'Inaccurate Information Has Led To Erroneous Policy'

Note: This sign-on letter is prompted by the communication, authored in July, 2009, by Mr Prithviraj Chauhan, written in his capacity at that time as Minister of State in the Prime Minister’s Office. This letter entitled “Concern on Introduction of Genetically Engineered Crops and Food” was an official response to a letter from Dr A Ramadoss, addressed to Prime Minister Dr Manmohan Singh (full letter attached), dated 2nd February 2009, when he held the portfolio as India’s Minister of Health.

In its opening paragraph it says: “the various issues raised in your letter have been examined carefully and by applying the best scientific evidence available today”. However, the signatories to this letter wish to respectfully bring to the attention of Prime Minister Dr Manmohan Singh, numerous factual and scientific errors within the Chauhan letter. From the content of this letter and its phraseology, it is apparent that much of it was excerpted directly from promotional materials of the agricultural biotechnology industry, in particular the International Service for the Acquisition of Agri-Biotech Applications (ISAAA), an organisation that at best can be described as pseudo-scientific, funded primarily by Monsanto and other biotechnology multinational companies and whose purpose is to promote and facilitate the commercial introduction of genetically modified (GM) crops in the developing world. Inaccurate information has led to erroneous policy on GM crops and Bt brinjal in particular. Therefore, in the context of the current debate on the introduction in India of its first major GM food crop, Bt brinjal, to be grown on a commercial scale, we strongly urge the Prime Minister to consider the factual and authoritative scientific content of this letter.

We hope that this letter will help to bring the true facts of GM crops into the open to enable an informed discussion on their unique risks to food security, farming systems and bio-safety impacts which are ultimately irreversible. We urge the Prime Minister, for the sake of the safety of the Indian people, and the welfare of Indian farmers, to re-address the official position on GM crops. The global community needs India to lead in the matter of exemplary regulation of these crops.

We highlight some of the many major inaccuracies found in the Chauhan letter in italicized quotes, followed by our comments with numbers in parentheses indicating items in the list of supporting References.

i. “With the rapid progress in advanced biology, biotech crops have been developed with the help of genetic engineering tools to possess special characteristics that make them better. ----also known as Genetically Modified (GM) or Genetically Engineered (GE) crops. The most common traits deployed in biotech crops so far include insect resistance, herbicide tolerance, virus resistance and improved product quality.

This statement broadly oversteps the facts and is in fact erroneous.

More than 95% of all GM crops are engineered to either synthesise an insecticide (Bt toxin) or to tolerate a broad spectrum herbicide (e.g. Roundup, Liberty) or both.
Despite many years of research, no GM crop is currently “deployed” with “improved product quality” as is claimed.
To date there are only four major commercialised GM crops (soya, maize/corn, cotton, canola/oilseed rape) most of which (soya, corn, canola) are used primarily as animal feed. All were commercialised in the late 90’s. Since then, no other commercially viable GM crop application has made it to market, especially due to farmers not accepting other GM crops (such as wheat, potatoes, and rice) for negative economic reasons (lack of buyers, loss of export markets).
GM crops have not been widely accepted around the world. 95% of all GM food crops are grown in only 5 countries: the US, Canada, Australia, Argentina, and Brazil. If you include fibre crops (cotton) India and China would be included. Only one GM crop is approved for cultivation within the European Union, MON810 corn, which has been banned by several member states invoking documented health and especially environmental risks.
Only two minor food crops have been released in the USA (squash, papaya) and one in Mexico (squash), which are engineered in an attempt to make them virus resistant. The outcome has been a mixed blessing; GM squash is resistant to some viruses but renders it more susceptible to attack by beetles (1).

ii. “It is expected that development of crops with tolerance to drought and salinity, improved nitrogen use efficiency, enhanced yield, quality and nutritional properties coupled with existing traits will be technically feasible in the near future and be a real value addition in India. From a technological perspective, what is feasible tomorrow is even more promising but scientists and Indian Industry need a predicable regulatory and social environment. At the national level, it will make agriculture more efficient and competitive to meet the challenges of hunger, poverty, malnutrition and food security in tomorrow’s world (Global Knowledge Centre on Crop Biotechnology, 2008)”

These “promises” taken verbatim from ISAAA industry promotional material do not match either scientific fact or reality.

“tolerance to drought and salinity, improved nitrogen use efficiency, enhanced yield, quality and nutritional properties” are hypothetical claims which have been made by industry for 15 years. Despite vast sums invested in research they have failed to deliver on these promises. The listed traits are genetically complex. The basic problem is that GM as employed in agriculture is conceptually flawed, crude, imprecise and poorly controlled technology (2-4), that is incapable of generating plants that contain the required multiple, co-ordinately regulated genes that work in an integrated way to respond to environmental challenges.
Contrastingly, crop varieties already exist that are tolerant to drought or salinity, or have improved nitrogen use efficiency either naturally or specifically bred by conventional methods, and augmented in some cases by modern non-GM biotechnology gene mapping (“marker assisted selection”; MAS). For example a novel upland rice variety, Birsa Vikas Dhan 111 (PY 84), has recently been released in Jharkhand bred using backcrossing augmented with MAS with selection for multiple traits for improved root growth and performance under drought conditions (5). These methods are sustainable and safer approaches to crop improvement, less expensive and give significantly higher returns on investment. A fundamental redirection is required in agricultural investment in these areas.
GM has failed to produce crops with improved nitrogen use efficiency whereas conventional breeding and improved farming methods have made significant improvements in this area (6).

iii. “The most compelling case for biotechnology and more specifically biotech crops, is their capability to contribute to increasing crop productivity, conserving biodiversity, reducing the environmental footprint of agriculture, mitigating climate change and reducing greenhouse gases, increasing stability of productivity and production, the improvement of economic, health and social benefits, the cost-effective production of renewable resource-based biofuels and thus provide significant and important multiple and mutual benefits to producers, consumers and global society.”

These claims again are a reiteration of industry promotional material and have no basis in science or the empirical evidence relating to the performance of GM crops.

Productivity—GM has not increased yield potential. Yields from GM crops to date have been no better and in the case of GM soya have been consistently lower. A 2009 report reviewing more than 20 academic studies clearly shows that the cultivation of GM herbicide-tolerant soybeans has not increased yields. Insect-resistant corn, meanwhile, has at best only improved yields marginally. This report found that increase in yields for both crops over the last 13 years was due to traditional breeding or improvements in agricultural practices (7).
Conserving biodiversity—In South America, GM soy has been instrumental in speeding destruction of the Amazon rainforest (8)
Reducing the environmental footprint of agriculture—GM crops have led to vast increases in pesticide use, not decreases and therefore reduction of agricultural pollution cannot be claimed (9).
Mitigating climate change—No-till agriculture using herbicide-tolerant GM seeds does not reduce greenhouse gas emissions. Contrastingly, the high soil carbon sequestration within organic matter inherently produced by agro-ecological farming methods markedly reduces greenhouse gas emissions (10).
Climate change brings sudden, extreme, and unpredictable changes in weather, which requires that a cropping system be flexible, resilient and as genetically diverse as possible. GM technology offers just the opposite.
Stability of productivity and production—is much lower with many of the GM crops commercialised today. Herbicide tolerant GM soya is far more sensitive to heat or drought stress than conventional soya (11,12).
Improvement of economic, health and social benefits—consistently, introduction of GM crops is linked to loss of markets and degradation of rural communities (13-17), and evidence continues to mount regarding the health hazards of GM crops (for example see refs 18-25).
Biofuels—Reports from the World Bank and the United Nations Food and Agriculture Organisation have identified the biofuels boom—not lack of GM foods—as the main cause of the current food crisis (26,27).
The IAASTD report* concludes that GM crops do not increase yield, have little to offer global agriculture and food security and the challenges of poverty, hunger and climate change. Instead it recommends applying low-input agro-ecological farming practices, whose use in the developing world has produced dramatic increases in yields and food security (28). [*The single largest research exercise on global agriculture in history, which was conducted with funding from multiple UN agencies and the World Bank. This report, published as Agriculture at a Crossroads, was produced under the auspices of the International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD). It involved around 400 scientists and twice that number of peer-reviewers. It underwent two rounds of open international peer-review and was ratified overwhelmingly at the intergovernmental plenary in April 2008, including by India.]

iv. “The concerns conveyed by you that the technology may induce instability in genetic level and have adverse health impact is not supported by scientific evidence”.

This is a scientifically indefensible statement because:

GM transformation can produce novel biochemical processes that are unpredictable and for which there is no natural history to assume are safe (2-4).
The GM transformation process is highly mutagenic leading to disruptions to host plant genetic structure and function, which in turn leads to disturbances in the biochemistry of the plant. This can lead to novel toxin and allergen production as well as reduced/altered nutritional quality (2-4).
It is not a question of if there are disturbances to gene function and biochemistry but to what degree they will be present within any given GM plant. For example, the levels of more than 40 proteins are altered significantly in the commercialised GM MON810 corn compared to equivalent non-GM corn, which included production of a new allergenic protein (3).
Numerous animal feeding studies demonstrate negative health impacts of GM feed on kidney, liver, gut, blood cells, blood biochemistry and the immune system (for example see refs 18-25).
Of greatest concern is that studies show negative health effects with GM crops that have already been approved and which have been grown commercially for 10-13 years (18-25). This highlights the inadequacy of the original criteria and set of data on the basis of which marketing approval was and is still being granted.

Note: MON810 has since been banned by many EU countries including France and Germany.

v. “Biotech or GM crops are approved for environmental clearance/commercial release by regulatory authorities after passing through various regulatory stages starting from IBSC-MEC, RCGM and GEAC. The three-tier system is in the hands of the best scientists, technologists, agricultural and environmental experts in the country.... The regulatory system is adequate, reliable, efficient and transparent.... These SOPs are consistent with best international practices”.

This position oversteps the mark and is technically inaccurate as highlighted above and as further evidenced below:

India’s Regulators do not require independent bio-safety tests, but uncritically accept as evidence of safety, research conducted by the company who is applying for commercial clearance of the product. This raises serious questions regarding impartiality and conflicts of interest, which are clearly justified, based on published evidence of bias in the research conducted by industry that is contrary to accepted normal scientific conduct (29).
GM food compositional analysis is superficial and the minimum required to establish “substantial equivalence”, a scientifically conceptually flawed parameter that is virtually meaningless with respect to determining health risk (30).
Experimental design used by the applicant is flawed, almost invariably containing irrelevant “control” non-GM comparator crop varieties, which serve to mask rather than to isolate and reveal the effect of the GM transformation process (20,24).
The biological testing required is not adequate to detect either acute or chronic toxic effects of GM foods. At best, only 90-day feeding studies are required by the government’s SOPs without an obligatory requirement for toxicological and histological evaluation. In order to assess medium and long-term (life-long) health impacts it is necessary to conduct lifetime and multigenerational feeding studies. Only these will reliably determine fertility and chronic health impacts, which is essential because it is the intension that people will be eating GM foods for their whole lifetime (24).
Experimental data is invariably not made publically available for independent scientific scrutiny under the pretext of commercial confidentiality. This has required court action (both in Europe and India) in order to obtain the information needed to assess the quality of the research submitted by industry to be scrutinised by authoritative bio-safety experts. Such independent re-evaluation of submitted industry data has repeatedly found that this research and its interpretation thereof to be flawed, inadequate, biased and thus misleading (20,24,25).
All of the above points are directly relevant to the current safety dossier of Bt brinjal and imply that the Indian government’s current requirements for GM food safety assessment are inadequate and need to be augmented.

vi. “Given that the discovery and use of Bt has completed hundred years in 2002 and Bt technology has a long history of safety, proven efficacy and benefits, Bt brinjal promises to be of great value to Indian farmers. It may be noted that those who stand to gain from wide use of pesticides, often provide misleading information for commercial interests. The GM food assessed and approved through rigorous science based regulatory process has been endorsed by Nobel laureates and leading global scientists”.

This statement ignores research showing:

Bt toxin is a proven potent immunogen raising justifiable concerns that it can give rise to allergic reactions (31,32).
Animals fed diets containing Bt corn have shown signs of direct toxicity (20-25).
Independent re-evaluation of Monsanto’s own research on their Bt corn crops shows negative health effects even in short-term (90-day) animal feeding studies (20,25).
The Mahyco-Monsanto dossier of the raw experimental data of animal feeding studies with Bt brinjal shows highly statistically significant negative signs of toxicity on the functioning of multiple organ systems such as liver, kidney, blood and pancreas in all animals tested (especially rats, rabbits and goats). It is very important to note that these adverse effects were observed after only at most, a 90-day feeding time, which raises serious concerns about the safety of consuming this product over an entire lifetime. Long-term (at least 2-year) animal feeding studies were not done and are stated as not required by the apex Regulator, contrary to the science, which requires these studies to detect chronic slow-onset toxicity and cancer.
There is therefore, no scientific justification for the safety claim of Bt brinjal by India’s regulators, which are based on an uncritical acceptance of the interpretation of the data submitted by Mahyco-Monsanto. This has been heavily criticised by eminent scientists of international standing.

vi. “Biotech crops are environmentally friendly and have contributed significantly to reducing the emission of greenhouse gases from agricultural practice”.

These claims again simply quote material from industry promotional material, which as noted above is not supported by data in published peer review scientific journals:

GM crops are designed to be used in conjunction with synthetic pesticides and fertilisers, which are manufactured from oil and natural gas.
GM crops do not reduce greenhouse gas emissions.
Recent data from the US Department of Agriculture has shown a vast increase in herbicide use since the introduction of GM crops tolerant to the application of these agrochemicals (9).
Therefore, the introduction of GM crops has exacerbated rather than reduced agriculture’s carbon footprint and is clearly unsustainable.

Alternative proven technologies that can reduce the amount of fossil fuel used in farming already exist. This includes methods for reducing fertiliser applications, selecting farm machinery appropriate for each task, managing soil for conservation, limiting irrigation and agro-ecological farming techniques.

Dr Michael Antoniou, King’s College London School of Medicine, UK (michael.antoniou@kcl.ac.uk)
Dr Thomas Bøhn, GenOk - Center for Biosafety, Tromso, Norway (thomas.bohn@uit.no)
Prof Philip L. Bereano, University of Washington, USA (pbereano@u.washington.edu)
Prof Marcello Buiatti, University of Florence, Italy (mbuiattister@gmail.com)
Prof Lawrence Busch, Michigan State University, USA (lbusch@msu.edu)
Prof Joe Cummins, University of Western Ontario, Canada (jcummins@uwo.ca)
Prof Jack A. Heinemann, University of Canterbury, New Zealand (jack.heinemann@canterbury.ac.nz)
Prof Angelika Hilbeck, Swiss Federal Institute of Technology, Zurich (angelika.hilbeck@env.ethz.ch)
Prof Malcolm Hooper, School of Sciences, University of Sunderland, UK (malcolm.hooper@virgin.net)
Prof Carlo Leifert, Newcastle University, UK (c.leifert@ncl.ac.uk)
Prof E R Orskov OBE, Macaulay Institute and Aberdeen University, UK (b.orskov@macaulay.ac.uk)
Prof Gilles-Eric Seralini, University of Caen, France (seralini.gilles-eric@neuf.fr)
Prof David Schubert, Salk Institute for Biological Sciences, California, USA (schubert@salk.edu)
Dr Joël Spiroux de Vendômois, CRIIGEN, Paris, France (jmspiroux@wanadoo.fr)
Prof Brian Wynne, Lancaster University, UK (b.wynne@lancaster.ac.uk)
Prof Louise Vandelac, University of Québec at Montreal, Canada (vandelac.louise@uqam.ca)
Dr Christian Vélot, University Paris-Sud, France (chriatian.velot@igmors.u-psud.fr)

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