the regulatory system was technically incompetent and nontransparent. The consensus was that it needed a radical overhaul to change its overbearing bureaucratic composition and the largely ex officio nature of the membership. The view on the incompetence and inadequacy of the regulatory system was shared equally by those opposed to Agbiotech as those strongly in favor of it.

In its recommendations, the biotech strategy report follows a standard western view on risk assessment, making liberal use of the ‘science-based’ approach promoted by the GM lobby and by the US. Despite their being mentioned in the Convention on Biological Diversity and the Biosafety Protocol, nowhere does the draft biotechnology strategy report acknowledge the special developing country concerns like the Precautionary Principle, especially relating to the centers of origin for crop plants, socio-economic concerns relating to small farmers and consumers and the right of the public to participate in decision making.

India is a biodiversity rich region from where major crop plants like rice have originated. It is therefore an important center of origin, where unique genetic wealth and diversity is found. There is global concern on GM crops being grown in their centers of origin and diversity because of the threat to this unique gene pool from contamination by foreign genes. Such contamination has already been found in Mexico’s corn and the authorities there are scrambling to find a way to contain the problem. The draft biotech report is silent on this crucial issue of particular relevance to India and ultimately to the world, since rice is the staple food of almost half of mankind. Similarly, there is no acknowledgement of other concerns being discussed on international platforms, for instance socio-economic impact of GM crops. It is recognized that there can be social and economic impacts on farmers, especially small farmers resulting from the application of GM technology in agriculture.

The section on Agbiotech policy is one that raises the most concerns. The draft makes recommendations that are irresponsible and potentially dangerous to the environment and human health. Far from adopting a precautionary approach, as advocated even by international treaties like the Biosafety Protocol, the report makes a departure from the established principles of biosafety and risk assessment that are practiced in other countries. A truly alarming recommendation is to do with the introduction of foreign genes into different kinds of crop plants. The draft strategy document recommends that "an event that has already undergone extensive biosafety tests should not be treated as a new event even if it is in a changed background
." This essentially means that once a gene like the Bt gene is tested for biosafety in cotton, it need not be tested when it is put into another crop like tomato or rice or cauliflower. According to this recommendation, Bt rice or Bt cauliflower (both in the pipeline in India) would not have to undergo any biosafety tests before being released to farmers for cultivation.

This kind of carte blanche to the producers of GM products, putting at risk not just farmers' livelihoods but also the environment and the health of consumers, is unprecedented. It defies all understanding of how biological systems and genetic engineering work. Genetic transformation is a rather imprecise technology because there is no control over where the foreign gene is inserted in the host plant nor how many copies of the gene have been able to integrate into the host genome. The genetic background of the host plant plays a crucial role in both the process of genetic engineering and the actual expression of the foreign gene in the new host.

There are complex interactions between the foreign gene and the genetic background of the host plant it enters; these interactions will be different in the case of different plants and there is no way of predicting the interactions or their outcome. That is why biosafety tests must be conducted every time a new plant is genetically engineered. That is also the reason why the regulatory systems in all responsible countries require biosafety assessments to be done every time a gene is put into a new plant. This clause dispensing with safety testing reduces the biosafety process to a complete farce.

More reckless recommendations follow with respect to biosafety. The biotech policy document states that even if the foreign gene has been changed and modified and then inserted into a new host plant, there is no requirement to conduct tests for allergenicity and toxicity if there is ‘no significant modifications in protein conformation’. This would mean for instance that if the existing Bt gene were changed to make it a different gene and the new gene was put into say, tomato, there would be no need to conduct allergenicity and toxicity tests for the genetically engineered tomato, if the protein produced by the new gene was not "significantly" different. It could be different but not significantly so and what will be considered "significant" is anybody's guess.

This second carte blanche to the producers of GM products has the potential to seriously jeopardize human health because it does not require testing for new allergens and toxins that could be produced when a plant is engineered with the new genes. Such an approach flies in the face of known genetic principles that have shown that genes will behave in different ways and produce different proteins in different backgrounds. If even small changes are made to genes, the products (proteins) they produce can change substantially.

If the human genome project has taught us one thing, it is that the complexity and sophistication of biological reactions rests not on a large number of genes,( humans are estimated to have just 30,000 genes) but on the subtly different ways in which genes interact with one another in changing situations to produce new proteins. Nothing in such a context can be considered ‘insignificant’ because a change that is not radical can have radical outcomes. Specially with respect to allergens and toxins in crop plants, it is well understood that the creation of new allergens and toxins is a complex affair influenced by a number of micro factors. Acknowledging this , the WHO and FAO are compiling an atlas of the known allergens in food plants so that these can be monitored when genetically modified plants are created and used as food.

In the case of the allergy inducing GM Starlink corn, for instance, it was found that the allergic action was seen when the gene was tested in a particular background but not in another background. Food safety, allergenicity and toxicity in connection with alien genes in GM crops and foods is only now being investigated and understood. In this uncertain backdrop, it is insupportable that the national strategy report makes the astonishing recommendation of dispensing with testing for the presence of allergens and toxins.

The biotech policy that is being proposed by the report will be more lax and negligent than almost any other in the world. This is even more frightening when one thinks that this is being proposed in a country where agriculture and food are sensitive issues, where small farmers are vulnerable and where the agricultural research system and the regulatory systems have large question marks hanging over their performance. A premier agricultural research institute in Delhi was hauled up not long ago for large scale biosafety violations with a GM crop and its test plants had to be destroyed. The regulatory system has failed to check the spread of illegal varieties of Bt cotton for the last five to six years.


Murder of the Magic Seeds

The proposed Seeds Bill will destroy the Indian farmers' right to livelihood and the fruits of the earth. Why does nobody appear bothered?

By Deeptiman Tiwary
New Delhi

[image caption: Doomsday? the new Seeds Bill will push the farmer into abject despair]

In a country where 70 percent people depend upon agriculture for survival while 75 percent of the seeds used in farming are produced by farmers, the government is pushing through a Bill that has the potential not only to make its farmers uncompetitive in the seed market but even deprive them of their traditional right to save, sell and share seeds. The contentious Bill in question is the Seeds Bill 2004. The proposal, meant to regulate the seed trade and provide impetus to seed export, is already mired in deep controversy. There are voices being raised all over the rural hinterland and among activists that it is basically anti-farmer and hits him where it hurts the most.

There are various provisions in the Bill that have raised doubts about the government's intentions and irked farmers' rights activists who are fiercely protesting against it. The bone of contention is the registration of all varieties of seeds without which no one shall be allowed to sell, save or share seeds. This is being seen as a major infringement of farmers’ rights.

This means that farmers involved in the traditional practice of seed sale and barter across their farm fence can be charged under the new Bill. Under this situation, the farmers may attract penal action (which could go up to a fine of Rs 25,000) including the liability to be searched by the Seed Inspector who has been given powers to break open anyone's door, enter his house and search if he feels the seed act is being violated.

"It is a Bill drafted under pressure from seed manufacturing mncs like Monsanto. It has the potential to spell doom for Indian agriculture. Most of the seed varieties used in Indian agriculture today are farmer-produced. If farmers are not allowed to save and sell their own seeds, there can’t be any agriculture here. The only aim of this Bill is to force the farmer to buy seeds from the market," says Vandana Shiva of Research Foundation for Science, Technology and Ecology (rfste).

Although the proposal gives exemption to farmers to save, sell or share their seeds without registration, there is also a clause that the farmer will not sell such seed that does not conform to the minimum limit of germination, and physical and genetic purity prescribed under the Bill once it has been enacted. The question as to who will ascertain these qualities when a farmer goes to sell his seeds has been left unanswered. Indeed, if he has to go to an institution or a committee, then it is as good as registering the seed variety.

"The idea is to make the whole process so bureaucratic that the farmer is rendered uncompetitive in the market. Which farmer will have the energy, time and money to go to a committee or an institution to ascertain the quality of his seed, get a certificate of approval and then sell, save or share it. This will only lead to widespread corruption and farmers will have to bear the brunt," says Shiva. Former Assistant Director General (ipr) of the Indian Council of Agricultural Research (icar), S. Bala Ravi, adds, "The so-called exemption given to farmers in the Bill merely allows saving and sowing in his own farm. This Bill takes away the other seeds rights of farmers, such as sharing, exchanging and selling the farm saved seed. The result of this provision is that the entire seed demand in the country is exclusively reserved to the seed industry."

Suman Sahay of Gene Campaign says, "Compulsory registration of all seed varieties is not entirely bad. It will only protect the farmer from spurious seeds. But the way it is proposed to be done in the Seeds Bill, is shocking. Why is the government pushing through the Seeds Bill while the Protection of Plant Variety and Farmers' Rights (ppvfr) Act is awaiting implementation for four years since its enactment. The industry has been angry with the Farmers’ Rights Act which recognises the farmers’ rights not just as a cultivator but also as conserver and breeder of various successful seed varieties. The new proposal covers that ground. It negates the Farmers’ Rights Act. The industry provides only 20-25 percent of seeds used in Indian agriculture. Rest of it is farmer-produced. It is this chunk of the market that the industry is eyeing. And the government is helping it at the cost of its own people.”

The other controversial issue is seed certification. This is mandatory in the new Bill. Under the existing Act (Seed Act, 1968) only central or state seed laboratories can provide seed certificates. But under the new Bill, accredited individuals or institutions will also be able to provide such certificates. "This will allow self-certification. Any seed company may establish an institution tomorrow and start certifying its own seeds. But who will monitor them is the big question," says Shiva.

Another concern is compensation to farmers when the agronomic performance claimed by the seed provider on a variety is not realised under cultivation. The proposal asks the farmer to claim it through consumer courts. Sahay says, "Knowing the tedious processes of consumer courts and the very inaccessibility of them to the rural masses, one reaches the conclusion that it is a provision that will deter the farmer from claiming the compensation."

A discerning look at the Indian seed industry and the direction in which the Seeds Bill will push it gives a fair idea of the major players of tomorrow. Today, there are over 400 odd seed trading companies in India. Majority of them do not have their own R&D capability. Few of those who have it do not have the technical and financial strength to survive competition. Nearly a dozen seed companies can be called majors in their scale of operation today. They may immediately survive, but not all of them can do so in the long run. Mergers have already started (Monsanto India holds 26 percent stake in Mahyco, India’s biggest seed company). It will only be hastened in the coming days.

Surely, this could become yet another ‘Coca-Cola story’. Remember the story of erstwhile Thumps Up, Gold Spot, Limca, Sprint, etc., and all those independent beverage manufactures when Coke and Pepsi entered the country market? And the mergers of all these small softdrink manufacturers into the two mega players in a very brief time? This could be the story yet again rewritten of the Indian seed industry.