Friday, February 05, 2010

Have a Bt Brinjal a Day - Part II

Contd. from Part I here

Concluding Part II

Fair & Lovely?

Regulations, Monitoring, Control ….Labeling Lollipops

It has been suggested that after the products are approved they should be subject to rigorous regulations, monitoring and control. Does such a regime seem feasible? It can only be talked about not practiced. Taking the specific situation of our country with millions of farmers, a long supply chain and logistics issues, regulations will be on paper and any effort to seriously implement, monitor and control would only lead to creating a costly maze of machinery which will keep chasing the goose. Once the genie is let loose, he will break the lamp from where he came and do what it wants, freed from his master. This is all the more so because the master does not know enough about the genie in the first place and the harm that can be caused is unpredictable and will be unexpected.

Even independent verification of data submitted by the applicant entities would serve little purpose because that again would be based on existing protocols which do not take into consideration the very real apprehensions about unforeseen events once the products enter the food chain. The real danger is that of one or more unexpected, uncontrollable events, which cannot be ignored.

It is also suggested that no GM foods should be introduced till there is a labeling regulation in place so that people can make informed choices. If the government is determined to proceed with the introduction, it may well propose to evolve strict labeling laws to silence such objectors. Will that do? Emphatically not. Labeling of GM foods is good only for intellectual discussions. It is an impossible and meaningless idea and once a GM product enters the food chain at the farm level, there is no way to label the food to achieve the so-called choice. Talking of labeling even imported packed processed foods for example, is a sheer absurdity and has no relevance in our country. It will simply provide a ruse to the Government to allow GM foods. Apart from not being capable of meaningful control, such labels would not make any sense for the average consumer except the intellectuals making the suggestion.

No, the issue needs to be stopped only at the threshold. That is the only time and place to make an “informed choice”. Once it has crossed the threshold, it would be impossible to stop it. It would not make sense to first invite a wild beast to enter, roam free and then try to lasso the beast and its progeny – an impossible task.

Case by Case Consideration

To offer a palliative, it has been highlighted that the approval would be on a case by case basis and so if the specific Bt Brinjal is approved now, it does not mean that new products can automatically enter the environment. What is wrong with this logic? A lot. As anyone used to the way in which a government works, precedent is what is important. Once a precedent is established, regardless of case by case consideration, essentially the same principles as well as procedures would have to be followed unless there are completely new situations. Once Bt Brinjal comes in, it will be quickly followed by corn, Jowar(Sorghum), rice, Okra and others. There are 25 kinds of rice, 23 kinds of tomatoes, groundnut, pigeon peas, potato, mustard, sugarcane, soya etc. awaiting GEAC approval. Before long, millions of farmers would become dependent on GM seeds forever.

The only Option?

An impression is being carefully and systematically created that GM foods is the only way to feed the people. The idea at once sounds attractive to Governments and the people because everyone is worried about food. The agriculture mismanagement places a tremendous extra psychological pressure on the Government to clutch at straws that are easier and convenient to catch.

Going by what the experts say, GM foods are not the only option at all to alleviate our food needs. In fact, the world can well do without them. If the Government was really serious about providing food why have they still not taken any major steps to aggressively push totally non-controversial logical actions like creation of storage and logistics infrastructure which would substantially reduce the massive losses across the board not just in one specific product like Brinjal? It is known that there are effective ways of pest management available. Even taking the case of Brinjal, see here and here.
Why have the agriculture extension scientists failed to train farmers in such pest management, optimal use of pesticides and other productivity improving methods? What innovations have been done in our research laboratories that waste billions of rupees, other than reproducing experiments done in other countries and developing countless hybrids that do not have the taste and flavour of the foods any more? After over 50 years of five year plans, is the country so totally crippled in agriculture that it has to now learn to run with untested crutches? And, does it mean that without GM foods, hunger and death are an inevitability for our people?

The only sensible question worth trillions of dollars and our food sovereignty which needs to be asked and answered is:

IF GM technology did not exist or if it was already proved to be harmful, what would the Government have done? Worse, if later on it is conclusively found that the GM foods are not desirable, what would we do?

If there is an intelligent answer, well then, that is what the country should be doing now.

Wider Implication of approval

If the GM food is approved at this stage by a weak-willed Goverment under pressure, there is a much wider implication way beyond the country. If a country of 1.2 billion people allows GM foods, it would be the best endorsement for those involved in the business of promoting GM foods and would be effectively used to break down the resistance of other countries much as is being done now by telling India about the "worldwide" acceptance.

Larger issues of Public Policy

Apart from the specifics, there are much larger issues which have profound and serious implications for Public Policy and even the future of our Independence which would be beyond the capacity of those who are pushing for the GM foods to decide.

First, whether the Government has the right to force-feed the people with products whose effects on their health it does not know for sure? More seriously is the Government competent to bind future generations to live with any ill-effects of allowing foods produced by interfering with fundamental rules of nature? As already discussed above, regardless of any labeling, in effect and in practice the people will simply not be able to exercise their freedom of choice once the product enters the food chain. It would amount to force feeding them.

Secondly, the long term strategic and wider implications of allowing this genie must be considered. In the theory of Globalization that our Prime Minister has been practicing goaded by the developed economies for their own gains, we are inexorably moving towards a situation where right from the first link in the supply chain (agriculture) to the final link (retail), the country is opening its doors to potential domination by the likes of Monsanto and Walmart (
see articles on FDI in Retail). The implications of this proposition, even if it may sound far-fetched or alarmist, can be ignored only at our peril. Particularly in the case of GM foods, allowing a producer to release a product is to ensure for him a virtual monopoly because unlike any other consumer product, every new intending producer of a similar GM food will have to undergo the same testing and approval regime, apart from intellectual property issues. At this stage, it is not known whether a farmer using “A” GM seed could at will switch to “B” GM seed. There is also need to be certain that the GM seeds would not have inbuilt mechanisms (like the Terminator gene) which would make it imperative for the farmers to keep buying new seeds each time.

Knowing how this Government has been implementing policies by a ham-handed approach and manipulation of public opinion rather than by transparency, it is hard to trust that its actions will always be solely guided by public interest. Two examples of its devious ways of working are the introduction of iodized salt (
see here) and FDI in Retail. Anything that the Government is determined to do becomes an action in public interest and supreme national interest and no one can raise a question.

It is really a question whether the Government itself has the competence to decide on this vital issue that impinges upon the freedom of the people and the very sovereignty of the country. It is submitted that it cannot be done without a specific mandate from the people. If it is really convinced about the justification, let it go before the people and seek such mandate.

What should be done?

The Government by now has the benefit of all views and should know the high level of concern that exists in India as well as "worldwide". Unless it simply chooses to erase all objections from its mind, the only course open to it is the sensible suggestion for once made by the previous Health Minister Ramadoss and simply defer a decision for five or more years. That will also provide clarity to all concerned. Any other view could spell unpredictable consequences for health, environment and impinge on the food sovereignty of the country. That, would be unacceptable.

Successors to Jehangir and the East India Company

Jehangir may be forgiven for allowing benign looking foreign traders with a shipful of gifts to set foot in the country and start equally benign sounding trading activity (factory), because he did not have history to guide him.(
see here) But the present Government and the people know enough of History, our own and that of others, and if we fail to learn, we have ourselves to blame for being an Independent nation only by label.

Select references:
Bt Brinjal Primer
Expert Committee II Report
GEAC Decision 14.10.2009
Statements by Scientists
Highway to genetic holocaust
Pawar view
Jairam Ramesh view
Report from Orissa
BBC Report 1999
Finding the Tipping Point
Bt Brinjal a step towards disaster
Prof. Seralini’s comments
Dept. of Biotechnology Brief on Brinjal
Patent application on Bt Brinjal
Prof. Kershen Letter
Do we need Bt Brinjal
Letter by Prof. Schubert, Salk Institute
Statements by GEAC member
How BT Brinjal was cleared
All Mahyco’s Men
Brinjal Pest Management
Brinjal Pest Management II
Prof. Seralini Talk
CSA Briefing
Who Benefits from GM Crops 2006 Report

Who Benefits from GM Crops 2009 Report
Does the world need GM foods
GM Food – Myth and Reality
Force feeding of Iodized salt
FDI in Retail – contrived justifications
FDI in Retail - Charade
Successors to Jehangir

It is time for the People to speak up

Have a Bt Brinjal a Day - Part I

This article is about GM foods, an issue of crucial importance for the people and in attempting to analyze the same in some detail, it has ended up being somewhat long. It is presented in two parts.

Part I

An unprecedented and furious debate has been raging due to the imminent introduction in India of the first GM food, Bt Brinjal which was recently recommended for release by the official Genetic Engineering Approval Committee, GEAC (aptly mentioned in a government memorandum as Genetic Approval Engineering Committee – a Committee to engineer approvals).
see here.

But the GM foods (termed Frankenfoods by many) controversy was not born then. Brinjal transformation in India was initiated as early as 2000. Prior to that the initiation of Bt Cotton started with approval for import of transgenic seeds in 1995 and the release of Bt Cotton was finally approved in 2002. Grave concerns have been and are continuing to be raised all over the world about GM agricultural products all through their journey for nearly two decades.

The concerns being raised have so far not being satisfactorily addressed and the Government appears determined to allow the first GM food into the food chain.

The main issues, about which people are and ought to be concerned, are: Ethical, Health and Environment and larger issues of Public Policy.

Leaving the much larger ethical issue aside, although it deserves to be debated, it is critical to examine the other two issues in detail as this first approval or rejection may be a momentous decision for the country and for the people in the present time and the future generations. For this reason, the people should be involved and engaged in this discussion, not merely shrug it off by accepting whatever the advocates of the GM foods or the Government dish out. For a broad idea of the specific issue of Bt Brinjal, it is useful to refer to
this publication by the Ministry of Environment & Forests.

"I should not be blamed then for the price rise"
A Brinjal of Contention

Immediately after the GEAC recommendation was made on 14.10.2009, the groundswell of protests gained momentum following which the Environment Minister Jairam Ramesh announced holding consultations with all interests before taking a decision. With his public hearings still underway, Pawar reportedly objected saying that the GEAC approval was final and the central government did not have any say in the issue. see here .
By experience, people know by now that utterances of Pawar are best ignored when it comes to judging public interest as opposed to private interest. Jairam rightly opposed his stand. Even the GEAC had said “Since this decision of the GEAC will have major policy implications, the GEAC decided to forward the recommendations and report of the Expert Committee….to the Government for a final view”. (Here)

The issue does have great public policy significance and cannot be confined to the scientists alone. Scientists like everyone else, know what they know and do not know what they do not know. They are not omniscient. Even when totally objective, whatever they say is based upon only the present state of their knowledge. They try to stretch the frontiers of knowledge all the time. That is how knowledge grows. They may also try to create something novel based on that knowledge.

Whether they claim ability to clone sheep or pigs or politicians with desirable characteristics, it is for the society to draw up their limits based on ethics and plain good sense and whatever they come up with by remaining within those limits, decide what is acceptable and what must be rejected. A very simple but related example is that of Basmati Rice. Scientists at Pusa Institute developed a hybrid closely resembling the premium pure Basmati minus its flavor. The scientists proved that they could do something like that but the new Evolved Basmati should have remained in their labs. Instead, it was released in the market. Who benefited? It benefited the adulterers for whom it is an ideal adulterant. Major importing countries were forced to evolve strict standards and even DNA based methods to check the adulterated Basmati. But the Indian consumer continues to pay a high price for a highly adulterated product happily believing it to be pure Basmati. Did it benefit the Basmati farmer or the consumer? No. Is any regulation and control working? No.

The mind of the Government is already made up

The public consultations may well be a mere charade to give the appearance of taking a balanced view for a decision that is already made elsewhere and balance already tilted on one side. The Government is known to work in this manner. The Prime Minister has hinted at an imminent positive decision stressing only on “appropriate regulatory control based on strictly scientific criteria”. (see here) Clearly he and his ministers know what the decision must be.

If the Government really wanted to have an informed debate involving the people on this crucial issue, it should have published long back a Green Paper. Rather than wasting 100s of crores of rupees from public funds on advertisements for promotion of politicians and announcing inauguration of minor events, it should have undertaken a major advertisement campaign fairly and transparently placing before the people the issues and the views of both the sides of the debate without giving out its own comments as it has done at this late stage by means of the Primer which is still not available widely. Obviously the people are just guinea pigs. How can it be believed that it genuinely wants to consider the views of the people?

Commercial Interests

Those who object to GM foods are also concerned about the fact that the entire movement for GM foods appears to be strongly driven by global commercial entities whose record is far from clean and who are the real beneficiaries at the cost of the supposed beneficiaries. See the reports here
and here .

In a recent news report, it has also been suggested that some members of the GEAC may be favourably disposed towards the entity whose Bt Brinjal is being considered. see

For every global business, India and China are the new frontiers to be attacked and conquered for their businesses to grow. This is true of agricultural inputs too and it is but logical that the companies involved in GM foods are vigorously pursuing entry into this market. In the light of our eagerness to embrace globalization we have demonstrated that we do not have the will to resist pressures for long and if the will exists, it is not impossible to weaken it by various means.

If the likes of Walmart having a plain retail business can lobby to enter into India, Monsanto can hardly be blamed for trying to sell their technology based product. Such interested parties have been extolling the virtues of their offerings from Retail trade to Branded Consumer products to GM foods and the Government has been lapping up their exaggerated claims and placing cut-and-paste copies before the people. The same arguments –“farmers will benefit”, “consumers will benefit” - applied for FDI in Retail are also being applied to GM foods. See here
and here.

Like all good salesmen whether they sell wonder wash detergent or magical weight loss program or double-your-money scheme, they will exaggerate to a point where customers will feel left out if they do not buy. Ultimately, it is left to the sanity and good sense of governments and the people to separate the chaff from the wheat. It would not be far fetched to say that especially in the case of GM foods, it is akin to a pusher tempting a potential customer for drugs which would lead to dependency. Caveat emptor – let the buyer beware.

Wonderful things GM foods will do

These salesmen claim that GM foods will dramatically reduce insecticide use, increase yield, faster growth, impart beneficial properties etc. The claims are limited only by the seller’s inventive genius. E.g.
- Food that can deliver vaccines- banana that can produce Hepatitis B vaccine (why??)
- Perhaps, Apple with the texture of jelly, taste of Jackfruit and shape of a beer can?

What Bt Brinjal involves

Brinjal is a plant native to India and is produced in India for over 4000 years. The country produces over 9.6 million tons of Brinjal annually with the top four producing States being West Bengal (29%), Orissa (20%), Bihar (12%) and Gujarat (10%) accounting for over 70% of the total. Apart from other pests, the main pest that attacks Brinjal is the Fruit and Shoot Borer (FSB). The Bt Brinjal variety is specifically developed to control the FSB which develops inside the fruit making it difficult to control it except with precisely timed pesticide application before it reaches the inside.

Bt Brinjal is a transgenic product made by inserting the toxin Cry1AC from bacterium B. Thuringiensis into Brinjal to induce resistance specifically to FSB. It is like the toxin getting under the skin of Brinjal and acting as toxin for the FSB resulting in its death. It would appear that the dead FSB would still remain within the fruit. Further, to an average person, it would seem that once the toxin is inside the fruit (even as a protein), it would logically remain there and get into the human body when it is consumed. It is also known that the pests develop resistance to pesticides over time, but it is claimed that in case of Bt toxin within the fruit, no such resistance would be developed. The scientists have tried to explain the issue and it is best left to the experts to agree or disagree on the same. But it does alter the genetic pattern of the food which has been developed over millennia.
The Expert Committee II has also included in its Report quantification of the economic benefits due to usage of Bt Brinjal. It is not clear whether the higher seed cost has been offset. But the point to note in all such benefit estimates is that they may be exaggerated and even if accepted at face value, once the product is commercialized, there is no way to ensure that such benefits continue to accrue over a period. They may well disapper over time.
Gene, the genie

Health and Environment issues

Many issues have been raised by experts and NGOs on health and environment related issues not only of Bt Brinjal but also GM foods per se. The objections are not peripheral but substantial and far from being emotional. It is not mere scaremongering. If the GM food advocates want scientists’ views to be respected, so also should the opposing views from scientists be respected. The fact that there is an overwhelming body of objectors, distinguished scientists and academicians themselves and with no apparent vested interest to oppose GM foods lends significant credence to the arguments of those who protest against GM foods. Just one article will indicate the status of the objectors and what they have to say. See Statements by Scientists.
Also see: Highway to genetic holocaust and a Letter from Prof. Schubert of the highly respected Salk Institute. (More references are given at the end of this article and may be referred to.)

The Expert Committee Report does seem to have considered in detail the findings on the large scale tests and also tried to respond to many of the questions raised about the findings, including the points of Prof. Seralini (see here) and Dr. P. Bhargava, (an invitee as directed by the Supreme Court), on whom some are placing reliance to voice their own objections.

But there are aspects related to the EC II Report and the GEAC meeting at which the same was approved, which raise concern about the way in which the matter has been gone about (engineered?)

1. Decision of GEAC was hurriedly taken within just 6 days of submission of the EC II Report.
2. Absence of Health Ministry representative in GEAC meeting. It is known that the previous Health Minister had objected to the introduction of GM foods by writing to the Prime Minister. Although he was part of the EC-II which reviewed the findings, the GEAC meeting was for a higher purpose. No leave of absence of absentees has been noted in the GEAC meeting.
3. It is accepted that Brinjal has its origin in India. see a Ministry Document and
also see a Patent application on Bt Brinjal as also the position of National Bureau of Plant Genetic Resources. The Cartagena Protocol on Biosafety has provisions that discourage genetic modification of crops in their land of origin. Apparently in order to get around this provision, the EC-II cited references just to show that there was no certainty about the origin of Brinjal.
4. CFTRI representative on the GEAC had suggested to test the Bt Brinjal for flavour which is an essential element of any food item apart from taste, texture, cooking quality and composition, Inexplicably, CFTRI refused to do the test on transgenic food. The EC-II decided to ignore this saying that the test was not required. This may be strictly true but doubts remain about the issue.
5. EC-II has noted that “Adoption of transgenic crops engineered primarily using the cry proteins to prevent damage caused by insect pests has given excellent results in cotton and maize worldwide resulting in significant economic benefits. A similar approach in brinjal is expected to provide substantial benefits to farmers.” The term “worldwide” has been freely used in the Report to suggest that if the entire world is accepting it (false), India must do it too. The term “worldwide” is designed to mislead. By far the main production is confined to the American Continent with USA being the biggest. In the USA itself, GM crop production actually increased pesticide use by more than 4 percent between 1996 and 2004 (see here)
It is more true that there is a worldwide disagreement on the need and desirability of GM products.
6. The GEAC opined that the cry1Ac gene incorporated in Bt brinjal event EE-1 is 100% identical to the one expressed in Bt cotton event MON-531 approved in India and globally. The fact is that the same is approved in the case of cotton and more important, the term “globally” is used to show as if Bt Cotton is grown all over the world which is not so.
7. How bt brinjal was cleared ( see here)
8. EC-II has rightly focused only on the prescribed tests saying that Regulatory mechanism is a dynamic process which is continuously updated based on scientific developments and evidences. But in the first place,there are doubts about the initial parameters set for the tests. The fact that decisions are based on these tests also shows that if subsequent evidence raises serious issues, it would be too late to correct the situation. This becomes important precisely because the discussion relates to products entering the food chain. Science is replete with examples, starting with DDT and now encompassing even the later-day pesticides, of how inventions hailed as panacea are now recognized as harmful by the very scientists who might have once promoted them enthusiastically and unreservedly.
9. The scientists making the recommendations have already given enough caveats to make it clear that they are basing their decisions on the tests as prescribed, on the findings as presented and on the basis of existing knowledge. See this: “Our collective wisdom is limited on recombinant technology. Therefore, we are treading carefully. Decisions have been based on current evidence in science. But, we must have a system of post-marketing surveillance to assess health impacts,” and “Brinjal is not a staple food for anybody. Unless the (GM) product is in use, how can we say? What will happen in the future is anybody’s guess” a member of GEAC expert committee, Vasantha Muthuswamy, said. In any case, she said, “the Bt gene may already have become a part of the food chain, as Bt cotton cakes are being used in animal feed and fodder.” (see here) Such remarks ring loud alarm bells and confirm that the scientists simply do not know enough at this stage and they would like the products to be first released in the food chain. It also shows that the Government approved Bt Cotton earlier without even considering that the product could enter the food chain. It would be reckless to repeat the same for an item of direct use without regard for the real fears and apprehensions already expressed by other equally or more knowledgeable scientists.

While the scientists may have kept escape clauses, the Government has a higher responsibility. It cannot simply say that they relied on what the scientists said and agreed to release. If anything goes wrong, who will take the responsibility and be there to face the consequences? This Government and the Ministers?

Bizzare Arguments

To push the case for GM foods, some really bizarre arguments have been used. For example:
a. EC-II, while rejecting the need for additional tests proposed by Dr. Bhargava, invitee at the instance of the Supreme Court, said “Raising the bar of the regulatory process based on hypothetical concerns and apprehensions would be highly detrimental for research and development in the area of agricultural biotechnology especially for public sector institutions.” It is an outrageous suggestion that just because research is done by a public sector institution it should be spared rigorous requirement even where human health and environment concerns so demand.
b. Another advocate from abroad one Prof. Kershen has written to the Environment Minister giving some bizzare arguments including “By failing to approve the commercial cultivation of Bt brinjal, India runs the very strong risk of discouraging agricultural research and development. India needs and deserves agricultural research and development from its scientists to reduce poverty and to remain competitive. But they cannot provide that research and development if their efforts are thwarted. ” (see here) Does this mean that the products need to be approved just to make the scientists happy?? No true researcher or scientist gets discouraged if his efforts do not yield fruit because that is inbuilt in the nature of his work, nor does any business get discouraged if one of its ventures fails. And why is HE pleading for scientists of a private entity? To present such an argument is to insult the intelligence of the Minister. The Professor says that he has been following the matter closely since 2000. The contents of his letter are enough to suggest that vested interests may be involved. Even assuming that it is not so, the arguments are worth ignoring.


see Part II here

It is time for the People to speak up