From: Kavitha Kuruganti
Dear friends,
Please find below the findings from an investigation into a Bt Bhindi [Bt Okra] trial plot in Gulbarga district of Karnataka, by Centre for Sustainable Agriculture.
In May 2006, responding to an application under Right to Information, the state government of Karnataka admitted that it has no information on where GM crop trials are happening in the state. The current investigation once again shows that concerned departments and officials in the state [the horticulture department in this case] do not have any information on the trials happening in the state and this is a clear violation of the conditional clearance that Mahyco had obtained from the government of India. Mahyco has been asked, in the clearance letter from the department of biotechnology, to keep the state government, district authorities and the village panchayat informed about the exact details of the trial but we find that this is missing. More importantly, the Genetic Engineering Approval Committee itself does not have information on where various trials are happening in the country after permitting such trials!!!
The investigation by CSA comes at a time when the Supreme Court had asked the GEAC not to permit any more trials in the country but has also said that it 'was not inclined to stop any ongoing trials'. [Further to this, in its October 13th hearing on the GMOs PIL, the Supreme Court has also allowed the Delhi University to plant its GM Mustard seeds, and would take a decision on it based on the petitioners' response to the impleadment application of the Delhi University].
The Bt Bhindi trial in Gulbarga is one such ongoing trial, showcasing many violations of the EPA and the conditional clearance as our investigation shows. Further, the scientificity of the trial is also questionable going by the practices being adopted in the trial, as reported to the CSA team.
Our earlier investigations into field trials have shown that this period is the usual period when harvested crop produce, which is untested and not cleared for biosafety, is allowed to contaminate the regular supply chain due to absent or lax monitoring.
CSA demands that given this lack of ability to monitor or understand the results from trials and given that there are no signs of improvements in the monitoring and liability mechanisms despite repeated reports from civil society groups over the years, it is time that the regulators and the Courts put a firm brake on the trials and take a complete assessment of GM crops and their trials in the country.
For more information, pls contact me [Kavitha Kuruganti] at the above email id or at (0) 9393001550.
Kavitha Kuruganti
Centre for Sustainable Agriculture
Secunderabad.
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An Investigation into a GM Okra Field Trial in Karnataka
- Centre for Sustainable Agriculture, Hyderabad
Date: 20/10/06 & 25/10/06
Place: Gulbarga town and Nandikur village; Bangalore Department of Horticulture office
Members in the team: Mr Chandrasekhar (agriculture scientist, CSA), Ms Kavitha Kuruganti (Consultant, CSA) and Ms Saraswathi Kavula (Independent film maker)
People met during the visit: Sri J M Tippeswamaiah, Joint Director of Agriculture, Gulbarga district; Sri Basavanappa Nagur, Sri Shekaiah Guttedar and other farmers of Nandikur village; Sri Laxman Poojary, Member of Nandikur Panchayat; Sri Suryakant Guttedar, Chairperson of Nandikur Panchayat; Sri Bheema Shankar, Temporary Field Assistant employed by Mahyco for the Bt Okra trial; Sri Somanna (Somasekhar) Nadakatti, farmer on whose land the trial is being conducted.
Telephonic conversation, twice with Mr Krishnamurthy, Deputy Director-Horticulture, Gulbarga district on 25th October 2006 and personal meeting with Ms Lakshmi Raju, JD-Horticulture, Directorate of Horticulture, Government of Karnataka, Lalbagh, Bangalore on 25th October 2006
Preamble
In 2005-06, a group of 20 civil society organizations formed themselves into the Monitoring & Evaluation Committee [MEC], stating that the official monitoring and accountability mechanisms, especially when it comes to open air trials of GM crops and post-commercialisation surveillance are absent or weak at present. To prove their point, this MEC documented many evidences of serious biosafety violations and unacceptable unscientificity in the field trials related to 2-gene Bt Cotton in the form of "Bollgard II" and "Fusion Bt" [brand names of some seed companies]. Further, Centre for Sustainable Agriculture investigated three GM food crop trials Bt Okra, Bt Rice and Bt Brinjal, all of Mahyco’s and found that biosafety violations and unscientificity in trials is a routine matter here too.
Despite a few rounds of dialogues with the regulators and the seed companies, going by the official records of the regulators, things did not improve. While all the issues pointed out by the civil society’s MEC were interpreted only as communication problems between the companies and the state governments, the regulatory authorities began to give many new approvals for open air field trials all over the country for a variety of crops for Kharif 2006 too without making any real improvements in the monitoring and accountability mechanisms that should govern biosafety and scientificity of trials.
In May 2006, responding to urgent interim applications from petitioners in a Public Interest Litigation, the Supreme Court of India ordered that only the Genetic Engineering Approval Committee [GEAC] should accord permissions to any field trials. This should have effectively put a stop to the Review Committee on Genetic Manipulation [RCGM] of the Department of Biotechnology giving permissions for multilocational trials for limited field trials, even as it promotes such GM crops itself! However, things did not improve much even after the interim orders from the apex court.
As per media reports, the GEAC cleared as many as 142 proposals for multi-locational trials from the time of the Supreme Court orders, uptil 22nd September 2005. It was around this time that the Supreme Court stepped in again to call a halt to any more approvals of field trials by the GEAC. However, the Court also said that it was not inclined to stop the ongoing trials at that point of time. This investigation comes at a time when the Court allowed a Delhi University planting of a GM mustard trial, even as it gave two weeks’ time to the PIL petitioners to respond to the Delhi University impleadment application.
The current investigation
Information was sought from the Member-Secretary, GEAC on the ongoing field trials, locations, farmers’ contact details etc. on 27/7/2006 by Centre for Sustainable Agriculture under the Right to Information Act. The application sought to obtain all details related to trials permitted by GEAC in its meeting on 1/6/2006 . In response to this application, the GEAC provided information on 6 trial plots of Bt Okra of Mahyco and 9 trial plots of Bt Rice, again belonging to Mahyco [only 15 trial plots in all!]. This information was subsequently put up by Centre for Sustainable Agriculture on a new website called www.indiagminfo.org .
Based on this information, a team from Centre for Sustainable Agriculture visited the Bt Okra trial plot in Nandikur village, Gulbarga district of Karnataka. The following are the findings that this investigation raises.
1. THE GENETIC ENGINEERING APPROVAL COMMITTEE [GEAC] ITSELF HAS NO INFORMATION ON THE TRIALS HAPPENING IN THE COUNTRY:
In response to an application under Right to Information Act, the GEAC provided details of only 15 trials [for two crops] to the Centre for Sustainable Agriculture.
When asked about the information on the scores of other trials happening all over the country, the Member-Secretary, in a personal communication to CSA on September 12th 2006 revealed that the GEAC itself is yet to receive information from the companies on where the trials are being conducted! This, despite the fact that permission letters stipulate a one-month period for the applicants in which to file information with the regulators about the exact locations for trials. This once again reinforces the point that civil society groups have been making that the regulators themselves have no control over the open air trials happening in the country. How can any scientific and systematic monitoring be expected in such a situation? Not giving full information on where the trials are happening is a clear violation of the conditional permission given by the RCGM. The RCGM permission letter under clause (f) says: "You should provide details of locations where you have undertook multi location field trials with in 30 days of issue of this clearance letter to the GEAC/RCGM/state department of agriculture/state agriculture universities/district authorities and other field functionaries".
It is also not clear whether the company has taken up Bt Okra trials, in this case, in all the authorized locations since information on only six locations is available. Can this then be considered as "Multi-Locational Trials" in that sense?
2. THE Bt OKRA PLOT IS SOWN ON THE SAME DATE AS THE PERMISSION LETTER ISSUED BY THE RCGM:
The temporary field assistant employed by Mahyco to oversee the trial in Nandikur village informed the CSA team that the plot was sown on July 11th 2006 . This is somewhat surprising given that the RCGM’s permission letter is dated July 11th 2006 too!
While the speed at which information moves from the regulators to the companies is impressive, it is very interesting to note that the same speed is not maintained when it comes to informing all other stakeholders about the trials.
3. PANCHAYAT HAS NO INFORMATION ON THE TRIAL:
A discussion with Panchayat representatives including the Chairperson Sri Suryakant Guttedar, reveals that the Panchayat has not been informed by the company about the trial happening in their jurisdiction.
This is a violation of clause (f) of the permission letter to the company from the RCGM which clearly states: "You should further inform the respective Village Panchayat officials about full details on the transgenic crop, name of the farmer and the location(s) where field trials have been undertaken".
4. JOINT DIRECTOR OF AGRICULTURE (GULBARGA DISTRICT) HAS NO INFORMATION ON THE TRIAL:
The Joint Director-Agriculture informed the team that his office has no information on the trial happening in Nandikur village. He further told us that no DLC meetings have been convened as per the Environment Protection Act in this district.
5. DEPUTY DIRECTOR-HORTICULTURE, GULBARGA & JOINT DIRECTOR-HORTICULTURE (VEGETABLES), BANGALORE HAVE NO INFORMATION ON THE TRIAL EITHER:
On 25th October 2006 , Mr Krishnamurthy, DD-Horticulture was contacted on phone for information on any GM crop trials [vegetables] happening in his district. After admitting that he has no information on any such trials in the district, the DD was kind enough to enquire with other concerned sources [university, other officials, KVK etc.] and to call back a CSA representative to say that there are no trials happening in the district. CSA representative then informed him about the ongoing trial in Nandikur village and the DD promised to make an inquiry into the issue.
On 25th October, a CSA representative visited the Director-Horticulture’s office in Lalbagh, Bangalore . Here, a meeting with the Joint Director-Horticulture (Ms Lakshmi Raju) revealed that the department has not been informed about the trial either. Asked whether other officials in the department might have information on where exactly such trials were happening in the state, officials here informed that they were the concerned wing and they should have the information, if any. Their files consisted of information on some Bt Brinjal trial from the previous year but nothing from Kharif 2006.
This is a violation of the permission letter issued by the DBT asking the company to file information on exact details of the trial to the state department and district authorities within 30 days of the clearance letter being granted (July 11th 2006 in this case). The concerned authorities in this case belong to the Department of Horticulture and they have no information on the trial.
6. SELECTION OF TRIAL FARMER:
The farmer on whose land the trial is being conducted by the company has been a distributor for Mahyco for the past 15 years or so. He informed the team that he does have information on what is being tried out in his plot but has not bothered to collect more information on what the potential hazards could be. He had leased out his 1.5 acres of land for the trial against a lease rent of Rs. 11,000/-. Asked about why he was selected as the trial farmer rather than any other farmer in the district or state, he felt that it could be because he was associated with the company for a long time as a distributor.
Despite this point coming up again and again in various investigations, it is not clear how the regulators or promoters are ensuring a modicum of scientificity in their selection of trial farmers. In the case of the Bt Okra trial investigated in Gulbarga , the farmer is obviously a resource-rich farmer who is into his own seed business too.
It was also interesting to note that Mr Nadakatti is a seed producer and trader who through his company called Mrutyunjaya Traders deals (ironically) with only traditional varieties of various seeds. He has had a negative experience with Bt Cotton and found that his crop was destroyed by high incidence of sucking pests and diseases.
Selection of a seed producer and trader for the trial has its own potential dangerous ramifications. Given the many scandals of contamination that the world is witnessing with GM crops, the regulators should be careful about such selection of farmers for trials.
7. MONITORING OF THE TRIAL BY THE REGULATORY AUTHORITIES:
A Bt Okra plot in Andhra Pradesh [in Narakoduru village of Guntur district] visited by a monitoring team from Acharya N G Ranga Agriculture University had the following point noted in the monitoring visit report:
"The ideal time for monitoring of the trial should have been 50-70 days of the crop and the present visit ( 9/12/2005 ) is at 90 days and it is not the right time for assessment of effectiveness of Bt Okra".
In the case of the Nandikur trial plot, the field has not been visited by any official team so far (by the time the CSA team made its visit on October 20th 2006 ). The Temporary Field Assistant of Mahyco informed the CSA team that an official team from UAS, Dharwad was expected on 26th October 2006 . This would mean that the official monitoring team is visiting the plot at 105 days of the crop. Going by the observation of another scientific monitoring team last year, how can this be the right time for assessment of the effectiveness of Bt Okra in Nandikur then?
8. FIELD DESIGN FOR THE TRIAL NOT FOLLOWED:
While the CSA team did not get to see if the field design was entirely as per the CRBD design laid down by the RCGM for the trial, it was clear that the trapper rows of Non-Bt Okra were not planted for the stipulated 50 meters around the periphery of the outer transgenic plant rows (Clause (c) of the RCGM’s permission letter). From the CSA team’s calculations, it was maintained for only 20 meters or so. Isolation distance of 400 meters all around the experimental plot is not being maintained in a strict sense. On one side of the plot is a sunflower crop recently harvested. Adjacent to this is a pigeonpea standing crop. On another side of the plot is a maize crop. One side of the plot has a road running next to it. Adjoining the fourth side of the plot is a coconut grove.
The land leased in was 1.5 acres and the trial layout seems to be in a larger area than the gross experimental plot area allowed by the RCGM in its permission letter [612 sq. mts, 30 mts by length for all the treatments and 20.4 mts by breadth for all the replications]. If this was the case, it is not clear if the interpretation for findings would be adjusted to this changed layout.
9. AGRONOMIC PRACTICES FOLLOWED QUESTIONABLE:
The Field Assistant employed by Mahyco, an agriculture diploma holder, told the CSA team that the trial plot has many more pesticides sprayed than the normal bhindi plots of farmers in the village. According to him, the trial plot has been sprayed with pesticides almost on a weekly basis, as opposed to probably just half the number of sprays in other non-bt bhindi plots of farmers. Further, according to the Field Assistant, it is this kind of intensive pesticide use that makes the plot "poisonous" [to a question on how this plot is different from other bhindi plots around and what is being tried out in the plot here].
Such practices will obviously have implications for the interpretations to be made of the results of this trial. This needs to be carefully investigated further. In fact, given the lack of monitoring from any official teams other than the one employee of the company who is generating data on the plot, it is not clear how such practices and their implications on the results obtained can ever be captured by the regulators.
Various violations of EPA and other concerns thrown up by this investigation:
To sum up, the investigation into the Bt Okra trial being conducted by Mahyco in the state of Karnataka along with other information from GEAC reveals the following:
GEAC itself does not have complete information on where the various multi-locational trials are happening.
Concerned state government departments [horticulture department in this case] at the state or district level do not have information. This is not only a violation of the clearance letter given by RCGM to the company but a violation of the Environment Protection Act.
The Panchayat officials have not been informed about the trial happening in their jurisdiction.
There is no monitoring evident by the state officials or the Union government of this plot; as per earlier official reports, end of the season monitoring, beyond 50-70 days of the crop, may not provide any information on the ‘effectiveness of the technology’. Further, such monitoring should have been in place to prevent serious violations of the kind witnessed in the earlier years including unacceptable contamination of the supply chain from the trial plots.
The design of the plot, the agronomic practices, the very selection of the trial farmer etc., raise serious questions on the results of the trial and the interpretations to be made therefrom. Such unscientificity has been captured in earlier investigations too.
Given that most GM contamination scandals that are emerging worldwide are related mostly to open air trials, it is imperative that the regulators (GEAC, RCGM, monitoring teams in all states that have been supposedly entrusted the job of monitoring), concerned government departments (including the Health Ministry of the GoI and the departments in the state) as well as the Courts acknowledge and accept the complete inability that exists now of regulating, monitoring and getting any scientific data on the efficacy as well as potential hazards of GM crops through these open air trials.
In this context, it is important for state governments to realize that while trials are happening in various states without the involvement of the concerned departments here, failure of GM crops in the time to come, to yield benefits to farmers or even the many hazards that are likely to emerge from such open air cultivation will finally have to be dealt with by the state governments! Farmers will turn to the agriculture departments in various states for redressal and not to the Union government and the state governments will do well to remember that.
Given this lack of ability to monitor or understand the results from trials and given that there are no signs of improvements in the monitoring and liability mechanisms despite repeated reports from civil society groups over the years, CSA demands that it is time that the regulators and the Courts put a firm brake on even the ongoing trials and take a complete assessment of GM crops and their trials in the country immediately.