The Renuka Choudhury-led Department-related Parliamentary Standing Committee on Science & Technology, Environment & Forests dealt a major blow to the transgenic food crop lobby with its insistence that no genetically modified (GM) crop should be introduced in India unless the bio-safety, socio-economic desirability, and long term effects are evaluated by a participatory, independent and transparent process, with a retrieval and accountability regime.

In its 301^st Report on “Genetically Modified Crops and its Impact on Environment”, submitted to Parliament on 25 August 2017, the Committee said the Ministry of Environment, Forest & Climate Change must examine the impact of GM crops on the environment thoroughly, in consultation with concerned Government agencies, experts, environmentalists, civil society, and other stakeholders so that the nation understands all its probable impacts before taking a call in the matter.      

Astonished that the Ministry’s Genetic Engineering Approval Committee (GEAC) approved commercialisation of GM Mustard when the matter is pending before the Supreme Court of India, the Committee pointed out that GM Mustard is a herbicide-tolerant GMO (genetically modified organism) and there is clear evidence of adverse impacts of such GMOs across the world. Many State Governments oppose its entry even in the form of field trials, leave alone commercial cultivation. Hence, the haste to commercialise GM crops is inexplicable.

The Ministries of Health & Family Welfare; Environment, Forests & Climate Change; and Departments of Biotechnology; Agricultural Research & Education; Animal Husbandry, Dairying & Fisheries; and civil society and subject experts deposed before the Committee.

GMOs are organisms (plants, animals or microorganisms) in which the genetic material (DNA) has been altered in a way that does not occur naturally by mating and/or natural recombination. In this technique, individual genes are transferred from one organism into another, even non-related species (recombinant DNA, rDNA). The offspring are called GM crops or transgenic plants.

Conventionally modified hybrid crops and organisms (cross breeding) are limited to exchanges between the same or very closely related species, and can take a long time to achieve the desired results. Genetic engineering facilitates specific and predictable changes in the transgenic plant, and crosses the species barrier to enable gene transfer across microorganisms, plants and animals.

According to the Secretary, Ministry of Environment, Forest & Climate Change, India framed comprehensive bio-safety rules in 1989 (‘Rules 1989’), and a proposal from the lab stage to the point of clearance takes at least ten years, if not more.

However, a non-official witness informed the Standing Committee (5 January 2017) that the Review Committee on Genetic Manipulation (RCGM) is only a lab (institutional) committee that ensures the lab procedures. But the legal body to ensure that the designs for the lab work are appropriate is the role of Department of Biotechnology. When sued for ultra vires, the Department started to write guidelines. The Bt cotton trials, after the planting of 1998, “when we broke the case”, they (developers) ran to RCGM which sent hand approvals to the people carrying out the trials. But it is not the competent body. Statutory approval on environmental safety and bio-safety in terms of a deliberate release into the environment can only be given by the GEAC.

The witness explained that anything in the environment is called a “deliberate release”. Once it is out even in a small trial, one bee can pick up the pollen and contaminate. Even a one-by-one plot in the open environment will affect the soil; affect the pollinator. Hence all tests have to be done under contained conditions of green houses where one can find out what is happening to the soil, to the toxicity and health through lab research. The witness insisted that the developers /promoters are wrong to claim that they need to do open releases for research; not a single health safety test is done in the field. “It is done in the lab by feeding trials and they have done no human feeding trials and they have done no animal feeding trials”.

Civil society representatives told the Committee that the existing regulatory mechanism is stringent only on paper and the regulation system depends upon data made available to the regulators by the technology developers. The Committee found this to be true, and urged the Central Government, in consultation with State Governments and Union Territories, to ensure that field trials are done in closed environment keeping bio-safety and health safety in mind and in collaboration with agricultural universities to minimise scope for fudging primary data.

Although GM crops were introduced in India in 2002 (Bt Cotton), the Government did not establish the desired protocols until 2011. Questions also arise about the criteria adopted by the Ministry for selection of the members of GEAC, and their credentials. Two of the top three GEAC posts are held by officials of the Ministry of Environment, Forest & Climate Change, and there is a conflict of interest in the appointment of some members. The Committee felt that the GEAC should be headed by an expert from the field of Biotechnology. Moreover, the GEAC should include members of civil society, representatives from States, especially where Bt Cotton has been introduced, and the District Level Committee (DLC), one of the most important bodies to regulate GM crops at the ground level. The DLC should include Members of Parliament of that constituency so that its activity is shared with the public.

Globally, GM crops were introduced in 1996 over an area of 1.7 million hectares, which spread to 179.7 million ha. in 2015. Currently, only 6 countries continue to account for over 90% of all GM crop area (USA 40%, Brazil 23%, Argentina 14%, India 6%, Canada 6%, China 2%). Most developed countries, including most of Europe, Japan, Russia, Israel etc., do not grow GM, as there is increasing evidence of the lack of safety of GM crops and little or no benefits to justify the risks. Indeed, the Government of India would do well to study why these developed countries have rejected this technology.

Bt Cotton

Bt cotton, the only transgenic crop approved for cultivation in India, was introduced mainly for bollworm control. Cotton yields which stood at 189 kg lint per ha. in 2001, increased to 504 kg lint/ha. in 2015. Before the introduction of Bt cotton in 2001, about 13,176 tonnes of insecticides were used for cotton pest control in around 86 lakh hectares at 1.53 kg insecticide per ha. In 2013, insecticide usage was 0.96 kg/ha. at a total usage of 11,598 tonnes used in 127.5 lakh ha.

The Department of Agricultural Research & Education, Ministry of Agriculture & Farmers Welfare, claimed that there has been no report of adverse impact on health and environment due to Bt Cotton cultivation. It claimed that comprehensive bio-safety studies were carried out by ICAR institutions with Bt cotton to study its effects on lab animals such as rabbit, rat and guinea pigs, on broiler chickens (by Central Avian Research Institute, Izatnagar, Bareilly); on fish (by Central Institute of Fisheries Education, Mumbai), on Barbari goats (by Indian Veterinary Research Institute, Izatnagar), on tethering goats (by Central Institute for Cotton Research, Nagpur) on cows (by National Dairy Research Institute, Karnal) and large animals like cow and sheep (by Central Sheep & Wool Research Institute (ICAR), Avikanagar). Claiming that Bt Cotton farmers earned a gross return of Rs 36,831.05/ha., the Department claimed that cotton yields doubled with Bt cotton and that crop failures are not responsible for farmer suicides.

Members of civil society dismissed this rosy picture, saying that cotton production in India has risen mainly due to increase in area under cotton, increase in irrigation, fertile groundnut areas shifting to cotton, etc. The Parliamentary Standing Committee found that the data provided by government agencies mention only production and not average yield in area. In reality, India’s cotton yields increased by 69% between 2000 and 2005, when Bt cotton was less than 6% of total cotton area, and by only 10% from 2005 to 2015 when Bt cotton grew to 94% of total cotton area.

NGOs point out that the production output of GM crops reduces with successive generations of crops - productivity of third generation GM crops is much lower than first generation crops. Hence, the long term benefits of GM crops are doubtful. According to a news item, at the Global Rajasthan Agri-Tech meeting, a Minister in the State Government of Rajasthan stated that Rajasthan already produces 28 to 30 quintal per ha. from normal seed whereas GM mustard reportedly produces only 16 quintal per ha. The oil content in their mustard was 40 to 42 per cent, which was the highest in the country.

Claims that GM technology will reduce dependence on chemical herbicides and pesticides were debunked by members of civil society who pointed out that use of insecticides for sucking pests has increased sharply in value and quantity because sucking pests replaced the bollworm menace when Bt cotton grew from 12% of total cotton area in 2012 to 95% of total cotton area in 2015. Maharashtra’s annual consumption of pesticides (insecticides, weedicides and fungicides) has risen from 2800 lakh tonnes in 2002-03 to 11502 lakh tonnes in 2015-16, an increase of 311%.

The Committee has observed that farmers using GM seeds have lost sovereignty over the seeds as they had to purchase seeds from seed companies every time, even if they were not getting fair price for their produce.

Environmental safety

The Standing Committee found that concerned government agencies have not conducted any study on the impact of Bt Cotton on the environment, bio-diversity, bio-safety, ecosystem, human and animal health. Witnesses informed the Committee that in response to an RTI query, the ICAR - Directorate of Rapeseed-Mustard Research (DRMR) revealed that no trials were conducted and that data received from the technology developer was passed to DRMR to pass on to the GEAC.

Gene flow and the potential of introduced genes to outcross to weedy relatives of crop plant have the potential to create new super weeds. The Department of Agricultural Research & Education, Min of Agri and Farmers Welfare, admitted that a herbicide-tolerant gene may escape through pollen into nearby farms and fields, to another GM or non-GM cultivars or to a wild and weedy relative.

The Committee found many instances of open air field trials of GM crops leading to contamination of non-GM crop. Cross pollination with non-GM could also be with related and wild species (not just intra-specie contamination), hence the possibility of a selection advantage being conferred on the new contaminated species. This could lead to erosion of native diversity and genetic purity. Contamination has an immediate regulatory implication for organic farmers as their organic status is withdrawn.

In the United States, farmers were faced with a tenacious species of glyphosate-resistant weed called Palmer amaranth, or pigweed, which grows three inches a day and can reach seven feet or more, choking out crops, and so sturdy that it can damage harvesting equipment. Hoping to kill the pest before it became that big, farmers began mixing herbicides into the soil. More than 50% of US farms surveyed for a study were infested with glyphosate resistant weeds in 2013. In southeastern USA, a reported 92% of cotton and soybean fields are infested with superweeds due to Roundup Ready HT crops.

GM contamination and creation of superweeds can destroy our traditional crops and organic farming. The Department of Agricultural Research & Education, Ministry of Agriculture and Farmers Welfare, accepted that an herbicide tolerant gene may escape through pollen into nearby farms and fields, to another GM or non-GM cultivars or to a wild and weedy relative. If GM crops are allowed in the midst of other indigenous farming, contamination cannot be stopped.

Regarding insect resistance to GM crops, the Ministry of Environment, Forest & Climate Change admitted that in long term, insects develop tolerance and cannot be managed. The officials submitted some resistance management strategies, which the Committee found impractical for small farms.

The Department of Agricultural Research & Education, Ministry of Agriculture and Farmers Welfare, admitted that commercialisation of transgenic crops may affect biodiversity and contaminate gene pools of endangered plant species, and many endangered plant species are threatened by habitat loss or hybridization with cultivated plants. The potential transfer of a transgene to local flora and its possible subsequent impact on specific plant species must be considered before commercial release of specific transgene.

Regarding concerns about GM genotypes becoming the dominant cultivars, the Ministry of Environment, Forest and Climate Change admitted that adoption of GM technology could result in one or a few GM genotypes becoming the dominant cultivars, leading to reduction of crop diversity in farmers’ fields. The Ministry added that pest management traits embodied in currently commercialised GM crops have caused changes in the use of pesticides that may impact on biodiversity.

Noting the changes in pest and disease ecology, the Committee observed that insects are a vital part of agricultural, horticultural and forest ecosystems and ensure food security as pollinators and natural pest controllers. Heavy and continuous exposure induces the target pest to develop resistance and several studies show how insect resistance to Bt crops have caused changes in pest and disease ecology.

In India’s experience with Bt cotton, secondary pests became major pests. Bollgard I was released in 2002 and Bollgard II in 2006-07 when the pink bollworm showed resistance. However, white fly, mirid bugs and other pests in Bt cotton crop have led to increased use of chemical insecticides. After 15 years of Bt cotton cultivation and expansion to nearly 95% of the cotton cultivation area, India’s pesticide use on cotton has only increased, and will have environmental impacts in terms of contamination of resources and impact on unintended organisms.

The Committee felt that insect resistant GM crops are based on faulty pest management science, where a target pest is sought to be killed through use of an externally sprayed pesticide, or in-planta toxin production wherein if the target pest eats the Bt plant, it gets killed. This kind of pest management creates resistance through natural principles of evolution and mutations, which happened with pink bollworm.

The sudden, lab-based insertion of genes, often across species, triggers unpredictable environmental impacts at multiple levels. Currently 99% of GM crops are modified to express only two traits ‘Herbicide Tolerance’ and ‘Insect Resistance or Pesticide Producing’, both of which are major interventions in living agro-ecosystems, natural ecosystems and human diets. Bt crops continuously express a pesticide which can adversely affect non-target organisms like soil microbes, insects, birds or even mammals, while developing swift resistance in the target insect.

GM technology impacts microbes, soil and water. Bt toxin produced in genetically modified Bt Crops is present in every part of the plant; when parts that have not been harvested decompose, a considerable amount of the toxin could reach the soil. Herbicides also impact soil microorganisms, which are the foundation for agricultural and wild ecosystems, and affect water sources for all species, including humans.

GM crops impact unintended organisms including beneficial organisms like bees and butterflies. A former Secretary of the Department of Biotechnology, Government of India, told the Standing Committee that hardly any research or study on the impact of GM crops was funded by Department of Biotechnology; most research was supported by seed and insecticide companies which cannot be relied upon.

Impact on human health

The Department of Health Research (24 May 2017) submitted that GM products in the international market have all passed safety assessments conducted by national authorities, and  so far, no serious health problem in humans has been shown as a result of the consumption of such foods by the general population in the countries where they have been approved. Several studies abroad were cited to support this contention.

But the Committee pointed to studies showing that an allergen from a food known to be allergenic can be transferred into another food by genetic engineering (Nordlee et at, 1996), while a UK study to assess degradation of transgenic DNA from GM Soya and Maize in human intestinal simulations indicated that some transgenes in GM foods may survive passage through the small intestine (Martin-Orue, 2002).

Regarding scientific studies undertaken to assess the impact of GM food on human health, the Secretary, Department of Health Research, informed the Committee: “In terms of food, it would be very difficult to design a study where you tell one group of people that you have to take only this GM food and, then, you tell another group of people to not take that GM. Then, you have to follow them for many years. So, this type of study has not been done anywhere in the world. It has not been done in India also”. He added that the Indian Council of Medical Research feels that this kind of test on human beings is not practical, and his Department has asked the World Health Organisation to give them some collective evidence from the globe.

The Secretary revealed that the GEAC was preparing a study but it was aborted in 2016 and no further action was taken. The FSSAI, not wanting to duplicate the GEAC effort, moved towards making consumers aware of what they were eating through labelling, and formed a scientific panel for GMO in food. It recommended that labelling should be mandatory for any food product having GE ingredient 5 per cent or more. A decision in this regarded is awaited.

The Committee was astonished to learn that the Department of Health Research had not examined the impact of GM crops on human health, beyond narrating studies done in other countries growing GM crops. Nor has there been any in-house scientific study to study the impact of GM crops on human health.

So how did the Department of Health Research give approval for commercialisation of GM crops in India without thorough study? The Department did not even collaborate with any country growing GM crops for in-depth research. Moreover, only acute and sub-chronic studies have been done and chronic (long term) effects have not been studied on human health anywhere in the world.

Animal health

The Secretary, Department of Animal Husbandry, Dairying and Fisheries opined that although ICAR has undertaken feeding trials of Bt Cotton on Broiler chicken, Sheep (Lamb), Goats, Crossbred multiparous cows karanswiss and Karanfresien (KS & KF) species, the trials were of short duration (one month to a maximum of four months). Hence, long term feeding trials in all species of livestock, including fish, are required.

The Committee was unimpressed by the duration and manner in which ICAR conducted its trials to study the impact of GM crops on animal health. The trials were conducted on a very small number of animals whereas they should have been conducted on a large number of animals and for at least 2 or 3 generations. The ICAR’s methodology for conducting the trials was also questionable. The Standing Committee suggested that the Department of Animal Husbandry, Dairying and Fisheries prepare guidelines for the purpose and conduct trials under its supervision, to establish the veracity of the claims.

Even after 15 years of introduction of GM crop in India, the Department of Animal Husbandry, Dairying and Fisheries has not scientifically proved whether GM crops have any adverse impact on the health of an animal. Paradoxically, when the Department itself feels that long term feeding trials in all species of livestock, including fish, are necessary, how did it conclude that GM crop has no impact on animal health? These scientific studies are imperative.

Several extant several animal studies indicate serious health risks associated with GM food, including infertility, immune problems, accelerated aging, insulin regulation, and changes in major organs and the gastrointestinal system. The Committee has urged the Ministry of Environment, Forest & Climate Change in consultation with ICAR and the Department of Animal Husbandry, Dairying & Fisheries, to organise serious studies on these issues.

In conclusion, the Indian agricultural scientific establishment across the country has failed to conduct a single credible investigation over the past 15 years on the impact of GM crop on soil fertility, on animals feeding on crop residue, and on human beings on whom GM food crops are being sought to be unleashed with the force of a hurricane.

The Renuka Choudhury-led Department-related Parliamentary Standing Committee on Science & Technology, Environment & Forests has performed a sterling service to the nation, vindicating the concerns of thousands of farmers, independent scientists, and concerned citizens regarding this toxic technology that has already claimed the lives of over three lakh Indian farmers with just one crop – Bt Cotton. One shudders to think of the impact of multiple GM food crops growing simultaneously in our fields.

This article was written for the forthcoming issue of the Swadeshi Jagran Manch Patrika