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Moderated conference on GMOs in the pipeline, hosted by the FAO Biotechnology Forum in 2012

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Biotech-Mod2 <[log in to unmask]>
Thu, 29 Nov 2012 17:45:08 +0100
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This is Aruna Rodrigues again in my third message on this subject, bringing various aspects of the independent assessment of the Mahyco-Monsanto dossier to the notice of this FAO email conference. These assessments which contributed to the moratorium on Bt brinjal will affect every GMO in the pipeline unless fully addressed in a transparent way to the satisfaction of civil society and the independent scientific community. I acknowledge the important contribution of Dr John Samuels (Message 60). Thank you indeed for your abundant clarification on the factual position regarding India's diversity in brinjal and its certain contamination if Bt brinjal were commercialised. In fact, India with 2500 varieties of brinjal and 29 wild species is the "centre of the world's biological diversity in brinjal" (Andow). Many will be interested in his professional assessment of the raw data of the dossier (relevant chapters) published in "Event EE-1: Bt brinjal: The scope and adequacy of the GEAC environmental risk assessment". Andow is acknowledged as one of the leading experts in the environmental risk assessment (ERA) of GM crops. 

In "Bt brinjal: The scope and adequacy of the GEAC environmental risk assessment", he states: "most of the possible environmental risks of Bt brinjal have not been adequately evaluated; this includes risks to local varieties of brinjal and wild relatives, risks to biological diversity, and risk of resistance evolution in BFSB". Briefly, "--- EC-II relied on dubious scientific assumptions, did not focus on realistic environmental concerns, inadequately evaluated some important environmental concerns, and ignored other real environmental concerns". 

Some of the more important findings include:   

EE-1 is a very old transgene, a view shared by Heinemann and Seralini, who also evaluated the raw data of the dossier; and while it may not be exactly "transgene dumping," India would do better to wait for a more efficacious transgene before seriously considering approval of Bt brinjal. Again, Andow with other scientists prove that the Dossier does not comply with the scientific aspects of transgene characterisation described in the 'Guideline for the Conduct of Food Safety Assessment of Foods Derived from Recombinant-DNA Plants' (Codex Alimentarius, 2003, CAC/GL 45-2003), a serious deficiency. The EC-II (The regulators' Expert Committee on Bt brinjal) not only failed to pick this up but wrongly affirmed that the dossier was compliant with the Codex Alimentarius.

There are six kinds of potential adverse environmental effects that Bt brinjal could have on biological diversity. These are: (i) increased secondary pests, either through direct enhancement or indirectly through the reduction of natural enemy controls or other means; (ii) reduction in soil quality or health, adversely affecting crop production in either the short or long term; (iii) reduced value of non-crop economic activities (such as honey production or wild food harvesting); (iv) reduced cultural value by affecting a cultural icon or a species of cultural significance (e.g., Monarch butterfly in the United States); (v) increased conservation concern, such as an adverse effect on an endangered species; and (vi) reduced environmental quality through an effect on an ecosystem service such as pollination. EC-II also draws conclusions about the absence of environmental risk in the absence of supporting data. For example, EC-II (page 41) concludes "there is no accumulation of the [Bt] protein in the soil associated with production of Bt brinjal," but this is not supported by any scientific data. 

The evolution of resistance in the Brinjal fruit and shoot borer (BFSB) to overcome Bt brinjal is a real risk that must be managed. EC-II does not acknowledge this risk, and the Dossier does not propose effective means to manage it. The likelihood of resistance evolving quickly is high. Without any management of resistance evolution, Bt brinjal is projected to fail in 4-12 years. Effective use of 20% non-Bt refuges can extend this time by 25% or more. The reason for this high risk is that EE-1 is a "low dose" event, by virtue of the relatively low control efficacy. Resistance risk would be substantially reduced if EE-1 Bt brinjal were never released commercially and India were to wait for a "high-dose" Bt brinjal. Resistance to EE-1 would be a stepping stone for more rapid resistance in any subsequent, improved event. 

Nearly all brinjal farmers in India are small-scale resource-poor farmers, who farm <1ha for all of their crops (Department of economics and statistics, 2008). They grow brinjal in small (~65 m2) plots, and sell to local village and town markets. For these farmers, brinjal production is essential for their overall economic security and well-being (Agricultural and Processed Food Products Export Development Authority, 2009).

EE-1 Bt brinjal is proposed as a hybrid, and is unlikely to fit well in the small-scale production systems relying on open-pollinated varieties (OPVs) of brinjal. For small-scale resource-poor farmers, brinjal is critical for creating economic security. Farmers are expected to retain only 10% of the increase in profitability from Bt brinjal, but are expected to retain 63% of the increase from brinjal integrated pest management (IPM). 

BFSB causes significant economic damage to brinjal throughout India for all farmers --averaging about 30% yield loss (a comparison of yield with pest management versus no pest management). Farmers are prone to overestimate the loss to BFSB, precipitating an over-use of insecticides significantly beyond that justified by the actual economic significance of BFSB. Real losses from BFSB are higher for large-scale commercial producers than for small-scale resource-poor producers because of the way damaged fruit can be used by the small-scale resource-poor farmers. EC-II vastly over-estimated losses to BFSB. 

Insecticide use can be reduced substantially using IPM. Useful alternative production systems for control of BFSB are being tested, actively used, and promoted in India: IPM, traditional pest management, organic production and other locally-derived methods that reduce costs associated with external inputs.  

Andow lists some 37 studies of which perhaps 1 has been conducted and reported to a satisfactory level by Monsanto 

Aruna Rodrigues
Sunray Harvesters,
Bungalow 69
Mhow - 453441
M.P. India
e-mail: arunarod (at) gmail.com

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