EXCERPTS: ...the farmer was not informed that this was a transgenic crop trial. He was not aware about the Bt Okra seed being planted on his land. This raises questions of ethics as well as issues related to conforming to biosafety guidelines.
Since he did not know what the crop was, it was more likely that he would violate norms. He did. The farmer and his family consumed the untested and not-yet-cleared-for-safety Bt Okra from the trial plots at least twice. The Field Assistant of the company was also not aware that this was a Bt Okra trial at the beginning of the season. He was told about it only later. This is also a matter of concern.
The farmer was also unaware about who was conducting the trials. His only point of contact was with a temporary employee of Mahyco [Indian partner of Monsanto]. From the 15th of December, this employee’s contract with the company has been terminated and there have been no more visits to the farmer’s plot by anyone. This was soon after a team of university scientists came and visited the plots.
The farmer does not know what to do with the crop on his plot no one has given him clear instructions on what to do and he is not sure whether he can uproot the crop, given that the crop belongs to the company! There is also clearly no liability-fixing mechanism in place here in case of crop failure as well as in case of other hazards emerging from the trial.
Discussions with some Mahyco employees revealed that as far as the company is concerned, the "trial is over". This kind of attitude by the company, while there is a standing crop in the field, is obviously a precursor to many possible violations. A trial does not get over when the regulatory team leaves and not until the crop has been destroyed properly!
Centre for Sustainable Agriculture has just visited a Bt Okra Field Trial in a farmer's field in Guntur district of Andhra Pradesh and found serious violations in biosafety guidelines and norms. This is probably the first time that a food crop trial was investigated by a civil society group while there is a standing crop in the trial plot. A report on this trial is being attached to this mail.
- to place a moratorium on all GE crop research and releases in the country, until the country decides through an informed debate whether India should have transgenic agriculture or not, especially in its food crops
- to fix liability on the company for the violations seen in this case. this includes the penal clauses of the Environment Protection Act 1986, with its 1989 Rules pertaining to GMOs, for contravening the Rules and Guidelines laid down under the Act
- to take responsibility on behalf of the DBT for giving many permissions without monitoring and regulation mechanisms in place
Centre for Sustainable Agriculture
12-13-445, Street # 1, Tarnaka
Secunderabad 500 017
Does India need GM Food? the case of the Bt Okra Field Trial in Guntur
A team from Centre for Sustainable Agriculture (Mr Gangadhar Vagmare, Mr Ramprasad and Ms Kavitha Kuruganti) uncovered a Bt Okra Field Trial happening in Guntur district of Andhra Pradesh on 19th December 2005. The plot was re-visited on 21st December. The following is a report on this trial and the serious concerns it raises.
First, consider this:
* Worldwide, the pipeline of GM crops research is drying up. Statistics available from US, Canada, EU and other countries show that the number of field trials of GM crops began declining in 2003 . By the middle of 2005, not a single application was filed in the US for any fresh trials. Not so in India however. The markets that India promises for the driven-out biotech corporations are huge. So is the haven provided by lax or non-existent regulation. The quantum of transgenic research in India only seems to be swelling, year after year.
* Many recent studies from across the world have strongly reinforced fears about the dangers of GM foods. India however plods on, happily unconcerned and/or unknowing. There have been many instances when the companies involved had to voluntarily withdraw the GM product after such studies and scandals elsewhere. At least three recent report, from Russia, Italy and Australia, along with the findings from Monsanto’s much suppressed study, raise fresh concerns on GM foods.
* Limited field trials have been authorized on 14 new food crops/varieties this year in India these include cabbage, cauliflower, brinjal, chickpea, groundnut, maize, mustard, potato and rice [October 17th 2005, Financial Express]. Both public sector and private sector enterprises are happily jumping onto the bandwagon of GM crop research.
* It is suspected that GM Mustard trials, the first trials of a GM food crop, were earlier taken up in Morena district of Madhya Pradesh in farmers’ fields by Pro-Agro/Bayer Crop Science in 2001-02. After getting rejected for approval in November 2002, experimentation on this crop was withdrawn, as were tests on several other crops by Bayer. However, other companies are going ahead with trials of several food crops including vegetables like okra and brinjal. Latest information obtained from a company like Mahyco points out that Large Scale Trials have happened last year in Kurnool district in a farmer’s field. Like most other such trials, it is not clear whether this was done with the permission of GEAC, whether all guidelines were complied with etc.
* While the Department of Biotechnology [DBT] has a one-track agenda of promoting transgenic agriculture amongst other kinds of biotechnology and allowing field trials all over the country, last year, the Indian Council for Medical Research [ICMR] sounded a severe note of caution on GM foods in India. In a report entitled "Regulatory Regime for Genetically Modified Foods-The way ahead", the ICMR invoked several studies from across the world to point out to the potential problems with GM foods and has asked for an overhaul of the existing regulatory systems. It takes note of the allergenecity potential of GM crops and the case of potential health hazards of GM potato, amongst other things.
* Reports of violations of biosafety and scientificity during field trials are present from earlier years, as in the case of Bt Cotton. However, no perceptible improvements are made in the regulation framework or on the ground. This, despite the fact that India is a signatory to the Cartagena Protocol on Biosafety.
* On another front, there has been no consensus reached anywhere about the desirability and efficacy of GM food crops in India. The National Biotechnology Development Strategy a policy paper of the Department of Biotechnology has met with stiff opposition from various quarters including prominent farmers’ organizations for its overly positive outlook towards transgenic crops. India is yet to decide by processes of wide consultation and participation on whether it wants GM crops and whether its farmers and consumers would benefit out of it. Such a process necessarily requires informed decision-making and we are far away from that, given that most farmers and consumers have not been informed about the various sides to GM crops.
The GM Cotton experience in India, on a non-food crop, is unresolved and has several lessons to teach the world about faulty technologies, lax regulation and disastrous results for farmers. It is in this context that the Bt Okra trial assumes great significance.
And now, a Bt Bhindi [Bt Okra or Bt Lady’s Finger] field trial?
* A Bt Okra Field Trial by Mahyco is currently underway in a farmer’s field in Narakoduru village in Guntur district [Shri Ardula Koteswara Rao]. This is probably the first time since 2001/02 that a GM food crop has come to light, being tested in a farmer’s field rather than in greenhouses and campuses of companies and agri-research institutes. Such trials are in almost all cases conducted shrouded in great secrecy.
* This transgenic variety is being apparently developed to create resistance in the okra plant to fruit and shoot borer [Earias] by inserting a Bt gene called Cry1Ac. A quick search of literature shows that it is probably only in India that Bt Okra is being experimented on, at such an advanced stage of trials. The plot visited was following a Random Block Design.
* Approvals for limited field trials on Bt Okra were accorded by DBT to Mahyco in 2003-04 [in addition to ten other crops, as per the Annual Report of the Department of Biotechnology]. However, such an approval is not seen in 2004. [http://dbtindia.nic.in/annualreports/2004-05/Extras/chap-07.pdf]. Nor is it seen in media reports of fresh approvals for 2005. Independent confirmation by some media representatives with the DBT shows that this has approval from the DBT.
* The limited field trial is happening on a 40-cents plot leased in from the farmer by Mahyco. The farmer has been paid Rs. 7000/- as the lease rent.
* Sowing of the plot took place on the 7th of August, 2005, as per the person employed by Mahyco to oversee the trial in this plot [Shri Brahma Raju]. The seeds were first grown in nursery bags and later transplanted. The transplanting took place quite late in the season, compared to the usual sowing time, as per the farmer.
* There have been four sprays of pesticides, as per the farmer and the employee of the company. The CSA team noted that the plants in the plot had several diseases and pests including bacterial leaf spot, cercospora leaf spot, yellow vein mosaic, spotted bollworm, powdery mildew, spodoptera, jassids, aphids and white fly. Though it is not clear from our visit which plot consisted of what variety, all the plots had several problems with regard to diseases and pests. Interestingly enough, the refuge/border lines show better growth and fruiting than the entries. So much for the performance of the crop.
* There are several violations and issues of concern with the trial. Firstly, the farmer was not informed that this was a transgenic crop trial. He was not aware about the Bt Okra seed being planted on his land. This raises questions of ethics as well as issues related to conforming to biosafety guidelines. Since he did not know what the crop was, it was more likely that he would violate norms. He did. The farmer and his family consumed the untested and not-yet-cleared-for-safety Bt Okra from the trial plots at least twice. The Field Assistant of the company was also not aware that this was a Bt Okra trial at the beginning of the season. He was told about it only later. This is also a matter of concern.
* The farmer was also unaware about who was conducting the trials. His only point of contact was with a temporary employee of Mahyco. From the 15th of December, this employee’s contract with the company has been terminated and there have been no more visits to the farmer’s plot by anyone. This was soon after a team of university scientists came and visited the plots. The farmer does not know what to do with the crop on his plot no one has given him clear instructions on what to do and he is not sure whether he can uproot the crop, given that the crop belongs to the company! There is also clearly no liability-fixing mechanism in place here in case of crop failure as well as in case of other hazards emerging from the trial.
* Discussions with some Mahyco employees revealed that as far as the company is concerned, the "trial is over". This kind of attitude by the company, while there is a standing crop in the field, is obviously a precursor to many possible violations. A trial does not get over when the regulatory team leaves and not until the crop has been destroyed properly!
* There were other violations in terms of the design of the plot there was no distance maintained between different treatments in the East-West direction, and between the treatments and the border rows on the side of the plot adjacent to the road.
* Similarly, it was not clear how a non-agriculture specialist employed by the company, a person who does not have an agriculture background nor is a practicing farmer but only employed for the season, is expected to record data from the field. Would he be able to distinguish between helicoverpa and spodoptera, especially in the earlier instars?
* The team discovered that all plots received the same kinds and quantities of pesticide sprays, as per the farmer and the employee. If this was the case, what would the data indicate? How can it be concluded that the pest incidence noticed was because of the presence of the Bt gene and not the pesticide sprayed?
* Though isolation distance was maintained, the farmer and his neighbor were made to believe that this is a seed production plot and that isolation was required for that reason. Information that this was a transgenic plot was not shared with them though.
* One of the norms for conducting trials says that only company authorized personnel should visit the experimental field and that a list of all visitors should be maintained. This did not happen as our own visit shows.
* The person employed by Mahyco is reported to be selling off the vegetables from this plot in the Guntur market and contaminating the supply chain. This, of an untested product. While he told CSA representatives that he had burnt the harvested products in the field itself, it was clear from our visit and from the farmer’s interview that the evidence of burning some fruits in the field was an afterthought. The quantities destroyed clearly do not account for the total quantity harvested so far. The farmer reported that the employee wanted to make a little money out of the trial and would have sold the produce in the open market. This, despite biosafety guidelines that say that all material from the field trials should be destroyed by burning.
* The agriculture department in the district is not aware of the trials happening. There is also no DLC [District Level Committee] formed [as per the Environment Protection Act 1986 and its 1989 Rules pertaining to GMOs] in Guntur district to oversee the various biosafety and other issues in the research and use of GMOs. The company representative informed us that the Assistant Director Horticulture was informed. Once again, it could not be confirmed whether the ADH was informed before the trial began, or whether s/he was informed at all. At the state level however, the Commissionerate of Agriculture was not informed about the trial. This is a repetition of the story of Bt Cotton trials in 1998-99, where state governments were not informed and their permission not sought.
This Bt Okra trial by Mahyco in the farmer’s field once again raises a host of concerns:
* the undesirability of GM food crops and the unresolved concerns centred around GE crops
* non-transparent functioning and decision-making related to GM crops
* the promotion of GE research on a large scale, in a large number of locations without adequate monitoring and liability mechanisms in place, especially to ensure biosafety of the trials is a violation of the principles enshrined in the Cartagena Protocol [of which India is a signatory]
* the violations being committed in the field trials endanger the environment and human health of the farmers and consumers, especially since there is contamination of the supply chain with untested products
* though EPA has a penal clause for violations of the Act and its Rules and Guidelines [of imprisonment of five years or fine of upto one lakh rupees or both], the GEAC and other authorities are choosing to turn a blind eye to all the violations happening on the ground
* the liability of GEAC and DBT, as approving authorities which cannot seem to ensure compliance to rules and guidelines
* trials that do not follow scientific norms are also bound to lead to faulty results, which end up in farmers obtaining unexpected results as in the case of Bt Cotton. Incidentally, this trial is being conducted by the same company which defied the Government of Andhra Pradesh when it was asked to take liability for the losses that farmers incurred with its Bt Cotton hybrids.
Centre for Sustainable Agriculture demands that all field trials in India be cancelled with immediate effect unless it is ensured that such trials can be done with biosafety and scientificity fully incorporated. Further, trials on food crops are not to be allowed until an informed debate is organized with farmers and consumers on the desirability of GM food crops in India.