From Dr Sagari R Ramdas
Director, Anthra

To Shri Jairam Ramesh                             
Minister, Environment and Forests
Ministry of Environment and Forests
New Delhi     
January 18,  2010

Dear Shri Jairam Ramesh

Sub: Addendum to my submission on Bt Brinjal, submitted on December 1st 2009.

Circular arguments and Mahyco Company Data being cited by the Regulatory Authorities as proof of safety of “Bt toxin tolerance range”.

I am attaching for your information the RTI response from the Department of Agriculture Biotechnology, NG Ranga Agriculture University, Andhra Pradesh, India regarding the source of their information of supposed “tolerance” levels of Bt toxin in Bt Cotton.

i) In Point 4, page 4 of my earlier submission I present how the GEAC has cited safe tolerant levels of Bt toxin as evidence of the safety of Bt cotton that was grazed upon by animals, which subsequently died. These “tolerant levels” were based on a letter submitted to GEAC by the Animal Husbandry Department, Andhra Pradesh (AHD), dated May 2007 (ref: No 3531/Epid/2006.dated 9/5/2007) (annexure 6)

 “ The Bt protein levels detected in the samples of Bt cotton bolls and leaves sent for analysis was recorded as 5 /gm. This level is within the tolerable range which is said to be “5-10 /gm”.  

The AHD had in turn cited this information from the Department of Agriculture Biotechnology, NG Ranga Agriculture University, Andhra Pradesh, which had tested samples of Bt cotton plant (bolls and leaves), which were sent to them in connection with reports of death in sheep after grazing on Bt cotton in 2006.(ref: letter roc no: 14627/Epid/2006/,  dated 20/9/2006).

ii) My organisation filed an RTI to the Department of Agriculture Biotechnology, NG Ranga University, AP, to obtain their source for the Bt toxin tolerance levels as also information on the tests and methodologies they have used to assess these safe tolerant toxin levels, with respect to the Bt cotton.

iii) In the RTI (annexure 1), the department states that the source of the Bt toxin tolerance levels is from the Department of Biotechnology, Government of India, cited from the IGMORIS website and is cited from the biosafety data of Bt cotton submitted by the companies”. This is completely unacceptable, and illustrates the complete incapacity of our research institutions to do any kind of independent research to prove or disprove whether Bt toxin was the cause of morbidity and mortality in animals that died after they grazed on Bt cotton.

iv) The Department further states that these biosafety tests were conducted by feeding pure Bt protein as also Bt cotton leaves to test animals such as rats, mice, guinea pigs, rabbits, goats and sheep.

This is completely untruthful. Not one bio-safety test was carried out feeding animals Bt cotton leaves. The biosafety data mentions that all tests were done feeding Bt cottonseed, and / or cotton seed cake to animals, and not Bt cotton leaves.

v) The absence of testing on leaves is precisely why civil society organizations such as ours, as also the Department of Animal Husbandry, GOAP, had demanded that all further testing should include feeding animals on leaves, which was accepted, and then turned down by the GEAC (see page 1 of my earlier submission).

v) It is unbelievable that an “independent” public research institution is reduced to quoting the industry and company’s data of safety, exhibiting absolutely “zero” capacity of being able to conduct independent inquiry and investigation.

vi) The RTI once again only reconfirms our worst fears regarding the utter and total scientific incompetence of our regulatory bodies and research institutions, which appear to be completely enslaved to the industry, and blatantly, tell the public falsehoods, so as to uphold the safety of the technology.

The regulatory authorities are using circular arguments, each one quoting the other, and then finally quoting the industry and companies’ data and research as proof of safety, which is unacceptable.  

The regulatory authorities have clearly failed in their role in investigating a straightforward problem of animals falling sick and in some cases dying from grazing on Bt cotton, something that has been happening since the past 5 years. This additional RTI illustrates yet again, the incompetence as also the absence of all scientific rigour and integrity within the research institutions and the regulatory authorities such as GEAC. If this is the case with animals, we can well anticipate what will unfold with respect to human beings who will be made to consume Bt toxin in Bt Brinjal, if the latter is allowed to be commercialized.

The issues of safety with respect to Bt toxin, are completely unresolved.

We demand a complete moratorium on all genetically modified crops including Bt Brinjal and Bt Cotton as they fail to meet any notions of safety. Further the complete failure and incapacity of the regulatory authorities in the country as demonstrated in the case of Bt cotton and Animals, threatens the safety of our citizens, animals and the environment.  

Yours sincerely
Sagari R Ramdas