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Failure of the GMO's in India

DR. VANDANA SHIVA & AFSAR H JAFRI 31may03

Introduction:

On 25th April 2003 the Genetic Engineering Approval Committee (GEAC) under the Ministry of Environment and Forests (MoEF), Government of India, denied the commercial clearance to Monsanto's Bt. cotton for the northern Indian states. This vindicates the apprehensions of the Research Foundation for Science, Technology and Ecology (RFSTE) and others who have warned the government about the severe repercussions to the Indian farmers and their livelihood if further clearance to the Bt. cotton has been allowed in view of its large scale failure in first year of its commercial planting in approx. 40,000 hectares.

This is a consecutive third victory for the people for their food security and food safety after the denial to ProAgro - Bayer for the commercial clearance to GE mustard as well as the rejection of import of 10,000 million tonnes of corn-soya blend suspected of containing Bt. corn “Starlink” as food aid by two NGOs – CARE India and Catholic Relief Services. This was achieved despite the massive media campaign in favor of transgenic mustard by ProAgro - Bayer as well as the massive pressure from USAID and the US Embassy who tried hard to subvert the GEAC's decision making process through the intervention of the Prime Minister's Office (PMO) by seeking an special audience in the official meeting of the GEAC.

This decision of the GEAC is welcomed by RFSTE and others because GMO's or no GMO's, Monsanto seeds are spreading disaster and recently Monsanto hybrid maize seeds has failed in more than 350,000 acres in about 11 districts of north Bihar. Farmers of these districts are in deep distress because Monsanto's sold its 700 metric tonnes of “Cargill hybrid 900M” maize seeds in the flood prone areas of north Bihar. Similarly the water intensive hybrid maize seeds were introduced in the drought prone regions of Rajasthan which has put extra burden of chemical inputs and water on the Rajasthani farmers. Though Monsanto India Ltd., a subsidiary of the US multinational, has been barred from selling seeds in Bihar for allegedly marketing substandard products, the intensive campaign by RFTSE in Udaipur forced the local NGO Karamsheel to snap their ties with Monsanto for spreading its Hamsafar programme for the propagation of maize seeds.

Bt. cotton failed in India

The GEAC denial to commercialize Bt cotton in the northern states comes after the massive failure of Bt cotton in the southern states of India. The GEAC, which, in spite of being aware of ecological hazards and GM corporations' false claims of reduced pesticide use and higher yields, had given permission to Monsanto-Mahyco to commercialise Bt. cotton in the southern states on 26th March 2002, had asked for a year's additional trials in the north. Though the official version about the Bt. trials by Indian Council of Agricultural Research Punjab (ICAR) as well Monsanto-Mahyco is not available, the independent studies by citizen group found that the Punjab farmers have rejected the first ever genetically modified commercial cotton hybrid seed, Bt Cotton, due to its poor harvest. Malwa, a cotton rich area, in southern Punjab is highly dependent on this cash crop, but successive failures have left farmers in the lurch. Though the Punjab Agriculture University was against the sowing of Bt Cotton seeds, several farmers smuggled Bt Cotton seeds from Gujarat hoping better results. The yield was, however, lower than claimed. The Daula village Sarpanch Mr. Darshan Singh said: "... We had to spray chemicals four to five times on Bt Cotton. The crops were attacked by various pests, specially the American Bollworm. The Bt Cotton yield was lower than that of the local varieties, which are more profitable."

Moreover, the Bt Cotton seeds are costlier. Farmers who sowed Bt Cotton got an yield of 250 kg a hectare while the local variety yielded almost double. Mr. Baljinder Singh, research scientist with Monsanto India Ltd, said: "Our aim is to reduce the cultivation cost". But farmers are unconvinced.

Research Foundation for Science, Technology and Ecology conducted a study in the states of Maharashtra, Madhya Pradesh, Andhra Pradesh and Karnataka which showed that not only did Monsanto's cotton not protect the plants from the American Bollworm, but there was a increase of 250-300% in attacks by non-target pests like Jassids, aphids, white fly and thrips. In addition, the Bt plants became prey to fungal diseases like root rot disease or fusarium. The Bt. cotton varieties gave very low yields. Even the staple lengths of whatever little cotton was produced were so short that the cotton fetched a very low price in the cotton market.

The failure of Bt. cotton has prompted the Agricultural Minister of Andhra Pradesh, Mr. V. S. Rao, to state that “overall information is that the farmers have not experienced very positive and encouraging results” with Bt cotton. The state government also said that farmers are not getting the yields they were promised and the poor quality of the crop also fetches a lower price in the market.

Even the Joint Director of Agriculture, Mehboobnagar, Andhra Pradesh, in a letter, on the performance of Bt cotton in Mahboobnagar District, to the Commissioner and Director of Agriculture of Andhra Pradesh, has recorded that Bt cotton failed in his district on the following counts:

1. Drying and falling of squares without boll formation, 2. Reduced boll formation, 3. Small sized bolls, 4. Very short staple length, 5. Very little resistance to boll worm, and requiring 2-3 sprays for control of boll worm, 6. Not resistant to dry spells, 7. Low yields (only 2 -3 quintals for MECH 162), 8. Low market value, 9. Cost-benefit ratio not on par with non-Bt cotton.

The Joint Director of Agriculture, Government of Andhra Pradesh, Mr. M. Laxman Rao, has stated regarding the experience of Andhra farmers with Bt cotton, “the seed did not have the impact as it was propagated. It has failed to show good results in the yield as well as in pest control.” Other Divisional Assistant Directors of the department observed high pest incidence in the Bollgard seed than in other varieties. One of them commented, “Going by the hi-pitch propaganda, the Bt seed should have much resistance, but the ground reality is in contrary”.

Though the government of Andhra Pradesh declared the Bt. cotton as failed and even decided to compensate the affected farmers, the Minister of Environment and Forests, Mr. T. R. Balu gave an statement in the Parliament that the Bt. cotton had shown a 'satisfactory' performance. And this statement is based on the report of the GEAC members on their two days visit to a few Bt. farms in Andhra Pradesh. This tour of the GEAC members was guided by Monsanto and Mahyco.

The Greenpeace investigation, where the team visited the same farmers as the GEAC team, stated categorically that “the statement of the Minister of Environment and Forests, Mr. T. R. Balu in the Rajya Sabha on December 16, 2002 is a gross misrepresentation of farmers' experiences. The government has lied to the nation on Bt cotton performance.

Greenpeace study also revealed the following:

The leading agricultural scientists, experts and academicians in India have also acknowledged the failure of Bt. cotton.

Bt cotton is a hoax here. If there is a genetic mechanism to resist the pest, it should not have attacked at such a scale. The experiment has completely failed. -Dr. M.Y. Parmar, Dean, Anandwan College of Agriculture, Punjabrao Deshmukh Agricultural University, Maharashtra.

(We expected the) new variety of a crop would give some relief regarding bollworms. There was no truth in the propaganda that Bt cotton was a non-spray. - Dr. C.D. Mayee, Director, Central Institute of Cotton Research (CICR), Nagpur.

Bt cotton products could have long term environmental and health effects. It is essential that the Health Ministry was involved more in such decisions. - Dr. C.P. Thakur, Former Health Minister, Union of India.

On the basis of the field trials by Monsanto and Mahyco, GEAC had, in its 32nd meeting dated 26.03.2002 given conditional clearance for three years from April 2002 to March 2005, for commercial release of three out of four of Mahyco's transgenic hybrids of the cotton. The GEAC has given approval for commercial cultivation of Mech-12, Mech-162 and Mech-184 varieties of the transgenic hybrids of the cotton to Mahyco.

The clearance to commercialise Bt. cotton was granted by GEAC on grounds that it had been fully tested in Indian condition, that it does not require pesticide sprays, that it gives higher yield and farmers have higher incomes. All the claims on the basis of which the clearance was granted have been proven false by the total failure of Bt. cotton in states where it was cleared for planting including Andhra Pradesh, Maharashtra and Madhya Pradesh.

However, while claiming on the one hand that the Bt varieties had been fully tested for six years, the GEAC tacitly appears to have accepted that the evidence is not complete.

The GEAC's conditions for approval include the following:

It is submitted that, in addition to the GEAC's own tacit acceptance of the incompleteness of the Monsanto-Mahyco Indian trials, by 2002 there was enough evidence from research by independent researchers, and actual experience of farmers worldwide to conclude that the Indian trials by Monsanto and Mahyco provided “inadequate information” and to “err on the side of caution and prevent activities that may cause serious or irreparable harm” to the environment, human health and farmers' income.

The independent study conducted by RFSTE in late October 2002 in the states of Andhra Pradesh, Maharashtra, Madhya Pradesh and Karnataka found that:

False Claim of Pesticide free cultivation:

Besides RFSTE, different other institutions and experts conducted their independent studies on the performance of the Bt. cotton. A study conducted by Dr Abdul Qayoom, formerly Joint Director, Agriculture, Government of Andhra Pradesh, Mr. Sakkari Kiran, an agricultural scientist and Dr G V Ramanjaneyaloo, among 21 individual farmers and farmers groups in 11 villages of Warangal District found that pesticide use showed only a marginal difference. While farmers have sprayed 4-6 times this season on Bt cotton, they have sprayed only 5-7 times on non-Bt. In this manner, Bt has been sprayed only once less.

Mahyco has said in its promotional cassette (given along with Bt. seeds) that if Economic Threshold Limit (ETL) level in Bt. Cotton, defined as 20 bollworms in one acre, is crossed, farmers have to spray to control pests. Their own promotional material proves that they knew their claim of pest resistance was false and they made this false claim only to get commercial clearance on false grounds to misguide farmers and to make illegitimate profit at the cost of innocent farmers.

Bt. cotton has also been attacked by wilt (fusarium oxysporum fsp. Vasinfectum) and root-rot (Rhizoctoria bactaticola) in Maharashtra, Andhra Pradesh, Madhya Pradesh and Karnataka. This has also been confirmed by the Dr. S.W. Khodke, Asst. Professor and Plant Pathologist at the Zonal Agriculture Research Center (ZARC) in Yawatmal, Mr. A.M. Ingle, Agriculture Development Officer (ADO) of Yawatmal as well as Dr. Jalapathi Rao, Principal Scientists and Head of the Agriculture Research Centre in Warangal. These diseases were limited to Bt. cotton varieties.

Bt cotton does not give higher yields

Bt. cotton was sold with the claim that it would give 15 quintals of yield per acre. However yields have been as low as 20 kgs in one acre. The average total yield per acre expected by Bt. cotton growers was 3 – 4 quintals per acre in Maharashtra and Andhra Pradesh.

In Madhya Pradesh, in Badwani, Khargaon, Dhar and Khandwa districts, almost half the 42 farmers visited reported that their crop had failed. Khargaon farmers faced total crop failure. In the other districts only one expected a yield of 12.5 quintals, the average yield expected by the others was 4.01 quintals, as compared to the 15 quintals promised by Monsanto-Mahyco.

In Karnataka, 15 of the 40 farmers visited in Bellary, Sirippupa and Haveri/ Dharwad districts, expected a total failure of their crops. The average yield expected by remaining farmers was 3.82 quintals per ha. Even the CICR is expecting a maximum yield of 4 quintals per acre in 10 acres of Bt. cotton being grown under Institute Village Linkage Programme (IVLP) in Maharashtra.

In most of the fields visited in the month of October, the Bt. cotton plants were in a stage of maturity with leaves turning red before dropping off. The non-Bt. on fringes looked far healthier, taller and wee more green than Bt. plants. The early maturity of the Bt. crop could be caused by the toxin gene because it could not be due to environmental conditions because non Bt. varieties and other hybrid cotton plants were healthy and lush green in October while Bt. cotton plants had started reddening.

In the Pattipakkam village in Shampet Mandel in Warangal, Mr. Venkat Reddy Bt. crop got completely matured in October and he removed his Bt. plants to grow another crop because he lost all hope of getting any further yield. It means that unlike other hybrid cotton, which yields upto March (and this year yield are expected to be more than 10 quintals), Bt. cotton farmers could not get any yield after November-December 2002.

This maturity factor could be caused by genetic engineering or genetic engineering processes through which the Bt. cotton has been developed. This could also be because of the toxic gene in the Bt. cotton plants.

The Bt. cotton disappointed its growers and the yield was much below their expectation.

Bt cotton does not increase farmers' income

The failure of Bt. cotton has completely exposed the companies who are trying to market their genetically engineered seeds at the cost of the farmers' live and livelihood and calls into question the GEAC clearance given to an unreliable, untested hazardous variety. The failure/ drastically reduced yield of Bt. cotton has devastated Bt cotton farmers, who are faced with penury. Mr. Mala Rao Krishna Rao Thakre of the Boath village in Yawatmal suffered a major heart attack when he found his 27 acres of Bt. cotton completely devastated by diseases and pests.

The incomes of Bt cotton farmers suffered not just because of low yields, but also because of staple size. The Monsanto-Mahyco claimed a staple size ranging from 26-29 mm, in actuality, it is hardly 15-20 mm, and fetched the rate of a short staple cotton (around Rs. 1500 per quintal), while the normal rate offered for best quality cotton is Rs. 2000 to 2200 per quintal. One of the buyers in the Warangal Cotton Market, Mr. Sarangpani of the K.N.R. Enterprises said that Bt. cotton staples are only 6-7 mm long while the staples of good quality cotton is 32 mm.

The failure of Bt. cotton can create a Warangal of December 1997 when hundreds of cotton farmers committed suicides due to the failure of their crops.

Some of the Bt. growers have received very poor yield. For example Mr. Purshotam Kushalrao Kakre of Aloda village has got 86 kilograms in 1 acre, Mr. Pandit Rao Rathod has got 40 kilograms from three acres, Mr. Rai Singh Seva Rathod of Jamwari village in Yawatmal has not picked anything from Bt. cotton till end of October, Mr. Sharad Choudhury of Wani has only received 8 quintals in 7 acres while Mr. Ganeshjee Gupta of the same tehsil has got only 63 kilo in one acre. Each Bt. farmers have spent thousands of rupees on its cultivation.

In comparison to Bt., some of the non-Bt. hybrid farmers have used a maximum of 4 sprays while many are not using sprays at all because they do not get any result. The non Bt seed cost is only Rs. 350 to Rs. 450 per packet (450 grams). The irrigation cost was more or less same in Bt. or non Bt. field. However Bt Cotton requires moisture and therefore some of the farmers had to irrigate their Bt. field more than non Bt. Those who grew indigenous varieties of cotton (desi cotton) e.g. AKA - 5 and AKA – 7, the in put cost was nil. This cotton was found at the Zonal Agriculture Research Centre (ZARC) in Yawatmal.

Moreover the staple size of Mahyco's Bt. cotton varieties is hardly 15-20 mm, and it would fetch the rate of a short staple cotton which could be around Rs. 1500 per quintal, while the normal rate offered for best quality cotton is Rs. 2000 to 2200 per quintal. One of the buyers in the Warangal Cotton Market, Mr. Sarangpani of the K.N.R. Enterprises said that Bt. cotton staples are only 6-7 mm long while the staples of good quality cotton is 32 mm and varieties like Banni, Brahma, RCH-2, Mech-1 cotton staples are of good quality which also get the highest market price.

Cost Benefit Analysis of Bt. cotton vs other cotton in one acre in Maharashtra and Andhra Pradesh
Bt. Cotton Non-Bt. Hybrids AKA 5 & 7 (Growing in ZARC, Yawatmal)
A. Expenditure on Inputs (Seeds, fertilizers, pesticides, irrigation) Rs. 8100/- Rs. 5750/- Zero Expenditure
B. Expected Total Yield 4 quintals 10 quintals 5 quintals
C. Output Value Rs. 6600 (Rs. 1650/- qtl) Rs. 16500 (Rs. 1650/- qt) Rs. 8250 (Rs. 1650/- qtl)
C – A Loss of Rs. 1500/ acre Profit of Rs. 10750/-acre Profit of Rs. 8250/- acre

Cost Benefit Analysis of Bt. cotton vs other cotton in one acre in Madhya Pradesh
Bt. Cotton Non-Bt. varieties
A. Expenditure on Inputs (Seeds, fertilizers, pesticides, irrigation, labour) Rs. 6675/- Rs. 7005/-
B. Expected Total Yield 4.01 quintals 7.05 quintals
C. Output Value Rs. 7218 (Rs. 1800/- quintal) Rs. 13320 (Rs. 1800/- per quintal)
C – A Income of Rs. 543/- acre Profit of Rs. 6315/- acre

Cost Benefit Analysis of Bt. cotton vs other cotton in one acre in Karnataka
Bt. Cotton Non-Bt. varieties
A. Expenditure on Inputs (Seeds, fertilizers, pesticides, irrigation, labour) Rs. 8925/- Rs. 10250/-
B. Expected Total Yield 3.82 quintals 7 quintals
C. Output Value Rs. 7640 (Rs. 2000/- quintal) Rs. 14000 (Rs. 2000/- per quintal)
C – A Loss of Rs. 1285/ acre Profit of Rs. 3750/ acre

The only paper that bolsters Monsanto's claim to Bollgard is a study by Matin Qaim (University of Bonn's Centre for Development Research) and David Zilberman (Professor at the University of California in Berkeley), published in the journal Science and saying that the Indian experience with Bt is positive and yields have increased by 80%. Qaim and Zilberman have used data provided by Mahyco-Monsanto, which is still not in the public domain, to substantiate their claims. These claims have been rebutted by internationally renowned scientists and experts. Shanthu Shantharam, a scientist who has worked as a regulator with the USDA and is an authority on “pest-resistant genes in managed ecosystems' states that such increase cannot be attributed to a single Bt gene, calling it a 'preposterous idea'.

The study is also rebutted by Dr. Suman Sahai of Gene Campaign, who said that this paper extolling the outstanding performance of Bt cotton is based exclusively on data supplied by the company that owns the Bt cotton, Mahyco-Monsanto. Bt cotton, the first GM crop to be grown in India was given approval for commercial cultivation just last year in March, so this is the first harvest of the Bt crop. The data presented in this sensational paper are however not based on this harvest, as one would expect but on a few selected trials plot belonging to the company. No data from farmers' fields or from the All India Coordinated Variety trials conducted by Indian Council of Agricultural Research (ICAR) have been included.

This amounts to manipulating data since trial plots are experimental fields with optimal conditions. The performance in real fields under normal cultivation conditions is very different. Nowhere near these kinds of results are seen anywhere else in the world where Bt. cotton is being cultivated. In the US and China, 10 to 15 percent yield increase is recorded. These sensational data have led to a spate of media reports about the 'superlative' performance of Bt. cotton both nationally and internationally. Such misleading reports can end up influencing policy makers in a direction that could ultimately be detrimental to farmers, and therefore must be publicly denounced.

Farmers, who according to GEAC's earlier statements that they would earn an additional income of Rs. 10,000 per acre with Bt cotton, actually lost more than this amount by planting Bt varieties. Not only is the cost of the seed higher than of non-Bt varieties, Monsanto's varieties need more fertilizers and water.

The Indian experience with Bt cotton shows that it neither gives higher yields nor does it increase farmers' incomes. This finding is in keeping with the USDA report on the economics of GM crops.

Yield drag in transgenic plants, affecting farmers' incomes have been reported in numerous other studies. A study based on 8,200 trials of soya varieties in US universities in 1998 reports yield drags between top Roundup Ready varieties and top conventional varieties averaging 6.7%. In some areas, best conventional varieties produced yields on average 10% higher than RR varieties sold by the same seed companies [Benbrook, C.M. (1999), Evidence of the magnitude and consequences of the Roundup Ready soybean yield drag from university-based varietal trials in 1998; AgBioTech InfoNet Technical Paper Number 1].

In May 2000, results of a two-year study by Nebraska University's Institute of Agriculture and Natural Resources showed RR soya yielded 6% less than their closest non-GM relatives and 11% less than high-yielding non-GM varieties. The yield penalty was attributed to the gene insertion process [University of Nebraska (2000) #145, Research shows Roundup Ready soybeans yield less; IANR News Service].

The University of Wisconsin found GM soya yields from the 1998 harvest lower than non-modified varieties in over 80% of cases in trials across nine US states.

A review of 40 trials of soya varieties in the north central region of the US in 1999 found a mean 4% yield drag in RR soya [Oplinger, E.S., M.J. Martinka, and K.A. Schmitz (1999), Performance of transgenetic soybeans-Northern US, presented to the ASTA Meetings, Chicago, cited in Clark, E.A. (1999) '10 reasons why farmers should think twice before growing GE crops].

In the UK, reports of crop trials from the National Institute of Agricultural Botany show yields from GM winter oilseed rape and sugar beet 5-8% less than high-yielding conventional varieties [Reported in Farmers Weekly (UK), 4th December 1998].

In summary, yield losses, not yield gains, are more commonly associated with transgenic crops compared to best available conventionally-bred cultivars and hybrids [Clark, E.A. (1999) '10 reasons why farmers should think twice before growing GE crops].

Yield drag in soya is associated with problems in root development, nodulation and nitrogen fixation, particularly in drought or infertile conditions, as the bacterial symbiont responsible for nitrogen fixation is sensitive to both Roundup and drought [Benbrook, C.M. (2001), Troubled times amid commercial success for Roundup Ready soybeans: glyphosate efficacy is slipping and unstable transgene expression erodes plant defenses and yields; AgBioTech InfoNet Technical Paper Number 4]. Furthermore, there is a metabolic cost to expressing herbicide-resistance or the Bt-endotoxin. For example, levels of proteins responsible for plant defence responses are depressed following Roundup application. Although these are eventually restored to normal, pathogens quickly infect the plants in sub-optimal growing conditions. This forces a diversion of energy to repair damage, resulting in an essentially irreversible tax on yields.

University of Minnesota economist Vernon W. Ruttan sums it up: "Thus far, biotechnology has not raised the yield potential of crops" ['Economist: Biotech has not made impact yet'; Farm Progress, 21 November 2000].

The present international scientific knowledge, information and experience on GE crops and on crops engineered to contain the Bt gene in particular, emphasizes the unpredictable, hazardous and unforeseen changes that can take place in the characteristics and behaviour of that organism itself; the unforeseen effects that it can have on other species if the gene is transferred to other species; the possibility of the creation and emergence of weed like characteristics and the creation of superweeds; the kind of potentially harmful impact that it can have on the environment and the ecology in general and in particular, the build-up of resistance in the target pest, Helicoverpa armigera (American bollworm) and other pests, which in cotton in India include Pectinomorpha gossypiella (pink boll worm), Spodoptera litura (army worm) and Bemisia tabaci (white fly).

The varieties of genetically engineered Bt cotton in India contain the Cry1Ac gene, of which Bharathan has stated “Cry1Ac is not the best gene for Indian conditions' (Bharathan, G 2000, Bt-cotton in India: anatomy of a controversy; Current Science 79:1067-1075). It is a known fact that H. armigera and Spodoptera, are less susceptible to Bt toxin than is Heliothis, the major US pest against which Bollgard gene was developed in the first place. Susceptibility is highly variable [Gujar, G. T., Kumari, A., Kalia, V., and Chandrashekar, K.; 2000; Spatial and temporal variation in susceptibility of the American bollworm, Helicoverpa armigera (Huebner) to Bacillus thuringiensis var. kurstaki in India; Current Science 78:995-1001] and resistance evolves rapidly in the laboratory [Kranthi, K. R., Kranthi, S., Alis, S., and Banerjee, S. K.; 2000; Resistance to CrylAc delta-endotoxin of Bacillus thuringiensis in a laboratory selected strain of Helicoverpa armigera (Huebner). Current Science 78:1001-1004.].

Buildup of resistance in Helicoverpa armigera (American Bollworm) to Bt

Studies since the mid-90s onwards have shown that the target pest Helicoverpa armigera is increasingly becoming resistant to genetically engineered Bt varieties of corn and cotton.

Bt cotton extensively grown in Arizona has shown that the decrease in non-Bt refuges increases chances of evolution of resistance in Pectinomorpha, a major pest of cotton in both Arizona and India [Genetically modified pest protected plants: science and regulation; 2000; National Research Council, National Academy Press, Washington, DC. USA].

The same study has shown that low toxin levels late in the season lead to relatively low susceptibility, which, combined with high intraspecific variation, increase chances of evolution of resistance in Helicoverpa. [Genetically modified Pest protected plants: science and regulation, 2000, National Research Council, National Academy Press. Washington, DC. USA.]

After their study on Heliothis virescens Gahan, Gould and Heckel concluded that it is now evident that any other allele with a molecular lesion somewhere in HevCaLP preventing it from functioning as a lethal target would give the same result, because r1 is a null allele. They cautioned that screening solely for the Hel-1 insert detects r1 but may underestimate the total frequency of resistance alleles in the field, where there is a high potential of the high-dose/refuge strategy failing. At the very least, preservation of DNA samples should accompany existing bioassay-based monitoring programs.

The 1998 study by Shen-Jin Liang et al from the Department of Plant Protection, Nanjing Agriculture University in China confirms the early build up of such resistance. Susceptible bioassay base line and discrimination concentrations were determined for Bacillus thuringiensis (Bt) on a susceptible (SUS1) strain of Helicoverpa armigera using the diet infection method. Susceptibilities to commercial Bt subsp. kurstaki formulations in newly-hatched larvae of H. armigera collected from 6 counties of 5 provinces in China were tested in 1995. Results indicated that populations of H. armigera from Yanggu (Shadong), Handan (Hebei), Xinxian (Henan), Xiaoxian (Anhui) and Fengxian (Jiangsu) showed clear resistance to Bt. The LC50s increased slightly but the slope (b) decreased significantly compared with that of the susceptible strain. However, the Dongtai population (Jiangsu) remained susceptible. Resistance to Bt was diagnosed for the first time. The effects of transgenic cotton lines expressing Bt toxin on various populations of H. armigera using the leaf bioassay were also determined. The average mortality of newly hatched larvae of H. armigera (Yanggu and Xinxiang) with early resistance to Bt declined significantly (16-29%) compared with those of the susceptible strain. It is suggested that populations of H. armigera from Yanggu and Xinxiang were resistant to Bt and transgenic cotton expressing Bt toxin.

Studies in China have been conducted on the impact of Monsanto's Bt cotton due to its introduction and popularization since 1997, Bt cotton plantings have had a very fast growth in area. In 2000, Bt cotton was grown on up to 1 million hectares, accounting for 30% of cotton production in China. It is estimated that the area planted to Bt cotton has increased to 1.5 million hectares in 2001, on 35% of the total cotton area. Monsanto's Bt cotton accounts for approximately two thirds of the Bt cotton grown, while the several domestically developed Bt cotton varieties account for the remaining one third.

Adverse Environmental Impacts of Bt cotton

Research conducted during the past few years at four domestic academic institutions shows that Bt cotton is effective in controlling the primary pest of cotton - bollworm (Helicoverpa armigera Hbner) - especially in seedling stage of cotton. However, laboratory experiments and field research also demonstrate that there are adverse environmental impacts associated with the cultivation of Bt cotton. These impacts are summarized below.

i. Although in the Chinese studies there are no significant impacts on predatory natural enemies associated with Bt cotton, there are associated adverse impacts on parasitic natural enemies of cotton bollworm. In Bt cotton fields, researchers have shown a decrease in the ratios of parasitization and eclosion and reduction in the weights of cocoon and adult. Consequently, the populations of parasitic natural enemies in Bt cotton fields are significantly reduced.

ii. Bt cotton is not effective in controlling many secondary pests, especially sucking pests. Field experiments showed that the populations of secondary pests such as cotton aphids, cotton spider mites, thrips, lygus bugs, cotton whitefly, cotton leaf hopper and beet armyworm increased in Bt cotton fields after the target pest - bollworm - had been controlled. Some pests replaced bollworm as primary pests and damaged cotton growth.

iii. The diversity indices of the insect community, the pest sub-community and the pest-natural enemies sub-community, as well as the evenness index of Bt cotton fields are all lower than those in conventional cotton fields. However, the pest dominant concentration in Bt cotton fields is higher than in the conventional cotton fields. Therefore, the stabilities of insect community, pest sub-community and pest-natural enemies sub-community in Bt cotton fields may be less than those in conventional cotton fields, and the possibility of outbreaks of certain pests in Bt cotton is much higher.

iv. Both laboratory tests and field monitoring have verified that cotton bollworm can develop resistance to Bt cotton. Laboratory tests for selection of Bt-resistant bollworm indicated that susceptibility of bollworm to Bt cotton fell to 30% after 17 generations under continuous selection with a diet of Bt cotton leaves. The resistance index of the bollworm increased 1000 times when the selection was continued to the 40th generation. Based on these results, the scientists concluded that Bt cotton would probably lose its resistance to bollworm in fields after the Bt cotton has been planted for 8-10 years continuously.

v. Bt cotton demonstrates excellent resistance to the second generation bollworm and chemical control is not generally needed for the seedling period of Bt cotton.

vi. However, the resistance of Bt cotton to bollworm decreases over time, and control is not complete in the third and fourth generations. In fact, farmers must use chemicals 2-3 times to control bollworm, particularly from mid-July to the end of August has been commonly recognized in China, but there are not yet effective measures to postpone resistance development or to resolve the resistance problem. A high-dose of the Bt toxin protein is considered difficult to obtain, and the refuge mechanism is not easily implemented. In addition, the high-dose assumption and refuge design have theoretical shortcomings.

Joanne Daly and Karen Olsen of CSIRO Entomology, GPO 1700 Canberra, ACT Australian Cotton Co-operative Research Centre state that resistance is an ongoing concern with the management of Helicoverpa armigera in the Australian cotton industry. In response, resistance management strategies (RMS) are in place to either prevent, or retard further development of, resistance to either chemical insecticides or to the Cry1Ac protein in transgenic plants. While these strategies have been successful at slowing down the rate at which resistance has developed to insecticides, they have neither prevented the ultimate spread of resistance to most field populations nor the evolution of new mechanisms of resistance that make resistance increasingly difficult to manage.

Farmers in Australia are now being advised to spray additional insecticide on Monsanto's GM Bt. cotton, INGARD, "under conditions of reduced INGARD plant efficacy". The latest official guidance makes it clear that Bt cotton is in some circumstances failing to control the principal target pest it was introduced for, Helicoverpa armigera [Resistance management plan for INGARD Cotton 2001-2002; Transgenic and Insect Management Strategy (TIMS) Committee of the Australian Cotton Growers Research Association].

Rigorous field studies of teams led by Bruce Tabashnik (University of Arizona) and Fred Gould (North Carolina State University), both reported in recent years in the Proceedings of the National Academy of Sciences, U.S., provide solid evidence of insect resistance to Bt cotton.

The other big claim for GM crops is reductions in pesticide use. In reality, herbicide tolerant and Bt-transgenic varieties of GM crops are trapping farmers into more reliance on pesticides. Recently, hundreds of hectares of GM cotton fields in Bulukumba, South Sulawesi, were destroyed by pests. Officials said that there was "nothing to worry about", and a spokesperson from Monsanto (the GM Bollgard cotton seed supplier) asserted that "they are just larva which eat the leaves, but will not disrupt cotton production". But local farmers complained, pointing out that the supplier had claimed the cotton variety was resistant to all kinds of pests.

Even when GM crops express pest resistance, there is little evidence of reduced pesticide use. This is borne out by data on transgenic cotton. Although to date one fourth of American cotton is produced with genetically engineered Bt varieties, no significant reductions in the overall use of insecticides were achieved [Thalmann, P. & V. Kung (2000), No reduction of pesticides use with genetically engineered cotton, for WWF International; and Thalmann, P. & V. Kung, (2000), Transgenic cotton: Are there benefits for conservation? A case study of GMOs in agriculture, with special emphasis on freshwater]. In fact, those insecticides that could be replaced by Bt cotton make up a minor proportion of the insecticides used.

Similarly, with Bt corn, there is no independent evidence of a reduction in overall pesticide applications despite industry claims. Nor is there economic advantage in using Bt corn except in areas with very high pest infestation. Insecticide use on US Bt corn has in fact slightly increased, with insecticide targeting European corn borer rising from about 4% of acres treated in 1995 to about 5% in 2000 [Benbrook, C.M. (2001), Do GM crops mean less pesticide use?; Pesticide Outlook, October 2001].

Since resistance has become a major worry, companies now insist that farmers follow resistance management plans (RMPs), which include "refugia" (keeping a certain proportion of fields free of Bt seeds and insecticides). These fields are to be the refuge of susceptible insects, thus slowing down evolution of resistance against the Bt gene. However, Tabashnik's team has questioned two fundamental assumptions behind all Bt RMPs - that resistance to Bt is a rare recessive trait and that cross-resistance to Bt endo-toxins is uncommon. The idea that resistance could be delayed through the use of two or more endo-toxins has, thus, been seriously undermined.

Further, field data show that expression of toxins in Bt-transgenic crops can develop unevenly in different parts of the plant. In one report, Bt toxin expression was found to be 90-95 per cent in the top part of the plant but only 20-25 per cent in the lower nodes, making them more susceptible. Since the lower nodes often produce the highest quality cotton, their loss is even more significant. Bt toxin expression also typically starts out high in the early part of the season but tapers off over time.

It is also inadequate in harsh environmental conditions such as drought. This "sub-lethal dose" of the toxin can facilitate the development of resistance over time, just as it happens with pathogenic bacteria when we fail to complete the necessary course of antibiotics. Uneven expression of Bt in the crop could also accelerate emergence of "behavioural resistance" (M. Harris, Science, 1996), because insects may sense which parts of the plant to avoid. In India, with so many difficult agro-ecological conditions and millions of poor farmers, Bt-transgenic crops are likely to grow unevenly across farms leading to many cases of sub-lethal doses of the Bt toxin and, therefore, resistance might be engendered at an even faster rate. Estimates of how long resistance can be delayed vary, but the average figure in most research, even in the relatively favourable circumstances of the U.S., is not more than five years. So powerful demands are being made that the Environment Protection Agency (EPA) should delay any further approval of Bt- transgenic plant varieties, and that previous approvals should be reversed when evidence points to imminent failure of an RMP. In any case, the EPA had granted only conditional registration to Bt crops in 1995, mainly due to fears that pest resistance could develop.

A study conducted in Alaska to see if targeted insect pests will evolve resistance to Bt showed that several species have evolved resistance to Bt in the field, and many other species have been shown capable of evolving resistance based on laboratory selection experiments. IPM of Alaska has documented Bt. resistant Indian Meal Moths, Plodia interpunctella in the Mat-Su Valley and Anchorage area in 2000 and again in 2001. The USDA tested Bt. resistant strains of the moth in the laboratory at their Agriculture Research Service Biological Control laboratory in Nebraska. One strain developed resistance to the CryIAc toxin by a mechanism that gave it broad resistance to many diverse Bt toxins including CryIIA, which is extremely different from the CryIAc toxin used in selection. This finding indicates that although there are many Bt toxins, once resistance evolves to one of them, we may not be able just to substitute a different Bt toxin.

The EPA has stated that one strain of the tobacco budworm that was selected to adapt to the CryIAc toxin developed a more specific mechanism for resistance. This strain now has over 5,000 fold resistance to CryIAc, which means it takes 5000 times more toxin to kill the resistant strain than it takes to kill normal strains. The resistant strain also has high resistance to a number of other Bt toxins such as CryIF. Interestingly, this strain is not highly resistant to CryIIA. It has been estimated that one in a thousand tobacco budworms carries a gene for Bt resistance. This is a higher frequency than expected for conventional pesticides and may be related to the fact that Bt toxins are so species specific.

Unlike risks of conventional pesticides that are typically limited to specific circumstances of use and location, and can be conceivably tackled, risks following Bt-transgenic resistance are essentially irrevocable. Once resistance genes emerge and gain a foothold in populations, they cannot be recalled.

Other environmental impacts of Bt cotton and other genetically engineered crops:

Numerous studies have shown that the genetic pollution with the introduced gene can cause the weedy relatives of the GE plant to become superweeds. Researchers have shown that a Bt gene can migrate to weeds in a natural environment and make the weeds stronger. Scientists studied genetically engineered sunflowers modified with a gene that produces a chemical toxic to certain insects to see what happened when transgenes, were inadvertently passed along to weedy relatives. Bt sunflowers are not in commercial cultivation. The resulting hybrid sunflowers that contained the transgene had 50% more seeds than control hybrids without the gene. "The researchers also found that the addition of this gene didn't harm the weeds' physical fitness, even when the sunflowers were deprived of water and nutrients”. A plant with a transgene may have to divert more energy to handle this new compound it's making," Snow said. "Doing so could reduce the plant's ability to reproduce. But that certainly wasn't the case here”.

There are also numerous studies by leading scientists of international renown and published in leading international scientific journals showing the hazardous impact on non-target species as well as essential pollinators such as the monarch butterfly. Studies conducted by the U.S. Department of Agriculture–Agricultural Research Service (USDA-ARS), Corn Insects and Crop Genetics Research Unit, and Department of Entomology, Iowa State University; Department of Entomology, University of Nebraska; Department of Environmental Biology, University of Guelph, Canada and Department of Statistics, Iowa State University, on the toxicity of various Bt proteins, confirmed the earlier findings of Losey et al, that Cry1Ab and Cry1Ac are toxic to monarch larvae. Losey's study was criticized on the grounds that there was no quantitative assessment of the protein consumed by the larvae. The later study admits that in field conditions, the toxicity depends upon the amount of pollen consumed by the larvae.

The insecticidal Bt-toxins, isolated from Bacillus thuringiensis are often engineered into plants in a pre-activated form, and are already known to be harmful to bees directly, and to lacewings further up the food chain. A recent study in Switzerland found that lacewings, which prey on corn pests, suffered mal-development and increased mortality when fed corn borers raised on Bt crop [A Hilbech, W.J. Moar, M. Prisztai - Carey A. Fillppin and F Zigler, Toxicity of Bt to the Predator Chrysoperla carnea, Environmental Entomology, Vol. 27, No 4 August 1998].

Research at the Scottish Crop Research showed that lady birds fed on aphids which were fed on transgenic potatoes laid fewer eggs and lived half as long as lady birds on a normal diet [A.N.E. Brich et al "Interactions between plant resistance genes, pest aphid populations and beneficial aphids predators, Scottish Crop Research Institute, Dundee, Annual Report 1996/97 p 68-71].

Evidences of the effects of GE-pollen on non-target species is increasingly coming to the fore. For example, a study on the phenomena of gene jumping done by Professor Hans-Hinrich Kaatz, a respected German zoologist at the University of Jena in Germany, found that the alien gene from genetically modified rape-seed had transferred to bacteria living inside the guts of honey bees. This research suggests that all types of bacteria could become contaminated by genes used in genetically modified technologies, including those that live inside the human digestive system [The Observer, New Delhi, dated 16 Oct 1999].

One of the chief concerns with genetically engineered crops is that they may become weeds in agricultural and non-agricultural settings. There is potential for herbicide resistant varieties to become serious weeds in other crops. Plants by nature are not weeds, but due to physiological and structural traits these plants are allowed to persist in the environments managed or otherwise influenced by humans. Some of these traits allow them to compete with the cultivated crops or plants. Scientists have suggested that some transgenes may confer or enhance the presence of weeds in some crops, i.e., transgenes may enhance the crop's capacity to persist in a field, invade new habitats or both. It is possible that Bt. plants do not show development of weedy character today, but there is no guarantee that it would not show such characteristics in the future. The weedy character is not observed in one year or two. In certain cases the weediness and invasiveness of species shows up decades later. When the British brought Lantana into India as a flowering plant, it didn't show any weedy character but today it has totally invaded all of India's forests and destroyed biodiversity as well as hindered forest regeneration.

Illegal Clearance and Illegal Trails

The conditional clearance dated 26.03.2002 for commercial release of the transgenic Bt. cotton seeds given by the GEAC, was based upon information obtained from previous tests and trials (open field trials) which was cleared by an authority which did not have the jurisdiction to grant approval for trials. Therefore even the decision of the GEAC to clear Bt. cotton for commercial planting is needs to be seriously scrutinized. This is so because the permission granted to Monsanto for the concerned open field trials are in grave violation of the existing biosafety rules.

Under the Rules for the Manufacture, Use, Import, Export and Storage of Hazardous Microorganisms, Genetically Engineered Organisms or Cells, 1989 framed under EPA, 1986 permission for release of organism into the environment and permission for conducting open field trials (which leads to release into the environment) as well as permission for its import can only be given by the Genetic Engineering Approval Committee (GEAC) which is part of the Ministry of Environment and Forest (MOEF). However, in this case, in violation of Rules, such permission was given by the Department of Biotechnology (DBT) which is under the Ministry of Science and Technology through the Review Committee on Genetic Manipulation (RCGM) which is part of the DBT.

The permissions for large scale field trials dated 27.7.98 and 5.8.98 granted by the RCGM and the proceedings which culminated in such permission to conduct multicentric open field trials at 25 locations in 9 states was in violation of the Rules of 1989. This is so because the said rule permits only the GEAC, under MOEF, to approve large scale multicentric trials. In the absence of such approval the "permission" by RCGM for import of transgenic material and the permission to conduct multicentric trials is totally vitiated not only on the ground of violation of the Rules, but also the provisions of EPA, 1986. As per Rule 4(4) the GEAC shall function as a body under the Department of Environment, Forests and Wildlife for approval of activities involving large-scale use of hazardous micro-organisms and recombinants in research and industrial production from the environmental angle. The Committee shall also be responsible for approval of proposals relating to release of genetically engineered organisms and products into the environment including experimental field trials. Moreover, the law as contained in Rule 8 clearly states that production in which genetically engineered organisms are generated or used shall not be commenced without the consent of GEAC.

Rule 9(1) states that deliberate or intentional release of genetically engineered organisms including deliberate release for the purpose of experiment shall not be allowed. The introduction and trials of Bt cotton by Monsanto – Mahyco and "approved" by RCGM was hence violative of all the above-mentioned Rules. In fact this was the basis of the RFTSE's Public Interest Litigation in the Supreme Court of India filed in 1999, which is still going on, but has been shifted to the Appellate Authority formed under Rule 19 of the 1989 Rules.

Therefore the conditional clearance dated 26.03.2002 for commercial release of the transgenic seeds is also illegal, as the decision though given by the GEAC was based upon tests and trials which was cleared by an authority which did not have the jurisdiction.

The unjustified haste of the GEAC in granting conditional clearance to Mahyco for commercial sale of its transgenic varieties is even more questionable when one considers the GEAC directions in the case of Navbharat-151. Navbharat-151 seeds, which was found to be a transgenic cotton seed and was being sold without requisite statutory bio-safety clearance, the GEAC had vide an order dated 18.10.2001 directed that the entire standing crop of Navbharat- 151 be uprooted and destroyed after burning. GEAC also directed to recover the cotton and the seeds harvested by the farmers from Navbharat-151 plants and destroy the same by burning, to destroy the seed production plots and to remove and destroy the breeding lines, hybrids, segregating material including any plucked cotton bolls or any breeding material and seed material available with the Navbharat Seeds company. The GEAC had passed such severe directions, including the uprooting and burning of the entire standing crop, in October against the crop of Navbharat – 151, holding that as it is transgenic (..having such an gene..) and an untested technology, it is extremely unsafe.

The transgene concerned in the GEAC decision is similar to that of the 5th April 2002 order (to Mahyco for commercial planting) in which as has already been mentioned been considered unsafe and was ordered to be wiped under a very stringent order of the GEAC. But only after a lapse of five months the same GEAC has granted conditional clearance to the Mahyco for commercial sale of its transgenic varieties, when no new independent and impartial data was available.

For all these reasons, it is clear that India do not have a proper set of guidelines, rules and systems for evaluating the biosafety and ecological and environmental impacts of genetically modified organisms used in crops. The government itself admitted in recent meetings that the capacities, infrastructure and mechanisms for monitoring have to be built in this country. It is absolutely essential that proper guidelines be in place with an independent monitoring and evaluation agency to ensure that “open trials” and “commercial release” of GMOs are safe for human health and ecology before they are permitted to be released into the environment.

Conclusion

The RFTSE and other independent field studies proves that the claims made by Monsanto and Mahyco about Bt. cotton as an effective pest resistant crop has been proved false by this years large scale commercial planting. The Research Foundation had also conducted a field study during the first large scale field trails in 1998-1999 and went to the Supreme Court to challenge the false claims by the companies. So far Monsanto and Mahyco have not submitted any data in the public domain. Even then government has accepted their claims and cleared the Bt. cotton for commercial planting. Now thousands of Bt. cotton growers are facing tough time because of the failure of their Bt. crop. The GEAC is responsible for a great loss to Bt. cotton growers caused by their haste and irresponsible decision to give clearance to an untested technology. The corporations are liable to pay immediate compensations to India farmers.

The concerns expressed, especially on the safety of GM foods, by a large number of healthcare and medical professionals, nutritional experts, social activists and environmentalists, in addition to many farmers' groups and consumers' groups have not been addressed in a systematic or satisfactory way. Moreover, certain official bodies like ICMR, NIN, ICAR and others on occasion have echoed these concerns too.

Given the fact that India is now a signatory to the Biosafety Protocol, and the protocol itself very close to coming into force, it is all the more relevant for India to respect the Precautionary Principle enshrined in the Protocol.

Given these strong grounds, RFTSE and others concerned groups have demand that the Government of India fulfill their obligation towards the Indian farmers, Indian consumers, our environment, our diversity and our very agriculture by imposing a 10 years moratorium immediately on the irreversible release of GMOs in this country.

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