Illegal and Unscientific: Field Trials of GM Crops in India

Thanks to Kavitha Kuruganti of the Centre for Sustainable Agriculture for forwarding the report below on Field Trials of GM Crops in India, which focuses on Monsanto's Bollgard II and highglights many disturbing irregularities, including major biosafety violations.

See also the press release on this: http://www.lobbywatch.org/archive2.asp?arcid=6114

The report has particular relevance to the meeting of India's Genetic Engineering Approval Committee, which is taking place tomorrow (13th January) and which will apparently include a review of the field trials. See the article: http://www.financialexpress.com/fe_full_story.php?content_id=114211

For how to express your concern to the Indian authorities, see our previous bulletin of today: GMW: URGENT - TAKE ACTION - BAN FIELD TRIALS IN INDIA.
---

Field Trials of GM Crops in India: Illegal and Unscientific

India is a signatory to the Cartagena Protocol - this international Convention, though primarily focusing on transboundary movement of living modified organisms [LMOs, also popularly referred to as GMOs - Genetically Modified Organisms including GM crops], emphasizes a precautionary approach towards LMOs. The Convention is about 'ensuring adequate levels of protection in the field, of the safe transfer, handling and use of living modified organisms resulting from modern biotechnology that may have adverse effects on the conservation and sustainable use of biological diversity, taking also into account risks to human health'.

The Convention, in its general provisions, says that 'Parties shall ensure that the development, handling, transport, use, transfer and release of any living modified organisms are undertaken in a manner that prevents or reduces the risks to biological diversity, taking also into account risks to human health'. Article 23 of the Protocol expressly provides for facilitating and promoting public awareness and participation concerning safe transfer and use of LMOs. Parties to the Protocol are expected to pro-actively inform their public and to consult their public in decision-making processes related to LMOs.

Even if the Protocol is meant to apply to transboundary movement, handling and use of all LMOs (through the mechanism of Prior Informed Consent), it is only to be expected that such principles as enshrined in the Cartagena Protocol, would also be applied domestically by India, given that India ratified the protocol.

Cartagena Protocol, would also be applied domestically by India, given that India ratified the protocol.

India also uses the Environment Protection Act, 1986, for regulating GMOs and hazardous micro-organisms. The 1989 Rules for the Manufacture, Use, Import, Export and Storage of Hazardous Micro-Organisms, Genetically Modified Organisms or cells were created with a view to protect the environment, nature and health in connection with the application of gene technology and micro-organisms.

These Rules lay down the competent authorities for regulating research and large scale use of GMOs, including experimental field trials. The Genetic Engineering Approval Committee, constituted under these Rules, is expected to supervise the implementation of terms and conditions laid down by it and has the powers to revoke approvals for non-compliance of stipulations including ones related to biosafety. The RCGM (Review Committee on Genetic Manipulation) established under the Department of Biotechnology (DBT) supervises and accords approval for research activities including small-scale field trials/pre-clinical trials, whereas approvals for large-scale releases and commercialization of GMOs are given by the GEAC, established under the Ministry of Environment and Forests.

The 1989 Rules of EPA have been supplemented by technical guidelines evolved from time to time to address issues/concerns of biosafety. These technical guidelines include "Recombinant DNA guidelines, 1990" and "Revised guidelines for research in transgenic plants & guidelines for toxicity and allergenicity evaluation of transgenic seeds, plants and plant parts, 1998".

The Environment Protection Act also has a Penalties clause (15) which says that "whoever fails to comply with or contravenes any of the provisions of this Act, or the rules made or orders or directions issued thereunder, shall, in respect of each such failure or contravention, be punishable with imprisonment for a term which may extend to five years with fine which may extend to one lakh rupees, or with both, and in case the failure or contravention continues, with additional fine which may extend to five thousand rupees for every day during which such failure or contravention continues after the conviction for the first such failure or contravention".

1. HISTORY OF BIOSAFETY VIOLATIONS AND UNSCIENTIFIC FIELD TRIALS IN THE COUNTRY

1.1. 1998 "Bollgard I" trials

Research Foundation for Science, Technology and Ecology [RFSTE], New Delhi brought out a report entitled "Globalisation and the Threat to Seed Security: the case of transgenic cotton trials in India" in which the organization goes into the details of Bt Cotton field trials in various locations in the country conducted in 1998. Field trial farmers from the states of Haryana, Punjab, Karnataka, Andhra Pradesh and Madhya Pradesh were met by the researchers of the study to look at the scientificity and legality of the trials. One of the main findings of the study of the 1998 trials is that the produce from the trial plots has been allowed to be directly sold in the open market mixed with normal cotton.

The report shows that not only were the wrong regulatory authorities involved in granting permission for large scale trials, the date of sowing (as obtained from farmers of the trial plots) pre-dated the provision of permission. The report points out that SBCC (State Biotechnology Coordination Committee) and DLC (District Level Committee), bodies which are entrusted with ensuring biosafety, were not informed about the trials happening in their jurisdiction.

The study points out that other than seeking information on pest load, agronomic performance etc., from the company, there was no environmental assessment carried out for the trial sites to monitor other possible impacts from the trial.

In terms of violations of guidelines, the study shows that experimental plot size norms, isolation distances to be maintained, norms related to maintenance of full account of all transgenic material produced including destruction of all material etc., were all violated by the company involved [Mahyco].

The study also points out that selection of farmers for trials is also based on unscientific sampling techniques, based on prior acquaintances rather than other scientific considerations. There was no independent scrutiny of the trials, the study report points out.

1.2. 2001 "Bollgard I" field trials

Another report entitled "Agricultural Biotechnology & Biosafety in India: Expectations, Outcomes and Lessons" from the Centre for Budget & Policy Studies and Stockholm Environment Institute, brought out in April 2005, also looked at Mahyco field trials in the state of Karnataka. The field study for this report was conducted in 2002 where Bt Cotton farmers who participated in the Mahyco trials of 2001 were interviewed, in addition to scientists from the local regional agricultural university to understand the monitoring mechanisms of field trials. The following passages are extracts from this report.

Mahyco was late in supplying the seeds, considerably delaying the sowing. "It is curious that the delay should recur, since the 2001 trials were ordered by GEAC precisely to meet the objections of the CSOs that the pre-2001 trials, being delayed, were invalid, because the bollworm attack would have peaked by the time the Bt-cotton bolls appeared".

One of the farmers had re-sown the crop seeds from the trial plot”¦.

It was most revealing to find out that the farmers had not been obliged either by Mahyco or by the monitoring committee to destroy the Bt-crop and the post-harvest residues on site after the trials were over. Instead, they were permitted to harvest the Bt-crop and sell it on the market, feed the post-ginning BT-cotton seeds to their livestock and use the Bt-cotton stalks as household fuel. The farmers were clearly pleased with this arrangement, especially as they had not incurred the expense of paying for the Bt-seeds. "This of course was a clear violation of not only the prevailing biosafety regulations but also the conditions that RCGM/DBT and GEAC/MoEF had attached to the Mahyco trials. It was extraordinary to discover that Mahyco’s trial Bt-cotton had reached the market (albeit in very small quantities), either by default or by negligence on the part of Mahyco and the monitoring committee, in clear breach of the regulations. This raises the valid and disturbing questions of whether (i) RCGM/DBT and GEAC/MoEF were aware of how the trials were actually being conducted not only in Karnataka but also in Andhra Pradesh, Haryana, Maharashtra and Tamil Nadu, and (ii) took steps to cross-check the veracity of the field trial reports submitted by Mahyco".

The biosafety regulatory regime stipulates that field trials be monitored by experts who are independent of the company conducting the trials. However, DBT apparently allowed Mahyco to take the initiative in setting up the monitoring committees, permitting the company to identify and draft members into the committees. The monitoring committees comprised only natural science (biotechnology-related) and agricultural science (including agronomy, i.e. farm-level economy) specialists, with social science disciplines, and Civil Society Organisations’ representatives excluded.

Out of the 37 farms in Karnataka where the trials were conducted, Mahyco picked only five for monitoring by the committee, which concentrated on four tasks: Measurement of (i) reduction in pesticide use, as determined by the number of sprayings (ii) pest-load (i.e. number of pests per boll) (iii) the tolerance capacity of the plants to pest-incidence and (iv) the yield potential of the three types of plots (Bt, non-Bt and check). The committee also checked whether the layout of the trial plots conformed to the pattern prescribed by DBT. The team concentrated on agronomic aspects that had a direct bearing on the yield, i.e. frequency and intensity of pesticide spraying, pest-load and pest-migration. No attention seems to have been paid to other crucial biosafety aspects contained in the biosafety regulations, e.g. ecology (e.g.GM-pollen-drift, GM-pollen-contamination and gene-flow), agricultural biodiversity, animal health safety (use Bt-cotton seeds as animal feed) and socio-economy.

The team’s visits to the trial plots were limited to about one a month. It is alleged that its work was desultory and its checking of the technical details (see the four tasks mentioned above) was not rigorous.

What these many reports point out to is not just that there are blatant violations of biosafety in the GE field trials, but these are done unscientifically and without adequate monitoring. This background clearly explains the actual performance of Bt Cotton on the ground, after many Bt Cotton hybrids were permitted for commercial cultivation. If the tests were comprehensive and done scientifically with adequate monitoring, many of the disastrous results experienced by farmers in the country would have been discovered right at the trials stage. The fact that they have not been shown at that stage is a reflection of the manner in which trials are conducted in this country.

2. 2005 "BOLLGARD II" FIELD TRIALS:

2.1. About Bollgard II:

Monsanto, the world’s leading seed company, which holds a whopping 14% share of the US$ 21000 mn global seed trade, brought in Bollgard® Bt Cotton into India and sub-licensed it out to Mahyco, Rasi Seeds, Ankur and Nuziveedu Seeds at an expensive rate, and these companies together have around twenty Bollgard Bt Cotton hybrids approved for commercial cultivation as of today. Numerous other companies like Tulasi Seeds, Ajeet, Emergent Genetics, Ganga Kaveri, Krishidhan, Pravardhan, Vikki AgroTech etc., have also lined up with their own Bt Cotton hybrids with the Bollgard gene and are soon going to walk up to the GEAC for approval, thanks to the unscientific policy that India adopts of approving one "event" [MON 531, with Cry1Ac gene in this case] once and all other hybrids only being evaluated for agronomic performance.

What is interesting to note is that both the companies promoting and profiting out of Bt Cotton and the regulatory authorities approving it for commercial cultivation know that the bollworm against which the Bt Cotton hybrids are supposed to be ‘tolerant’, would soon develop resistance adding to and rendering the technology ineffective. The product [Bt Cotton] was introduced knowing fully well that its life is short and other solutions have to be provided to increased problems of poor farmers in just a short while. As other parts of this report show, Bollgard I itself has been approved for commercial cultivation based on unscientific trials, undertaken in conditions that violate biosafety guidelines in every manner possible.

As a solution to the ineffective technology that was introduced, a new product called Bollgard II (BGII) is being sought to be introduced by the same companies (and would surely be at more expensive rates, in this game of fleecing hapless farmers for more profits). Monsanto’s Bollgard II has Cry 2Ab and Cry 1Ac genes a technology of stacked genes, which is supposed to render the BGII cotton plant tolerant against the bollworm complex (American bollworm, Pink bollworm and Spotted bollworm) as well as against the tobacco caterpillar (lepidopteran pest).

2.2. What is wrong with BGII?:

BGII, like BGI, does not result in sustainable pest management. Any technology that puts tremendous selection pressure on the pest population is bound to fail and is not useful for farmers in India. The story of pesticides and the story of BGI has already told us this.

As the experience of Bt Cotton from across the country this year shows, the Bt Cotton hybrids have witnessed a massive attack of sucking pests and are therefore also greatly vulnerable to disease attacks, spread by sucking pests. The stress intolerance of BGI has also been clear and BGII is not going to be any different if at all, it can only be worse in its vulnerability to sucking pests, diseases and stress. The economics are going to be more adverse to Bt Cotton farmers if BG II is allowed in BGI farmers are already committing suicides in various states.

Another important aspect to be regulated with the advent of BGII is that for it to be effective, BGI has to be phased out. There are studies that show that concurrent use of transgenic plants expressing a single and two Bacillus thuringiensis genes speeds up insect adaptation to pyramided plants .

In Australia, which out of scientific resistance management plans began its Bt Cotton use by imposing a 30% ceiling on Bt Cotton extent out of the total cotton area in the initial years, introduced BGII last year but with an enforced condition: that BGI would be completely phased out when BGII is used, knowing fully well that the purpose would be served if at all only if concurrent use is not made.

In India, the government has been unable to regulate Bt Cotton in its single-gene version. Illegal Bt Cotton is proliferating everywhere and even in the case of approved Bollgard varieties, refuge planting is nearly completely absent indicating a complete failure of the resistance management plans laid down by the government. How is India going to ensure that BGI [Bt Cotton with single gene] and BGII do not co-exist? Did the DBT/GEAC think about these things before permitting trials? Or is it too much for these bodies to think coherently in the interests of farmers?

2.3. About Field Trial permissions given to BGII so far:

On 14th July 2004, in its 44th meeting, the GEAC permitted Large Scale Trials of Mahyco’s MRC 7201 BGII, MRC 7160 BGII, MRC 7301 BGII, MRC 7326 BGII, for South and Central Zones, at 80 representative locations per genotype per zone and seed production in an area of 40 ha for MRC 7201 BG II and for the remaining hybrids in an area of 5 ha.

On 8th September 2004, in its 46th meeting, GEAC considered additional seed production request by Mahyco. The company wanted permission for an additional area of 20 ha for the last three hybrids too. On the grounds that there is a need to demonstrate the BGII technology at varied micro agro-climatic locations, the GEAC approved the request of the company.

On 4th March 2005, GEAC held its 52nd meeting. Here, Mahyco’s application for large scale trials of certain BGII hybrids in the North Zone and permission for seed production was discussed. The GEAC approved large scale trials of MRC 7017 BGII and MRC 7031 BGII at 80 representative locations per genotype, ICAR trials and seed production in an area of 50 ha for each variety, subject to the following conditions:

The applicant should look for the incidence of sucking pests on these hybrids during large-scale trials and also artificial screening for CLCV (Cotton Leaf Curl Virus) resistance

The Agricultural Universities would be involved in the monitoring of large scale trials with specific reference to incidence of CLCuV

Until an alternate mechanism for monitoring of large scale trials is established, these trials may be monitored by the MEC

More BGII cotton hybrids were approved for Large Scale Trials in the 54th Meeting of the GEAC on 3rd May 2005. Krishidhan’s KDCHH 621 BGII and KDCHH 441 BGII [Central Zone], Rasi’s RCH 515 BGII [Central Zone], Mahyco’s MRC 7301 BGII, MRC 7326 BGII, MRC 7351 BGII, MRC 7341 BGII and MRC 7347 BG II [Central Zone] were approved for large scale trials in this meeting. Similarly, Ajeet Seeds' ACH 11-2 BGII and ACH 155-2 BGII were also approved for large scale trials for Central Zone.

For South Zone, Mahyco's MRC 7160 BGII, MRC 7201 BGII, MRC 7351 BGII and MRC 7347 BGII, Rasi's RCH 530 BGII and RCH 533 BGII and Krishidhan’s KDCHH 621 BGII were allowed for large scale trials in the same meeting.

2.4. But what about Monitoring Mechanisms?

It is interesting to note that the GEAC went ahead with all these field trial permissions of "unapproved events", knowing fully well that there are no proper monitoring mechanisms in place. For instance, it knew that the MEC's term expires on 4/9/05. This issue got discussed in the GEAC meeting of 14/9/05 (and not before that)! The GEAC awaits to this day responses from state governments for alternate monitoring mechanisms for large scale trials and post-release monitoring. As a temporary measure, the RCGM has been asked to extend the tenure of the MEC it is not clear if this has been done and who is currently monitoring these trials!

2.5. Biosafety Guidelines to be followed:

The applicants conducting limited scale field trials or large scale field trials in the farmers’ field are to follow the prescribed protocols. These protocols consists of information on the number of checks, plot size, controls etc. The protocols are slightly different for limited scale field trials (RCGM/MEC) and large scale field trials (GEAC approved).

The isolation distances to be observed while conducting field trials is based on the prescribed distance in the Indian Minimum Seed Certification Standards, 1988 for cotton, it is 50 meters.

The parameters that would be observed and noted in data books while conducting the field trials are:

larval counts of bollworms including spodoptera (spotted, American and pink bollworm and spodoptera)

sucking pest population of aphids, jassids, white flies and thrips

viral, bacterial and fungal diseases incidence (CLCV, bacterial blight, wilt and other)

beneficial insect population of coccinellids, chrysopa, syrphids and spiders

agronomic traits (like seed cotton yield, lint yield, bolls per plant, plant height, germination etc.)

summary of fibre properties etc.

The following are the conditions laid down, including the biosafety guidelines, for conducting the trials:

a) Applicant would provide with three photographs of experimental site, taken from a distance sufficient to indicate the transgenic plots in a single photograph; such photographs would be taken at three intervals during the season to document the start of the experiments, the mid way of the experiments and the end of the experiments. These photographs would be submitted to the Government at the conclusion of the experiments.

b) Applicant would keep full account of the transgenic materials and seeds, if any, set in the transgenic plants. All materials after experimentation including the seeds of cotton for the trapper rows would be fully accounted for and the information would be documented and preserved in a bound book that would be available to the Government as and when requested for. The harvested crop from the experimental plants, border row plants, leftover plant and plant parts from entire experimental plot shall be destroyed by burning after completion of the experiment.

c) Applicant would collect and provide all the experimental data to the Government for inspection whenever required.

d) Applicant would ensure that while performing the experiments, the "Recombinant DNA Safety Guidelines-1990" and "Revised Guidelines for Research in transgenic plants & Toxicity and Allergenicity evaluation of transgenic seeds, plants and plant parts" of the Government of India would be strictly adhered to. Accidents, if any, arising out of the experiments may be brought to the notice of the Government immediately.

e) Applicant would further ensure that only company authorized personnel would be permitted to visit the experimental plot and persons visiting the experimental plot shall enter the name, designation and purpose of visiting the experimental plot in a bound book which should be made available to the Government when requested for.

f) Applicant would extend full cooperation to the authorized personnel of the RCGM/MEC as well as the State Government Officials or their nominee to inspect the experimental sites and to have access, for official use only, the experimental results of the above.

For RCGM trials (multi-locational limited trials), an RBD design is adopted, with 3-4 replications required per entry. A 2 meter distance is to be maintained between replications. Similarly, space between experimental area and 5 trapper rows is to be 2 meters. The test entries should be Bt Cotton test hybrids with analogous non-Bt cotton hybrids wherever available. The checks should have a recently released Bt Cotton, a national non-Bt check and a popular non-Bt Cotton hybrid of the zone as another check.

For large scale field trials [LSTs], 80 trials are permitted per zone usually. The entries in this case would be BGII with the checks being a latest transgenic Bt Cotton hybrid, one non-GM cotton hybrid which could be a popular national or zonal check and a non-GM counterpart of the test hybrid [in case of direct GEAC trials].

The design adopted for large scale trials is a non-replicated one. All entries including the test GM hybrid and checks are to be sown in the same field. The plot size, per entry is supposed to be 40 m X 25 m or 40 m X 32 m in case of applicants cleared by MEC/RCGM. The spacing between plots is expected to be 2 meters. The trial is to be conducted in an area of one acre divided equally per entry, with the field conforming to the following layout (not to scale).

BOLLGARD II FIELD TRIALS: UNSCIENTIFIC AND ILLEGAL

The following pages, based on information and evidence that emerged during the cotton growing season of 2005 from the states of Andhra Pradesh, Madhya Pradesh, Maharashtra, Punjab and Tamil Nadu have illustrative cases to demonstrate the numerous violations that are happening with Bollgard II trials in the country. These cases were identified through investigative approaches, with no readily-available information from the government or the companies in most cases.

The story is almost a repetition of the field trials that had happened when Bollgard I was sought to be introduced. The same kind of secrecy, the same kind of lax monitoring, the same kind of unscientificity to the trials and the same kind of violations with a total disregard to biosafety. Despite several earlier reports pointing out to the lack of proper monitoring and liability with regard to violations, it is obvious that nothing has been improved on the ground. A whole set of players the GEAC, the DBT’s various committees, the corporations involved, the state governments and their agriculture scientists, the DLC members are responsible for this sorry state of affairs. If this is the state with cotton a non-food crop, it is frightening to think about the scores of experiments and trials happening with numerous food crops across the country.

Members of the Monitoring and Evaluation Committee [MEC] started looking for BGII field trials from the month of August. Department officials in various districts refused to give us information on where these trials were happening. In Punjab, some senior government officials responded to our request for information by saying that "this is top secret". In the ADA’s office in Attur division in Salem district of Tamil Nadu, the officials lied to us saying that there were no BGII trials happening in their Division when we had already come across one!

In the JDA’s office in Warangal, as late as in November, we were told that the government is trying to get a list of field trial farmers from the companies and have not been successful in getting this list! If it is true that the local officials are not being provided with these lists, then it is a violation of the EPA rules which have a specific role envisaged for the District Level Committee [DLC].

Many of the cases being presented here have been chanced upon by us during our regular monitoring. In the case of Madhya Pradesh, lists have been provided by some district level officials upon our request.

We have been following these field trial farmers and made at least a couple of visits to each farmer/plot. In many cases, the farmers have not been told what varieties were being tested. The selection of farmers for the field trials in itself is questionable are results from these plots really applicable to the general growing conditions of many cotton farmers? It was also very revealing to find that many of the company personnel supervising the trials did not have enough knowledge about biosafety guidelines.

In each of the illustrative cases, we have video footage of the plot and an interview with the farmer. A checklist of questions was prepared beforehand and questions posed as per this. The compilation of evidence of violations includes some RCGM trials also.

Even as our documentation was happening, the MEC came across some farmers/dealers from Nanded in Maharashtra who were taken to Jalna, to Mahyco’s headquarters, where they were clearly told that BGII will be effective against sucking pests also! The saga of lies and lures continues”¦.

Each illustrative case that we had come across is being presented in the following pages. The presentation attempts to show the situation as against the biosafety guidelines laid down. We have come across cases which are not being monitored not even by the company! We wonder what numbers will be cooked up by the companies concerned or whether the game of averages can be pulled off by them!

In addition to many violations on the biosafety front, the cases that we came across also revealed many important issues with regard to field trials and the way they are conducted in the country. These include questions on scientificity, ethics, accountability, regulation and so on.

Farmer: Mr Rajendra [Rajesh] Badrilal Jamadan
Village: Anjad, Badwani block, Badwani district, Madhya Pradesh
Test hybrid: MRC 7341 BGII
Controls: MRC 6301 BGI Bt and Ankur 651
Our visit date: October 25, 2005 (in the forenoon)
Visit by: Kavitha Kuruganti, Nilesh Yadav, Avdhesh Sharma, Radhesyam Parmar

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with 3 trial plots inside it Field trial happening in 1.5 acres of land Isolation distance from the trial plot, for cotton to be 50 mts On one side of the plot is the Anjad-Rajpur road, on another side is a plot of soybean that has been harvested, on a third side is an empty plot and on the fourth side is a plot of Shakti 9 Bt Cotton Refuge of 5 rows all around the squarish plot [trapper rows] Refuge of 5 rows of cotton only on three sides Distance of 2 mts to be maintained between different test and check plots No distance maintained; the farmer took up "gap-filling" of Shakti 9 cotton between the plots Regular monitoring to be done by company personnel and MEC/RCGM appointed teams [from Khargone in this case] Only one visit by the company so far Sowing to take place during the normal sowing period of the region Sowing took place very late, in the first week of July; for sowing the trial and check seeds in his land, Rajendra first uprooted a badly-germinated plot of Shakti 9 Bt Cotton and replanted the land with the free seeds given by the company Register of all visitors to the plot to be maintained No such record is being maintained, as our own visit shows All field trial produce to be destroyed to ensure biosafety Rajendra mixed up the cotton from his different plots and has already transported the harvest to his house, which the team inspected. He is about to sell it to the local mandi and expects a price of more than 2000 rupees per quintal

The farmer was only informed by word of mouth about the seed that was being tested on his plot. It is obvious that there is NO PRIOR INFORMED CONSENT for field trials especially for those crops whose biosafety is yet to be established

He was shown by the Mahyco company personnel brought to him by a dealer known to him about how the sowing was to be done. However, the company personnel did not ensure compliance.

It was apparent that there was no proper planning on the part of the company in the selection of its field trial farmers. Rajendra Jamadan happened to have approached his dealer with a complaint that his Shakti 9 Bt Cotton had failed to germinate in a few days’ time, instead of paying him compensation, the dealer brought Mahyco company officials to Rajendra Jamadan with a promise that they would give him free seeds for his land. Rajendra Jamadan did not want to spend any more money buying seeds and therefore, agreed. There is of course no accountability mechanism in place in case there is a problem with the seeds of either crop performance or unexpected results!

It was very obvious from visiting Rajendra Jamadan that the company, Mahyco in this case, gave up on this plot soon after the season began as there was a problem with water availability in this field (though the farmer went to the trouble of deepening the depth of his tubewell so that he could irrigate this plot of land) in this game of averages. What would be interesting to note would be the numbers that the company would present as its results from this plot. Are Rajendra Jamadan’s field trial plot and its results still being counted by the company? What numbers and from where would data be presented? What about the fact that the company has not come back to collect the seeds from the trial plot? And that there were no scientists from Khargone who had visited the trial either?

All material from this field trial, including seeds, cotton, crop residue etc., has entered the regular supply chain and other ways of utilizing crop produce. This is a clear violation of biosafety rules for Bollgard II. Who is to be made accountable for this?

Farmer: Mr Ranchodlal Gonaji
Village: Temariyan, Petlawad block, Jhabua district, Madhya Pradesh
Test hybrid: Mahyco’s BGII, exact hybrid not known (name obtained from a list of field trial farmers in the ADA’s office, Jhabua)
Controls: Not known

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with 3 trial plots inside it Field trial happening in more than one acre of land. Isolation distance to be maintained with neighboring plots for cotton to be 50 mts Not maintained on two sides the adjacent plots are also Bt Cotton, one of which is also a Nuziveedu Seeds’ trial Refuge of 5 rows all around the squarish plot [trapper rows] Only 3 rows, on 3 sides Distance of 2 mts to be maintained between different test and check plots No distance maintained between plots Regular monitoring to be done by company personnel and MEC/RCGM appointed teams No visits by the company; in fact, the plot had begun wilting and the farmer approached the company quite a few times but in vain Sowing to take place during the normal sowing period of the region Sowing took place late. The farmer was asked to remove the soybean existing on his plot and then sow the BGII seed supplied to him. Register of all visitors to the plot to be maintained No such record is being maintained, as our own visit shows All field trial produce to be destroyed to ensure biosafety The farmer has already sold two lots of produce (small quantities) to a local trader in Petlawad.

It is clear from this case where the farmer has incurred heavy losses and where the company refused to come and monitor the plot, that there are no accountability mechanisms put in place that protect the farmers’ interests given that this is a trial plot and results can be unexpected.

It was very obvious from visiting Ranchodlal Gonaji that the company, Mahyco in this case, gave up on this plot when the crop started to perform poorly. They stopped visiting and recording data from the farm. Would this mean that they cook up numbers for this plot, or that they calculate averages for approval only from those plots that the company finds promising, is a question to be explored. There were of course no independent teams which monitored which could have acted as a check for both possibilities mentioned earlier.

Farmers: Mr Mahesh Kanshiram Mukati, Mr Rajan Kanshiram Mukati
Village: Kalibedi, Badwani block, Badwani district, Madhya Pradesh
Test hybrid: Mahyco’s MRC 7347 BGII
Checks: MRC 6301 Bt and Ankur 651

Mr Gulabchand Kanshiram Mukati, Mr Suresh Kanshiram Mukati and Mr Hukumchand Kanshiram Mukati
Village: Kalibedi, Badwani, Madhya Pradesh
Test Hybrid: MRC 7351 BGII
Checks: MRC 6301 Bt and Ankur 651

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with 3 trial plots inside it There are at least five trials right next to each other, in one location only, belonging to one family. While two farmers’ names are recorded under village Kalibedi, the others have been recorded as lands belonging to Badwani Isolation distance to be maintained with neighboring plots for cotton to be 50 mts There is no isolation distance being maintained; not only are the neighboring plots growing cotton, they are also BGII trial plots Refuge of 5 rows all around the squarish plot [trapper rows] It was not clear whether such refuge was being maintained, because plots were separated with these 5 rows without any clear bunds differentiating the plots. Therefore, one common refuge for two plots was found. Distance of 2 mts to be maintained between different test and check plots Distance being maintained. Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Not clear whether such monitoring took place Sowing to take place during the normal sowing period of the region Sowing took place on 5th July 2005. The farmers feel that the particular hybrids that were sown on their plots are summer varieties and should have been sown in May itself; they are very unhappy with results of the plot now, where the farmers have incurred more expenses than their returns. There is of course no accountability on the company to pay compensation for the losses incurred. Register of all visitors to the plot to be maintained No such record is being maintained, as our own visit shows All field trial produce to be destroyed to ensure biosafety The farmers intend to sell the produce in the local market and have no instructions from the company on what they should do with the crop, its produce and its residues.

RCGM LIMITED FIELD TRIALS

Farmer: Mr Komirisetty Nageswara Rao
Village: Pedapalakalur village, Medikonduru block, Guntur district, Andhra Pradesh
Test hybrids: ACH 11-2 BGII, ACH 155-2 BGII, ACH 33-2 BGII, ACH 21-2 BGII
Check: ACH 155, ACH 33, ACH 21, ACH 11, RCH 368 Bt, RCH 2 non-Bt, Bunny non-Bt, Bunny Bt
Our visit date: November 22, 2005 (in the late afternoon)
Visit by: Kavitha Kuruganti and Ramprasad

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with RBD design Field trial happening in 1.5 acres of land Isolation distance of 50 mts all around the plot to be maintained Being maintained one side is a railway track, another is a road, a third side are hutments and a fourth side is a small track Refuge of 5 rows all around the squarish plot [trapper rows] Being maintained Distance of 2 mts to be maintained between different test and check plots Distance maintained Regular monitoring to be done by company personnel and MEC/RCGM Regular visits by the company happening Sowing to take place during the normal sowing period of the region Sowing on time Register of all visitors to the plot to be maintained No such record is being maintained, as our own visit shows All field trial produce to be destroyed to ensure biosafety Based on what happened in the previous year with the same company, farmer says that other than the samples that the company takes, the cotton will be sold in the local market

RCGM LIMITED FIELD TRIALS

Farmer: Mr Ravinder Reddy s/o Narayan Reddy
Village: Damera, Atmakur mandal, Warangal district, Andhra Pradesh
Test hybrids: Tulasi Seeds’ Bollgard II hybrids (Tulasi 1 BGII, Tulasi 3 BGII and Tulasi 5 BGII, as per the farmer)
Check: Not known
Our visit date: November 7, 2005 (in the late afternoon)
Visit by: Kavitha Kuruganti, Rajasekhar and Amjad

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with RBD design Field trial happening in 1 acre of land Isolation distance of 50 mts to be maintained Being maintained all around Refuge of 5 rows all around the squarish plot [trapper rows] Being maintained Distance of 2 mts to be maintained between different test and check plots Distance maintained Regular monitoring to be done by company personnel and MEC/RCGM Regular visits by the company happening; no visits by others so far Sowing to take place during the normal sowing period of the region and after permission is granted by MEC/GEAC Sowing took place 15 days later than all other plots ("the company would like to show a good field to the visiting Delhi team and therefore, they wanted to sow late", explained the farmer) Register of all visitors to the plot to be maintained No such record is being maintained, as our own visit shows All field trial produce to be destroyed to ensure biosafety The farmer’s arrangement with the company is such that they provide seed free, do regular monitoring and spend on pesticides and fertilizers, while the farmer is supposed to take care of intercultivation practices, provide the workers etc., and finally take the produce for himself. Ravinder Reddy is planning to sell the produce in the local market, after mixing all the yield from all the plots. He also said that only in the case of Syngenta, with their vip Bt Cotton has he seen destruction of crop material in an incinerator, whereas all other companies allow the farmers to keep the produce and farmers then sell it by themselves in the local markets, thus contaminating the supply chain.

RCGM LIMITED FIELD TRIALS

Farmer: Mr Bommineni Raji Reddy
Village: Gudeppad, Atmakur block, Warangal district, Andhra Pradesh
Test hybrids: Rasi Seeds’ BG II hybrids [names not known]
Check: Not known
Our visit date: November 25, 2005 (in the late afternoon)
Visit by: Rajashekar and Amjad

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with RBD design Field trial happening in one acre of land Isolation distance of 50 mts to be maintained Being maintained by growing crops like vegetables and maize on the neighboring plots Refuge of 5 rows all around the squarish plot [trapper rows] Being maintained Distance of 2 mts to be maintained between different test and check plots Distance maintained Regular monitoring to be done by company personnel and MEC/RCGM Regular visits by the company happening Sowing to take place during the normal sowing period of the region Sowing on time Register of all visitors to the plot to be maintained No such record is being maintained, as our own visit shows All field trial produce to be destroyed to ensure biosafety Farmer says that he had already sold about one quintal from the plots in the open market. He also says that the company will take only 10 kilos per quintal as their sample and as for the rest, the farmer is free to sell it in the market.

Farmer: Devi Lal s/o Shiv Lal & Indraj Singh s/o Brij Lal
Village: Killianwali, Khuian Sarwar Block, near Abohar, District-Ferozepur
Test hybrid: 1) KDCHH 441 BGII 2) KDCHH 621 BGII 3) KDCHH 531 BGII
Checks: MRC 6301 and others

RCGM Trial

Field Trial & Bio Safety Rules Actual Situation

Field trial permission given only for one acre of land, with three equal trial plot inside it The trial was conducted in one acre Isolation distance to be maintained with neighboring plots for cotton to be 50 mts All around there was hybrid with a width of 12 feet. There was no gap except this, between the trial and the other crops. On one side there is Road & the other side is a canal at a distance of less than 25 meters Refuge of 5 rows all around the squarish plot [trapper rows] Refuge of 5 rows all around Distance of 2 mts to be maintained between different test and check plots As per the farmer, there was a distance of 3.5' plus 3.5' maintained between trial varieties; it was not clear whether the distance was just 3.5 feet or 7 feet Regular monitoring to be done by company personnel and MEC/RCGM appointed teams The persons from the company visited regularly, every fifteen days, beginning one month after sowing

Sowing to take place during the normal sowing period of the region Sowing done in May’ 05 Register of all visitors to the plot to be maintained No such register has been maintained All field trial produce to be destroyed to ensure bio-safety The farmer has collected and mixed this cotton from this BG-II trial in to the normal crop. Some of this produce has been sold and now he is waiting for a hike in the price of cotton, to sell his other produce. When asked specifically whether the company gave him instructions on whether he could sell his produce, the farmer reported that nothing has been told in this regard.

Farmer: Mukhtiar Singh s/o Dayal Singh & Amrik Singh S/o Mukhtiar Singh
Village: Gobindgarh, near Abohar, Abohar to Muktsar Road, Abohar, District-Ferozpur
Test hybrid: Trial of Krishidhan BGII hybrids
Checks: Farmer says that it was Surya 144 and others

RCGM Trial

Field Trial & Bio Safety Rules Actual Situation Field trial permission given only for one acre of land, with three equal trial plot inside it The trial was on one acre Isolation distance to be maintained with neighboring plots for cotton to be 50 mts No such distance was maintained. Cotton all around Refuge of 5 rows all around the squarish plot [trapper rows] 4 rows maintained Distance of 2 mts to be maintained between different test and check plots Not maintained Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Regular monitoring by the company people Sowing to take place during the normal sowing period of the region Sowing done in the last week of the April 05 Register of all visitors to the plot to be maintained No such register was maintained All field trial produce to be destroyed to ensure bio-safety The crop is partially sold and the rest of the crop shall be sold in due course, as informed by the farmer

Farmer: Jagshir Singh s/o Wazir Singh
Village: Vehmi Choohar near MUAR Mandi, Block- Rampura Phool, District Bhatinda
Test hybrid: 1) KDCHH- 441 BG II 2) KDCHH- 621 BG II 3) KDCHH- 531 BG II

Checks: Surya-144 of the Krishidhan Company and others

RCGM Trial

Field Trial & Bio Safety Rules Actual Situation Field trial permission given only for one acre of land, with three equal trial plots inside it The trial is happening in more than one acre Isolation distance to be maintained with neighboring plots for cotton to be 50 mts On one side there is about 11' wide passage and on the other side, there is a road. On a third side is a paddy field. This isolation distance of 50 mts has not been maintained Refuge of 5 rows all around the squarish plot [trapper rows] Five rows of refuge were maintained Distance of 2 mts to be maintained between different test and check plots Estimated distance between plots is about three feet, as per information given by farmer Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Monitoring done by the company's staff regularly Sowing to take place during the normal sowing period of the region Sowing was done on 11th May 2005 Register of all visitors to the plot to be maintained No such register is maintained All field trial produce to be destroyed to ensure bio-safety The farmer has uprooted the crop and sold it to someone for the fuel purpose. The BG-II cotton harvested has been sold in the market @ Rs. 2150/- /quintal

Farmer: Harpreet Singh s/o Karam Singh and Mander singh s/o Harnek Singh
Village: Virk Kalan, District Bhatinda
Test Hybrid: MRC-7017 BG-II
Checks: MRC-6301 Bt and Ankur non-Bt hybrid

Field Trial & Bio Safety Rules Actual Situation Field trial permission given only for one acre of land, with three equal trial plots inside it Trial on one acre Isolation distance to be maintained with neighboring plots for cotton to be 50 mts No such distance has been maintained Refuge of 5 rows all around the squarish plot [trapper rows] Refuge of only 4 rows all around the squarish plot [trapper rows] Distance of 2 mts to be maintained between different test and check plots No such distance was maintained Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Regular monitoring by the company people was done Sowing to take place during the normal sowing period of the region Sowing done on 1st of June 2005 Register of all visitors to the plot to be maintained No such register was maintained All field trial produce to be destroyed to ensure bio-safety The farmer has picked the cotton from the trial of MRC-7017 and mixed it with the rest of his crop and some part of this crop has been sold by the farmer while he is awaiting a price hike for selling the remaining crop. The plant parts and residue have been kept for fuel purposes, after uprooting.

Farmer: Balistar Singh s/o Harnail Singh
Village: Gandhar, Muktsar district, Punjab
Trial: Mahyco's MRC 7017 BGII Large Scale Trial
Checks: Not known

Field Trial & Bio Safety Rules Actual Situation Field trial permission given only for one acre of land, with three equal trial plots inside it 80 X 72 karams were used for the trial, which means 2 acres of land Isolation distance to be maintained with neighboring plots for cotton to be 50 mts Only around 11 feet of a path and 5 feet of a canal separate the trial plot from neighboring cotton plots Refuge of 5 rows all around the squarish plot [trapper rows] 4 lines of refuge maintained Distance of 2 mts to be maintained between different test and check plots 2.75 feet only Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Monitoring done by the company uptil the cotton formation stage; subsequently stopped. The farmer informed that even these visits were superficial and no careful recording made Sowing to take place during the normal sowing period of the region Sowing in May 05 [first week] Register of all visitors to the plot to be maintained Not maintained All field trial produce to be destroyed to ensure bio-safety The farmer has mixed the produce from the trial plot along with produce from his other cotton fields and sold it in the Muktsar market.

Farmer: Mr Devinder Singh s/o Bhagwat Singh
Village: Fatehpur Maniawallah, Lambi block, Muktsar district
Test hybrid: Mahyco's MRC 7017 BGII
Checks: MRC 6301 Bt and Ankur non-Bt

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with 3 equal trial plots inside it The trial is happening on one acre of land which is squarish in its shape. Isolation distance to be maintained with neighboring plots for cotton to be 50 mts No isolation distance maintained with neighboring plots which are also cotton plots Refuge of 5 rows all around the squarish plot [trapper rows] Five rows of refuge of non-Bt Cotton was sown Distance of 2 mts to be maintained between different test and check plots Not known Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Monitoring done by the company regularly; a team from the government also came once Sowing to take place during the normal sowing period of the region Sowing took place in the first week of May Register of all visitors to the plot to be maintained The Company did a mela on the farmers’ field; the farmer reports that no records of the visitors of this mela were ever maintained All field trial produce to be destroyed to ensure biosafety The farmer has not been instructed on the destruction of material from the field and is ready to sell it in the local market, at the time of writing of this report

Farmer: Mr Angrez Singh s/o Malkit Singh
Village: Madmallu, Muktsar tehsil, Muktsar district
Test hybrid: Mahyco’s MRC 7017 BGII
Checks: MRC 6301 Bt and Ankur non-Bt

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with 3 equal trial plots inside it The trial is happening on one about one acre of land; however, it is a triangular plot with 3 sides. Isolation distance to be maintained with neighboring plots for cotton to be 50 mts No isolation distance maintained with neighboring plots where on one side Rasi Bt cotton and on another side, Mahyco Bt Cotton are being grown; only four feet of a mud bund separate the trial field from its next plot Refuge of 5 rows all around the squarish plot [trapper rows] Four rows of refuge of non-Bt Cotton were sown Distance of 2 mts to be maintained between different test and check plots Only four feet distance is being maintained (little over 1 metre) Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Monitoring done by the company regularly Sowing to take place during the normal sowing period of the region Sowing took place in the first week of May Register of all visitors to the plot to be maintained The farmer reports that no records of the visitors was maintained All field trial produce to be destroyed to ensure biosafety The farmer has not been instructed on the destruction of material from the field and is ready to sell it in the local market, at the time of writing of this report. He is also ready to use the cotton stalks as fuel at home. He had already mixed the produce from the trial plot with cotton harvested from other plots and is ready to sell this mixed cotton in the local Muktsar market.

Farmer: Mrs Purnima Vinayak Rao
Village: Takar Kheda Shambhu, Bhatkuli taluka, Amrawati district, Maharashtra
Test hybrid: Mahyco’s BGII [coded as D1 in this case]
Checks: MRC 6301 Bt and Ankur 651 non-Bt

Field Trial & Biosafety Rules Actual Situation Field trial permission given only for one acre of land, with 3 equal trial plots inside it Trial happening on one acre, with three equal plots in the rectangular-shaped field Isolation distance to be maintained with neighboring plots for cotton to be 50 mts There is no such isolation distance being maintained the distance from neighboring plots is hardly 3 meters; however, the neighboring plots have crops like sunflower, channa and til [sesamum] Refuge of 5 rows all around the squarish plot [trapper rows] Refuge of 5 rows has been planted on only 3 sides Distance of 2 mts to be maintained between different test and check plots Only 3 feet distance has been maintained between the plots; within this 3 feet distance, a row of hibiscus [ambadi] has also been sown to differentiate the plots Regular monitoring to be done by company personnel and MEC/RCGM appointed teams The company representatives were available on call for advice, according to the farmer; no government teams had visited the plot Sowing to take place during the normal sowing period of the region Sowing has happened some what late, on 5th July, as per the farmer Register of all visitors to the plot to be maintained The farmer reports that no records of the visitors was maintained; there was an exposure visit for other farmers during the first week of November in this plot. The farmer says that no records of the visitors were maintained. All field trial produce to be destroyed to ensure biosafety The farmer, even as she said that the produce from the plots will be kept separately for the company, also said that the entire crop will be sold in the local market

Farmer: Mr Sakthivel
Village: Ottapatti village, Attur taluk, Salem district
Test hybrid: Mahyco’s BGII hybrid
Controls: unknown
Our visit date: December 4th 2005, forenoon
Visit by: Jai Krishna and Sakthivel .G
Field Trial & Bio safety Rules Actual Situation

Field trial permission given only for one acre of land, with 3 trial plots inside it Field trial happening in One and a half acres of land Isolation distance from the trial plot, for cotton to be 50 m. On one adjacent plot, Bunny Bt Cotton is being grown. The distance between the trial field and this cotton field is only around one and a half feet Refuge of 5 rows all around the squarish plot [trapper rows] Refuge is not sown in all directions. It is sown on the east and west side of the land but for six rows each Distance of 2 m to be maintained between different test and check plots 2 m maintained Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Regular monitoring done till the field got affected by floods. The company representative had stopped visiting/ monitoring after that Sowing to take place during the normal sowing period of the region Sowing happened during the normal sowing time of the region Register of all visitors to the plot to be maintained No register maintained, as our visit shows. All field trial produce to be destroyed to ensure bio safety The farmer insists that the produce belongs to him and the company representative has not prepared any buy-back agreement

Note: Till a week before the floods (last week of November) the company representative visited the field regularly. This was abruptly discontinued in December. Faced with losses due to floods, the farmer decided to sow paddy and he had cleared the trial field on 29th December and transplanted the paddy subsequently.

The stalks and other residue were buried in the same field and the small quantities of cotton were harvested and stored soon to be sold in the market.

The exact varieties of the seeds given to the farmer were not revealed. The farmer was told that the centre plot is the new seed and the ones around it are existing varieties. They were named as T1, T2 and T3.

Farmer: Mr Rajamanickam.P
Village: Vadukathampatti village, Attur Taluk, Salem district.
Test hybrid: Mahyco’s BGII hybrid
Controls: Rasi and Mahyco’s hybrids of Bollgard I and non-Bt Cotton
Our visit date: September 27th 2005, afternoon
Visit by: Jai Krishna, Sakthivel .G and Sathriyasekar

Field Trial & Biosafety Rules Actual Situation

Field trial permission given only for one acre of land, with 3 trial plots inside it Field trial happening in One acre and 40 cents.

Isolation distance from the trial plot, for cotton to be 50 m. On the west side of the field there is another cotton plot of RCH2 Bt Cotton and the distance between the two fields is only about 2m. Refuge of 5 rows all around the squarish plot [trapper rows] Refuge criteria followed as specified. Distance of 2 m to be maintained between different test and check plots 2 m distance is maintained between the test and check plots. Regular monitoring to be done by company personnel and MEC/RCGM appointed teams Regular monitoring done every week Sowing to take place during the normal sowing period of the region Sowing happened during normal sowing period of the region Register of all visitors to the plot to be maintained No register maintained, as our visit shows. All field trial produce to be destroyed to ensure biosafety The farmer insists that the produce belongs to him, and the company representative has not sought any agreement.

4. CONCLUSIONS

The MEC has looked at 7 large scale trial fields in Madhya Pradesh [including 5 plots that were right next to each other in the same location], 4 in Punjab, 2 in Maharashtra, 2 in Tamil Nadu and 3 limited/RCGM trials in Andhra Pradesh and 3 RCGM trials in Punjab pertaining to Bollgard II. These cases represent various companies which are on the BGII bandwagon including Mahyco, Rasi, Ajeet, Krishidhan and Tulasi Seeds. This is an "event" that had not cleared bio-safety as yet. During this investigation, the MEC came across several issues which have been brought to the notice of the regulators as far back as 1999 that of unscientific, un-monitored trials with numerous bio-safety violations.

Firstly, field trials are shrouded in great secrecy to this day. Department officials are not willing to share information on field trial locations even if they have such information. Often, it was also found that the local agriculture department officials are not even kept in the loop about such trials happening in their jurisdiction. Such secrecy also means that bio-safety violations happen more routinely. Trial farmers themselves are not educated about the technologies/varieties that they are trying out and therefore, do not feel the need to adhere to bio-safety guidelines. There is no pressure from neighboring farmers and others like the Panchayats either to conform to bio-safety norms because of the secrecy involved and lack of awareness. The companies however benefit from such secrecy since there is no independent monitoring happening of these plots.

Companies undertaking trials are fully liable for adhering to guidelines prescribed for trials both related to bio-safety aspects and the scientificity of trials. It is very apparent from the kind of deals that the companies have with farmers that the companies are only trying to economise on their costs, at the expense of biosafety. A deal for a trial on one acre of land should obviously include a 50 metre isolation distance on all sides if the neighboring plots are also growing cotton, for instance. However, the company, even in cases of lease arrangements, has not bothered to lease in this extra land required to comply with isolation norms.

Farmers are being lured into field trial arrangements since they are getting new kinds of seed free of cost. However, there are no accountability systems in place to protect the farmer in case of failure of this new seed being tested. We had come across many cases of farmers who have incurred a lot of expenditure, to grow this free sample of seed, only to face severe losses, with no one to compensate them for the loss.

Biosafety and scientificity of trials are being violated on every front whether it be sowing time, of isolation distances, distance between plots, careful monitoring and recording of results, careful selection of representative locations for assessing a technology in various growing conditions and for adequate number of seasons, for destruction of crop material after the season so that contamination of supply chain does not take place etc.

Farmer selection for field trials is highly questionable and unscientific. Those with the best resources and management capabilities are being selected for the trials. Majority of farmers who would actually purchase the seed after it is approved for commercial cultivation may not fit into this framework and the results could be very different in their fields, in real life conditions. The MEC has come across five trials happening in the same location in Kalibedi village of Badwani district, Madhya Pradesh. How representative are these trials then of varied agro-ecological conditions of cultivation across the state?

Regular monitoring is missing in many cases that the MEC documented. While lack of monitoring means a lack of accountability towards the trial farmer, it also implies a few possibilities that data is being cooked up for that plot without real monitoring; or that, averages are being created out of smaller number of plots than prescribed (80 representative locations per zone are the usual number of trials asked for), with the company choosing to keep data from only those plots that have performed well. It was very apparent that the monitoring of badly-performing plots is stopped soon after the bad results start appearing”¦.since there is no independent monitoring by the government or others, the regulators would probably never know that data is being manipulated this way. Or probably even if they knew, they do not care about the fate of farmers in the country!

Nearly 1600 large scale field trials of several BGII hybrids of several companies were allowed upto Kharif 2005. From all the cases documented by the MEC, it was evident that in all the field trials, crop produce was being allowed to enter into the supply chain. The collective contamination of the chain is enormously high from all these plots. Furthermore, crop residues were being used for various purposes by the farmers, including as cooking fuel, without the products having been cleared for biosafety. This shows an utter failure of minimum biosafety requirements on the part of the regulators and the companies involved. All the concerned agencies should be made liable for these serious lapses in field trials.

Another serious issue is that approvals for a large number of trials of an unknown product were given knowing fully well that there was no monitoring body in place the GEAC knew that the mandate of the current MEC expires in the month of September and approvals for field trials were given despite the fact that no alternative was put into place.

Companies are indulging in publicity and propaganda over unapproved hybrids and technologies also. Kisan melas [farmer fairs] are being organized at the trial plots, as though these were demonstration plots! This is unacceptable and encourages illegal supply of seeds as is the case with Bt cotton all over India today. This is also being done in violation of norms which require strict compliance of restricted visits to the trial plots of only company authorized personnel, with records of such visits being maintained in a bound book.

This story of how field trials are being conducted in India explains the huge failure of Bt Cotton (in terms of the crop performance as well as the failure of regulation) when farmers grow these crops in real life conditions. The lack of scientificity of trials and their monitoring and an utter disregard to norms and guidelines is reflected in the larger story of how Bt Cotton has actually performed in the past four years as well as the total collapse of regulatory mechanisms and accountability systems in commercial cultivation also.

In fact, the number of years of actual commercial cultivation, before the hybrid is getting rejected by the farmers, is the same as the ideal number of years of field trials. For instance, MECH 12 Bt proved to be an utter failure in many parts in the first year of its commercial cultivation. While this was withdrawn and MECH 184 Bt and MECH 162 Bt were promoted instead, they soon proved to have huge shortcomings too and farmers rejected these in places like Andhra Pradesh.

This then, is the story of how experimentation seems to be happening after approval for commercial cultivation rather than at the time of field trials, at the expense of farmers and their livelihoods!

MEC now demands:

*that the GEAC and RCGM cancel all limited and large scale field trials of 2005

*that a full-blown investigation be carried out on all violations in all trials, BGII as well as various food crop trials, by including members of civil society in the investigation teams. Such an investigation should look at past trials also. For all those cases where violations are discovered, the trials and any subsequent permissions should be immediately cancelled

*that the government not permit any more trials unless the report of this investigation is made public and unless alternative mechanisms of proper monitoring and compliance are put into place. Such alternative mechanisms should include prior informed consent to be provided by Panchayats, participating farmers and neighboring farmers before trials take place in their jurisdiction/on their lands.

*that liability be fixed for violations witnessed so far this should include, at the very least, the EPA liability clauses for contravention of the Act and its

Rules

*that in all those cases where there are standing crops left for this season, that the government ensures that the crop is destroyed immediately and farmers compensated by the companies

*that the government ensures that farmers are compensated properly by the companies also in all those cases where the field trials have created economic losses for the participating farmer

Report of the MEC. The Monitoring and Evaluation Committee [MEC] to monitor Bt Cotton across the country was set up by Adivasi Ekta Sangathan, AKRSP, CEAD, Centre for Sustainable Agriculture, Grameen Vikas Trust, Greenpeace India, Jan Saahas, Kheti Virasat Mission, Krishnadevaraya Rythu Sankshema Sangam, Krushi, MARI, Navajyothi, Pasumai Tayagam, Prasun, Rashtriya Satyagrah Dal, Sampark, Sarvodaya Youth Organisation, SECURE, VASPS and YUVA

Called the "Cartagena Protocol on Biosafety to the Convention on Biological Diversity"

"Concurrent use of transgenic plants expressing a single and two Bacillus thuringiensis genes speeds insect adaptation to pyramided plants" - Jian-Zhou Zhao et al, PNAS, Vol 102, No. 24, June 14, 2005

"Field Trials of GM Crops in India: Illegal and Unscientific": MEC Report
Total area allowed: 1 acre (4047 sq mts)
5 non-GM trapper/refuge rows
Isolation distance from other fields
Check plot: latest released BGI hybrid
Check plot: Popular non-GM hybrid
Test Plot: BGII