July 28, 2006

To
Shri Bir Singh Parsheera
Chairperson, Genetic Engineering Approval Committee [GEAC]
Ministry for Environment & Forests [MoEF]
Paryavaran Bhawan, CGO Complex
Lodhi Road, New Delhi.

Dear Shri Parsheera

Sub: Sheep mortality reports after grazing on Bt Cotton subsequent investigations

reg.

A fact finding visit to four villages of three blocks in Warangal district of Andhra Pradesh on April 22^nd 2006 had found a strong correlation between mortality of sheep being reported by shepherds from across villages and open grazing on Bt Cotton fields. This fact finding team consisted of members from the Andhra Pradesh Shepherds & Goatherds’ Union, Anthra [an NGO working on livestock issues with qualified veterinary doctors and scientists] and Centre for Sustainable Agriculture [an NGO working on establishing ecological alternatives in agriculture, consisting of qualified agriculture scientists]. It has to be informed here that the fact finding visit was commissioned in the first instance because 11 cases of postmortems were taken up in the district Animal Health Centre between February and March 2006, with recorded cases of Bt Cotton grazing and poisoning. This was discovered quite by chance by a member of the Shepherds’ Union visiting the AHC, who then approached the above mentioned NGOs to make a preliminary investigation. It should also be noted here that the eleven shepherds who brought in their animals for postmortem because they could not diagnose the problem themselves did so in an uncoordinated fashion, but with similar case histories and similar symptoms. This little history to the sheep mortality reports that emerged later is important to note since there were some views expressed that the shepherds had fabricated the problem hoping that they will get some insurance money [for animals which were not insured in the first instance]! In fact, they had brought their animals for post-mortem since they wanted the ‘unusual sickness and death’ to be diagnosed properly.

The findings of this fact finding visit were widely covered by the media and CSA also sent a formal complaint with the report to the GEAC, amongst others, asking for immediate investigations into the matter. CSA, Anthra and the Shepherds’ Union made subsequent visits for more data to the affected villages on May 12^th 2006. CSA also applied for copies of the post-mortem findings register for the period January April 2006 from the Joint Director Animal Husbandry [Warangal]’s office on May 12^th 2006, under the Right to Information Act. We also asked, under the Right to Information Act, for the findings of the Veterinary Biological Research Institute [VBRI, Hyderabad] which had investigated the matter on the behest of the Director Animal Husbandry Department, Government of AP and were following up with them on the ‘investigations’ that they were supposed to be taking up. The Government of India was also supposed to be investigating further into the matter.

Meanwhile, Anthra made a formal submission of the study report to Dr Nem Singh, Director, Indian Veterinary Research Institute, Izzatnagar, on 13. 06. 06 with a request that IVRI, which is the highest body within India doing research on matters concerning Veterinary Science, investigate this matter further. We received an immediate reply from IVRI on June 17^th 2006, stating their willingness to be involved in any further investigations regarding BT cotton. They requested us to inform them immediately in the event of any further mortality associated with grazing on BT cotton, so that they could immediately dispatch their research teams.

On June 24^th 2006, Anthra sent the report to Dr Hafeez, Dean of the Sri Venkateshwara Veterinary University, the recently constituted Veterinary University of Andhra Pradesh, with a formal request that the University depute its researchers to investigate and study the effects of sheep grazing on BT cotton residues.

In this context, we would like to place on record our strong protest about the way the entire investigation was handled and the conclusions drawn, especially by the GEAC.

1.       The 67^th GEAC meeting, held on May 22^nd 2006, completely ignored this sheep mortality report and did not discuss it at all! It is shocking to see that the GEAC does not proactively address such issues though its very raison d’etre is this.

2.       The 68^th GEAC meeting, held on 1^st June 2006, discussed the sheep mortality issue as Agenda item 1.7. The minutes of this meeting recorded that “the general opinion was that the report appears to be highly exaggerated and is based more on hearsay than scientific facts”. We strongly object to this and demand to know what in the report was highly exaggerated. It has to be informed to the GEAC that this was indeed a fact-finding visit report which demanded that a more in-depth investigation is needed. It was upto the government, including bodies like the GEAC, to have commissioned such an in-depth scientific investigation and not the liability of civil society groups.

3.       The 68^th meeting minutes go on to reiterate that several feeding studies have been taken up while testing Bt Cotton, even though our fact finding report clearly points out to the serious shortcomings in the feeding tests which did not include grazing tests that have been done in the name of biosafety testing.

4.       The GEAC meeting also cited an acute oral toxicity study taken up in the Agriculture group/Environmental Health laboratory in the USA that there was no treatment-related adverse effect on mice that have been administered Btk HD 73 protein. We wonder why the GEAC did not take into consideration studies that point out that Bt toxin is also known to bind to the gut cells of mammals, as some studies in mice show? Why invoke only one study which was convenient for the proponents? What about all the data that shows that there are indeed potential hazards?

5.       The RCGM apparently decided in its meeting on 23^rd May that the DBT would sponsor a study to assess the problem in Warangal district with the help of the local veterinary hospital. The GEAC apparently recommended that the “DBT expedite the study so that the allegation made by the NGOs can be brought to a logical conclusion”. We object to the fact that this is being called an allegation when instances of a particular serious phenomenon are being reported to the GEAC. Further, we would like to know what your logical conclusion on this? Are you saying that it is pre-concluded about what such a study would have to show the world? What happened to the proposed DBT study and what are the findings?

6.       The Minutes of the 68^th GEAC meeting also record that “the Committee further decided to refer the matter to the State Department of Agriculture for a factual report on the allegation made by the NGOS and the findings of the post mortem report”. We hope that the GEAC has followed up on this systematically and demand to know what has been obtained in the form of a ‘factual report’.

7.       Later, there were media reports [in the Financial Express, on June 20^th 2006, under the banner of “GEAC dismisses Bt Cotton affecting sheep in India” etc.] based on the way the GEAC discussed the issue and the way the minutes were drafted. These reports concluded that the “GEAC has finally brushed aside the allegations made by NGOs”.

It is in this context that we would like to point out that the GEAC failed miserably in its mandate of protecting the health of animals and human beings and when there are manifestations of the problem at the ground level, is irresponsibly discounting them as “exaggerated”.

v      We demand that the GEAC improve its monitoring mechanisms in at least getting information from the ground on what is happening who from the RCGM and the GEAC have visited the affected villages and what do their visit reports say? Or is this not serious enough for them to investigate personally in the field?

v      The GEAC did not attempt to even do a secondary survey on what exists as reports on sheep mortality from other places in India since the advent of Bt Cotton. There is a report from WWF-India which also reports about sheep mortality from grazing on Bt Cotton fields from Khammam district. In Warangal, this is a second year that such reports have emerged. There are also media reports from Nalgonda district in Andhra Pradesh. Further, there are reports from the Nimad belt of Madhya Pradesh, shared informally by veterinary officials themselves, that such phenomenon has been observed there too. Is GEAC even aware about these various reports?

v      The GEAC could have commissioned at least a quick survey on the extent of mortality being reported by doing a ‘verbal-autopsy-equivalent’ survey in the population about the exposed and affected animal population. This is a case of deep-rooted suspicion of people and their observations, more than anything else. For the civil society groups reporting this matter, the issue begins with trust in the people and their knowledge rather than in industry-sponsored science.

v      Did the GEAC or RCGM check the postmortem findings registers in various districts for the period during which such mortality is likely to happen [January to April]? Did they compare the figures available for this year with figures as well as findings from earlier years when the pesticide use was ostensibly higher [than after the advent of Bt Cotton, as per the industry and the regulators]? How do these compare?

v      The GEAC could have tried to understand the complexity of the real life situation in which the shepherds find themselves in. Were there any tests done for Bt Cotton which included open grazing by sheep? Were there any tests done for the combined effect of Bt Cotton, with higher fertilizer use and continued pesticide use? Did the GEAC ever realize while approving Bt Cotton in the country that not having any regulatory limits on its spread could threaten the very livelihoods of shepherds and lives of important livestock [in countries like Australia, there was a cap of 30% fixed for Bt Cotton extent out of the total extent of cotton land, for instance, though as a resistance management strategy]?

v      CSA, since the time the fact finding report has been put out, has accessed the information available in the Post-Mortem Findings Register in the Warangal ADDL, for January to April 2006. This required a lot of persistence and struggle, it must be added.

It is important to note that while the GEAC and the industry are busy negating civil society reports, the postmortem findings register has been tampered with. WE are aware of at least three cases [documented as video testimonies with the shepherds going on record on video] where the shepherds had not said anything about pesticides being used on Bt Cotton, whereas the postmortem findings register has some new things added about this in a different ink. The tampering is to such an extent that where farmers had not reported about grazing their animals on chilli crop simply because there was no chilli crop being grown in a particular village, the postmortem register now has this mentioned in the case history, in a distinctly different writing! It is important for GEAC to understand what is the pressure on the local doctor and officials that they feel the need to add unreported details into the register so that they are not blamed for reporting things as they are? A popular doctor, who was advising the farmers not to graze their animals on Bt Cotton, given the trend that she noticed from the postmortem cases, is under pressure to tamper her records why? Who is behind this? Has the GEAC done anything to support her and investigate the whole issue?

v      It is also important to realize that the postmortem findings register, the most important evidence given the lack of other evidence in this case, clearly has some cases recorded under tentative diagnosis as “poisoning fed on Bt Cotton”. How can the GEAC and RCGM ignore this very important evidence and diagnosis, even as the sought-after-factual-report is supposed to be based on this register? Why then are civil society findings “exaggerated”?

v      The GEAC and all other biotech proponents were busy repeating that the Bt toxin works only against lepidopteran pests and no other organisms. However, they had not thought of any other possible mode of action and tested out for the same.

v      The other conjectures on the possible phenomenon here could not be ascertained by the VBRI investigations. Altered gossypol content on Bt Cotton, as compared to the non-bt counterparts of the same hybrid, could not be tested for, for instance. Similarly, the possibility of an alteration in the intestinal biota and their activity due to excessive ingestion of Bt Cotton foliage that could have altered the digestive processes fatally could not be ascertained. Could the intestinal medium have become alkaline due to ingestion of high cellulose-containing material? In such a case, does the Bt toxin bind to intestinal walls of sheep too?

v      Finally and most importantly, the VBRI investigations with Bt Cotton leaves, bolls and flowers yielded one important clue that of high nitrate and nitrite content in the Bt Cotton plant parts tested for. Interestingly enough, only traces of pesticides were found. Could the nitrate content in Bt Cotton have been fatally high due to excessive application of chemical fertilizers on Bt Cotton? Nitrate accumulation as a result of prevailing drought conditions can be ruled out in this case since most of the green fields where the animals were grazed were on irrigated plots. Further, if it is stress-induced nitrate accumulation it should have happened in the earlier years too with a similar phenomenon experienced by the shepherds and in non-bt cotton and other crops as well.

The other possible common reason for nitrate and nitrite accumulation is the excess fertilizer application on Bt Cotton crop. Even though Bt Cotton was released without any altered management recommendations, after 3-4 years of cultivation, it is now being said Bt Cotton needs more fertilizer application. As many studies have shown, Bt Cotton farmers indeed do end up applying more chemical fertilizers than non-Bt Cotton farmers. This is something that even companies and agriculture scientists are recommending now. While excess fertilizer application might save the Bt Cotton crop, it was never tested to see if this would also mean more nitrate accumulation, leading to nitrate poisoning of animals [several of the symptoms for nitrate poisoning match the symptoms witnessed by shepherds here]. This would then explain why animals grazed on non-Bt Cotton earlier were not affected and this is one plausible mode of action with Bt Cotton. However, no tests have ever been done along these lines in the country while testing for the safety of Bt Cotton. This is just to illustrate that several possible modes of action for the manifestation of the phenomenon were never visualized or tested for. The GEAC and the industry were only keen on completely rubbishing the experiences of the shepherds.

We would like to conclude that the regulators were too busy discounting our report rather than finding ways of getting down to the scientific investigation needed along different lines of hypothesis [whether related to gossypol or the accumulation of nitrates and nitrites on Bt Cotton, especially compared to non-Bt Cotton]. Why are the regulators not ready to even hypothesise about various possibilities while shepherds are so convinced that they have never witnessed this phenomenon earlier, though their animals routinely graze on [non bt-] cotton? Do you not believe in people? You did not begin with the premise that if it was pesticide poisoning that had led to sheep mortality, such reports should have appeared more frequently before the advent of Bt Cotton [if the Bt Cotton companies’ data is to be believed!]. Did it happen earlier, even as per official postmortem records and by unofficial media reports? Did GEAC do anything to check this systematically?

We demand that the GEAC:

v      Discuss the progress of investigations into the sheep mortality reports in the next GEAC meeting and put out the findings of these investigations into public domain as annexures to the meeting minutes and not allow the media and others to conclude that “GEAC has finally brushed aside the allegations”. If you have indeed brushed these off, we demand that you tell us how you have done so and on what basis.

v      Immediately commission studies on the following, by first picking up the material available in the field, especially in the northern cotton belt of the country:

*         check for gossypol content in Bt Cotton, compared to the non-bt counterparts, in real growing conditions, in a multi-centric, scientifically selected sample

*         check for nitrate & nitrite content in Bt Cotton, compared to non-Bt counterparts, in real growing conditions [by collecting information on fertilizer use in these different fields], in a multi-centric, season-long study with a scientifically selected sample

v      alert the whole animal husbandry system in the cotton-growing belts of the country to the possibility of such mortality being reported this year too, so that investigations are made in time on sick and dead animals

v      Consitute a National Research team consisting of researchers from National and State Research Institutes, such as IVRI and the State Veterinary Universites who can immediately respond with detailed investigations in the event of future mortality in the coming year, as also conduct their own in-situ research. 

v      Pro-actively set up systems to inform shepherds that they should not graze their animals on Bt Cotton fields

v      Investigate the reasons as to why the postmortem findings register in Warangal ADDL had to be tampered with, with data unreported by shepherds added in later on.

Sincerely

Sd/-

G V Ramanjaneyulu                                                              Sagari Ramdas                        

Centre for Sustainable Agriculture                                             ANTHRA                   

POSTMORTEM FINDINGS REGISTER

Excerpts of Information Copied Down Under Right To Information Act

from the Postmortem Findings Register, Animal Disease Diagnostic Laboratory, Warangal by Kavitha Kuruganti, CSA

[Information Obtained On June 24^th 2006, pertaining to Feb-April 2006]

Excerpts from the Register

Note:

1. The sentences in italics and underlined have been specially marked because it appears that these lines have been added later in the register, with a markedly different pen/writing.

2. Pachha Purugu bollworm; Mirchi - chilli

3. The above table contains only extracts from the register of those cases that contained references to grazing on cotton fields or specifically Bt Cotton fields in the history and/or in tentative diagnosis.

4. Neither the above table nor the Abstract table before that are an indication of the actual morbidity or mortality on the ground since this is data from only such animals that are painstakingly brought for postmortem investigations from all over the district.