Also available as a booklet from Earthcare books
Mr Jairam Ramesh,
Minister of Environment and Forests
Government of India
Subject: Bt Brinjal
January 30, 2010
Dear Mr. Jairam Ramesh,
Any decision permitting the environmentaI release and sale of Bt Brinjal in India is fraught with the most serious, far-reaching and irreversible consequences affecting our land and her inhabitants – human and non-human – for generations to come. With over 50 more genetically modified (GM) crops reportedly in the Indian pipeline, we must exercise utmost caution. Once released, these cannot ever be recalled, nor can the chain reactions they unleash be stopped.
You are well aware that a broad cross-section of Indian citizens – including outstanding scientists of undisputable integrity, as also large numbers of farmers and consumers – have opposed the sanctioning of Bt Brinjal, expressing grave concern for the potential hazards posed to human, animal and environmental health, and to the very food security and sovereignty of India. These are certainly not trivial matters permitting any foolhardy haste in pushing Bt Brinjal down the throat of this nation.
Prudence demands that all the above burning concerns should first be rigorously addressed and satisfactorily resolved, before a highly controversial crop like Bt Brinjal is even considered an option. The people of India refuse to be anyone’s ‘lab-rats’ or sacrificial goats, as you have plainly heard from many.
From your Public Consultations at Kolkata and Bhubaneswar, it is clear beyond doubt that the people of the states of Orissa, Bihar and West Bengal – that produce 60% of all the brinjal grown in India – overwhelmingly oppose the release of Bt Brinjal. The Chief Ministers of these 3 States have reportedly written to you recording their opposition, and have pointed out that since agriculture is a state subject, the Centre should not impose the unwanted Bt Brinjal on them, even ‘unofficially’ via a neighbouring state, as would inevitably happen if Bt Brinjal is at all permitted anywhere in India.
At least 5 more States, including Andhra Pradesh, Chhattisgarh, Karnataka, Kerala, and Madhya Pradesh, have also opposed the release of Bt Brinjal – to protect their citizens and the natural wealth of their land. Indeed, several of these States are in favour of a total ban or moratorium on GM crops. Till date, has any State pleaded for expediting the environmental release and sale of Bt Brinjal – without any further evaluation or debate in the matter? If so, please inform which State/s, and what urgent reason/s they have cited in justification.
I was able to speak briefly at your Kolkata Public Consultation on the 13th January, when I also presented you copies of my relevant books, ‘The Great Agricultural Challenge’ and ‘Organic Revolution’. I now submit (herebelow) my detailed presentation, as requested by you.
1) What is this unseemly rush for Indians to be the world’s first guinea-pigs for Bt Brinjal, bearing a bacterial gene of Bacillus thuringiensis (Bt) that secretes its own pesticide? A baingan (aka brinjal/eggplant/aubergine) engineered to be pregnant with poison! The first such Bt ‘food’, anywhere on earth, specifically targeted for human consumption rather than fibre or fodder – if India finally permits it.
2) India’s foray into GM began with Bt Cotton. The toxin generated by the plant was aimed at the bollworm, but did not know where to stop killing. Thousands of cattle died grazing on the Bt crop residues. Thousands of farmers cultivating it were driven to suicide. And yet, introducing Bt in our brinjal? A popular vegetable – consumed widely by rich and poor alike – inexpensive, and in no short supply. Why? What is the need? A convincing reply remains elusive.
3) Organic poly-cropping (mixed planting) with native local varieties of brinjals and other vegetables/plants, cultivated appropriately, have no significant pest problem. This is the experience of traditional/organic farmers all over the country. Various strategies of ‘Non-Pesticidal Management’ (NPM) successfully thwart or check pest damage. Hence, no Bt crops or synthetic pesticides are required if such classically sound agronomic methods are widely promoted. This is the saner, safer, simpler model — offering multiple benefits in a sustainable, holistic manner – that India needs to follow, and which the Ministry of Environment and Forests must pro-actively canvas and support.
4) While unsustainable monocultivation of brinjal does entail the use of chemical pesticides, the farmers are yet able to control the dosage, depending on pest incidence. With Bt, there is no scope for moderation according to need. The genetically tampered crop uncontrollably generates its noxious pesticide, 24×7, deep in every part and cell of the plant – including leaf, root and vegetable And there is no possibility whatsoever of washing off the toxin. The poison is potently inescapable!
5) There is no mandatory labelling of Bt Brinjal required to warn consumers, mocking their right of free choice, and thus trampling a fundamental human right enshrined in our constitution.
6) To respect, beyond mere tokenism, the consumer’s inalienable right to choose his/her food on the basis of its time-tested safety, you must consider how any mandatory labelling of Bt/GM foods would be actually enforced in practice. In the absence of strictest enforcement, you should leave alone both the monster (Bt) and its tail, declining sanction for its release.
7) Consumers, consumer organisations, doctors and mothers have warned that if Bt Brinjal infiltrates the market, significant sections of people, conscious of its hazards, may be forced to stop eating brinjals altogether. They would thus be deprived of a cheap and “excellent source of vitamins, minerals, … and amide proteins” that our many indigenous brinjal varieties are acknowledged to provide. Such nutrients are especially needed by the poor, who your government is expected to protect.
8) It is significant that brinjal is one of the most affordable vegetables abundantly available all over India, second only to the potato in the total quantity grown and consumed. Why should we wilfully destroy it? And who benefits economically from such destruction?
9) India is the global centre of origin and diversity of brinjal, grown in this sub-continet since well over 4,000 years. Over 2,500 varieties of this vegetable have been recorded here! The release of Bt Brinjal will inevitably and progressively contaminate the hundreds of indigenous varieties that still remain. The well known instability of transgenic lines not only affects agronomic performance, but also safety, tending to enhance horizontal gene transfer and recombination. It is thus imperative to stop Bt Brinjal now before it is too late. Failure to do so would violate the farmers’ fundamental right to grow and save their traditional seeds of choice, free of externally imposed ruinous contamination.
10) By sanctioning the release of Bt Brinjal, we would also be violating the Cartagena Protocol on Biosafety adopted at the UN Convention on Biodiversity, to which India is a signatory. Most significantly, no GM crop is allowed to be grown in any region of the world that is a centre of origin or diversity of that crop, as with Brinjal in India. Approving the release of Bt Brinjal would thus be most reckless and inexcusable, causing a loss to both India and the whole earth – a crowning irony in the current ‘International Year of Biodiversity’ (2010)
11) Besides being the centre of origin and diversity of many important agricultural crops, including rice, evolved here over millennia, India hosts at least two important global centres of exceptionally rich, uncultivated, indigenous biodiversity – the Western Ghats and North-eastern India – which are also at high risk from the new genetically tampered species.
12) On 20-1-2010, the Supreme Court of India asked the Indian Government to detail the steps – including the rules and implementation mechanisms/measures – it has put in place to protect India’s traditional crops and plants from possible contamination by field trials of genetically modified seeds. With Bt Brinjal too, we must know what mandatory steps your Ministry will take to protect our indigenous crops and plants from contamination. How will you ensure that the minimum prescribed isolation distance of 300 (three hundred) metres between Bt Brinjal and other old native varieties is not violated by commercial Bt growers, researchers or corporate interests.
13) In West Bengal – which cultivates over a hundred indigenous varieties to produce 30% of India’s entire output of brinjal – more than 90% of the farmers have small or marginal holdings, each touching the next. Thus, even a 30 (thirty) metre isolation distance may be extremely difficult or impossible to ensure. This is true too of Orissa, Bihar and several other states. How then do you propose to protect such small farmers and their many traditional varieties from contamination? As cross-pollination in brinjal is possible even with an isolation distance of three kilometres (3000 metres) or more, how can you ensure that the pollinating agents of nature, the bees, etc., do not transgress the prescribed limit of 300 metres that seems rather arbitrary?
14) Prof TK Bose, former Vice Chancellor of Bidhan Chandra Agricultural University, and a veteran agricultural scientist, warns that the release of Bt Brinjal would also likely result in the contamination of the entire Solanacae family of crops to which brinjal belongs. This includes the potato, tomato, and chilli, portending disastrous consequences to the nutritional security and livelihood security of consumers and farmers. As already pointed out, potato is the most widely consumed vegetable in India, followed by the brinjal – both from the same Solanacae family.
15) It was also pointed out to you at the Kolkata Public Consultation that the fruit/shoot borers, for which Bt claims to offer protection, are only two of the fifteen or so insect pests that attack the brinjal in monocultural cash-cropping of this vegetable. The concerned farmers clearly do not expect any significant reduction in the use of pesticides by planting Bt Brinjal; rather, they are apprehensive that more chemicals (both fertilisers and pesticides) may soon be needed.
16) GM crops are totally prohibited in most nations. In much of Europe, including UK, Germany, Switzerland, Austria, the ban continues in defiance of WTO directives. Over 85% of global GM cultivation is confined to just 4 countries: US, Canada, Argentine and Brazil; and to a mere 4 crops – corn, soya bean, cotton and canola.
17) India’s Planning Commission Task Force to review GM policies and laws, chaired by the eminent geneticist, Suman Sahai, recommended that our regulatory system must first be vastly improved, and all alternatives thoroughly explored. Meanwhile, there should be no commercial release of GM crops. But throwing caution to the wind, rice, pigeon pea, mustard are already under open field trials; to be followed by wheat, jowar, ragi, bajra, corn, cassava, potato, onion, sugarcane, tea; also various pulses, oilseeds, vegetables, fruits and spices. Bt Brinjal seems just the first test case, opening the floodgates for the rest to follow, unless checked right now.
18) The Supreme Court of India appointed Dr Pushpa Bhargava – globally renowned scientist, honoured with Padmabhushan, a former Director of the Centre for Cellular and Molecular Biology, and Vice Chairman of India’s National Knowledge Commission – to oversee the Genetic Engineering Approvals Committee (GEAC). Dr Pushpa Bhargava has categorically declared: GEAC failed to take note of “the numerous research publications by well-known and highly credible scientists working in prestigious institutions, … that have appeared in some of the world’s best known scientific journals,” warning against indiscriminate release of GM crops, which cannot be recalled, no matter how much damage they cause. Dr Bhargava adds, “ … some 30 tests are needed … Monsanto has done less than 10; and we have no facility in the country to determine whether the tests were actually done, leave aside their validity… There were many scientific errors even in these tests, (which were all) on samples provided by Monsanto, a company that has proved itself most untrustworthy… No studies were done on the effects of Bt on soil microbial species, or on soil nutrients, or on cattle microflora. …It is perfectly possible that the increased health problems in the US in the last decade are due to increased consumption of GM corn and soy.”
19) Following a Public Interest Litigation in the Supreme Court of India, leading to the public disclosure of Monsanto-Mahyco’s Bt Brinjal biosafety data, an independent analysis of such data by a team led by Prof Seralini of the Committee for Independent Research and Information on Genetic Engineering (CRIIGEN), France, concluded: “Bt Brinjal release into the environment may present a serious risk to human and animal health and should be forbidden.” It pointed out that the longest toxicity tests done were for only 90 days, and hence did not assess long-term effects like the development of cancerous tumours, or effects on succeeding generations fed on the Bt crop. Will Monsanto, Mahyco, or the Indian Government advise citizens not to consume Bt Brinjal for more than 3 months?!
20) In case Monsanto and Mahyco are confident of even the long-term safety of Bt Brinjal, what legally binding responsibility and liability are they willing to commit themselves to if adverse health and environmental consequences do manifest within the next 5, 10 or 20 years?
21) The effects of Bt Brinjal consumption on young children, pregnant mothers, the aged and diseased, as well as the synergistic ‘cocktail effects’ of multi-toxins with Bt have also not been studied at all.
22) For any truly independent system of objective evaluation, India must set up a lab of her own, having high public credibility, which must be governed and staffed by an impartial body of people with unquestionable integrity, who have no economic link/s whatsoever (direct or indirect) with any GM producing or marketing company. It is such a body that must undertake – in a totally transparent, peer-reviewed manner – all the required bio-safety and related tests, monitoring, assessment and evaluation, including multi-generational studies. This has been stressed by the Supreme Court appointee, Dr Bhargava, by the Planning Commission Task Force on GM policies and laws, and by many others, including a host of acclaimed scientists and other citizens. Without such independent, credible testing and evaluation, any approval of a GM crop would only be based on make-belief science – and engineered/tampered second-hand information – remaining at the mercy of extra-territorial economic and political interests.
23) Multinational corporations like Monsanto make no secret of their resolve to wrench total strategic control of world agriculture through control of seeds and other inputs. Already, nearly half the global trade in seeds is controlled by a handful of MNCs, of whom Monsanto is the undisputed leader in the controversial GM crops. Within India too, the USA and American MNCs presently account for more than half of the $1 billion organised seed market. Fortunately, almost 80% of India’s farmers still follow the traditional system of saving, sharing and exchanging/bartering seeds, and hence do not buy them. It is this section that the MNCs greatly want to target.
24) Shri Vasant Futane, an organic farmer of Amravati District, Maharashtra, relates that no cotton seeds apart from Bt are now sold in his area; the local farmers there (as also in Andhra Pradesh) have no choice but to buy Bt. This is a consequence of aggressive ‘market capture’, beyond misinformation. Shri Futane adds, “Our healthy indigenous seeds, handed down over generations, are inevitably contaminated. What right do the GM companies have to pollute our seeds, the very lifeblood of Indian agriculture and many millions of self-reliant livelihoods?”
25) The WB Agriculture Commission, chaired by Prof RN Basu, recommended in its 2009 Report “a complete ban on all open field trials and commercial cultivation of GM crops” at least until all relevant safety and sovereignty concerns were “rigorously addressed and resolved.” Other States that oppose the release of Bt/GM crops include: Andhra Pradesh, Bihar, Chhattisgarh, Orissa, Madhya Pradesh, Karnataka and Kerala. Several other states too, like Tamil Nadu, have expressed reservations about allowing Bt Brinjal, and hence oppose any hasty decision in the matter.
26) Overall, there has been significantly increased consumption of chemical fertilizers, pesticides and irrigation with Bt Cotton and other GM crops, rising progressively over time. This is the experience worldwide. Leading GM seed companies like Monsanto, Du Pont, Syngenta, Bayer are also the top pesticide companies in the world. They have no economic interest in reducing their sale of chemicals, from which they have made massive fortunes.
27) The Chairperson of India’s Agricultural Scientists Recruitment Board projected that even a 6% expansion in GM crop area would lead to a doubling of chemical fertilizer consumption! And already, India’s annual fertilizer subsidy bill stands at a whopping Rs 1.2 lakh crore, a recurrent and mounting expenditure – each year – that starkly exposes the inherent economic bankruptcy of the industrial model of agriculture, even without considering the huge uncalculated costs of ecological devastation, water scarcity, health problems and lost livelihoods – suffered by present and future generations.
28) A Canadian Govt study showed that after just 4-5 years of commercial growing, herbicide resistant GM oilseed rape (canola) had cross-pollinated to create invasive super weeds resistant to upto 3 different broad-spectrum herbicides. Similarly, a recent analysis of data from the US Department of Agriculture (USDA) reveals that the cultivation of GM corn, soybeans and cotton has increased the overall use of toxic herbicides by 318 million pounds in the U.S. over 13 years from 1996 to 2008, because of the emergence of herbicide resistant super weeds infesting millions of acres. About 46% of this increase occurred over the last 2 years, 2007 & 2008, for which data was available. In our Indian agro-climatic conditions, such problems are expected to manifest much faster.
29) Bt insecticide producing GM crops have inexorably, over time, led to increased resistance in pests, resulting in rising chemical applications and the emergence of ‘super-pests’. In China, Bt Cotton seemed initially successful in suppressing the boll weevil, but in subsequent years, there appeared increasing populations of pests like mealy bugs and mirids, highly resistant to Bt, necessitating more spraying and/or stronger pesticides – a growing treadmill of toxins. Vandana Shiva (Navdanya) similarly reports that in the Vidharbha region of Maharashtra, the proliferation of aphids, jassids, army bug and mealy bug has resulted in a whopping 13 (thirteen) fold increase in the use of pesticides!
30) Ironically, Bt producing crops irreparably damage beneficial insect populations, including bees and butterflies, not originally meant to be targeted. This significantly affects the output of all crops that such insects pollinate. Bt crops also endanger many soil dwelling microorganisms and insects vital for the soil’s fertility, as well as beneficial pest predators that are friends of the farmer. (The predator species greatly help to check the build-up of pest populations.) But of course, the agri-business MNCs are not complaining about such ‘collateral damage’.
31) There is growing evidence of Bt toxins entering, lingering, and accumulating in the food chain, thereby posing a grave hazard to humans, animals, aqauatic life and soil organisms.
32) The seeds of Bt/GM crops necessarily have to be repurchased every season from the Company producing them. These patented varieties cannot be re-sown from the farmer’s own harvest, as with traditional seeds. Once the local native seeds are lost, or too hard to source, the helpless farmers inevitably have to pay sharply increasing amounts for buying the MNC seeds.
33) The world is already producing more than enough to feed the entire population on earth. But almost a billion people suffer from hunger or undernourishment, because the requisite food is not available to them at an affordable price. With GM pushing up production costs, maldistribution and hunger are sure to rise among the poorest sections, apart from malnourishment and cumulative toxemia.
34) GM crops are strictly prohibited in organic farming anywhere in the world, as pointed out by the International Federation of Organic Agriculture Movements (IFOAM). Presence of GM in any crop immediately debars it from organic certification, with serious consequences for organic exports, a “sunrise sector of the global economy”.
35) The medicinal use of various native brinjal varieties (uncooked) in Ayurveda is seriously threatened through contamination by Bt Brinjal, rendering toxic the intended medicines.
36) The development of antibiotic resistance, directly linked to the consumption of GM crops containing antibiotic resistant markers, is another glaring consequence. Many doctors believe that this would render ineffective various national health programmes like the drive against drug-resistant tuberculosis.
37) GM technology, artificially transferring genes from one species to another, permanently and progressively alters Nature’s blueprint. For example, the world’s first GM vegetable, the ‘Flavr Savr Tomato’ (containing a fish gene meant to delay ripening) was withdrawn from the market under public pressure, but the genetic contamination it unleashed cannot be recalled.
38) What stops highly secretive GM corporate giants – not known for scrupulousness – from genetically modifying rice to contain a scorpion’s gene, or wheat to bear a pig’s gene, or sugar to include a cow’s gene? Wilful sabotage and bio-terrorism, beyond plain mischief, are also possible. An introduced bacterial toxin can be modified to make it especially hazardous to humans. The concerned companies would obviously suppress any such information, witholding it from governments. While direct toxicity may be detected through tests, induced carcinogenic activity or toxicity caused through interaction with other foods could take decades to detect, if ever. The danger is particularly significant in the absence of independent testing (and testing facilities), monitoring and transparent evaluation by an impartial body of competent people with high integrity.
39) Genetically tampered ‘Terminator Seeds’ or ‘Suicide Seeds’, originally developed by the US Department of Agriculture and some seed MNCs, contain a ‘Terminator Gene’ that prevents plants from producing fertile seeds. The ostensible intent of such engineered sterility was to force farmers to buy new seeds every year, rather than save and replant from their own harvest. But once the terminator seeds are released into a region, the trait of seed sterility can pass to other non-genetically-engineered crops and plants, making most or all of the seeds in the region sterile! The possibility that the terminator gene could be transferred is not denied by anyone. In fact, the tendency of the inherently unstable GM crops/plants to ‘leak’ traits is exceptionally high. Following worldwide condemnation of the terminator seeds, the UN’s Convention on Biological Diversity (2000) recommended a de facto moratorium on their field-testing and commercial sale. This was re-affirmed in 2006. But now, there is a new push by companies like Monsanto to overturn the moratorium, and try to re-introduce terminator seeds, ironically under the guise of ‘bio-safety’. If they succeed, this would be an unparallelled disaster to all humanity, agriculture, and the world of Nature.
40) Even forgetting conspiracy theories, and assuming for a moment that companies like Monsanto are compassionate angels, more interested in harnessing the power of ‘advanced technology’ for the progress and well-being of humanity, rather than money and power for themselves, here is an interesting quote from an outstanding organic farmer, now 87, hailed as the ‘Gandhi of Natural Farming’. He says in his Open Letter to MS Swaminathan (The Great Agricultural Challenge, Earthcare Books): “By its very mandate, genetic manipulation strives to maximise the ‘performance’ of certain essentially limited features, not knowing what the wider consequences may be. But Nature works through the interplay of an incomprehensibly vast array of factors, far beyond the professional concerns or cognitive reach of genetic engineers. While (they) may have certain economic or political interests in mind, they cannot even begin to imagine trying to forge an overall balance that fosters health – the mysterious harmony of diverse elements and forces.”
41) The British Medical Association (BMA), with over 120,000 members – representing more than 80% of British doctors – has asked people to reject all GM foods. It has also called for a halt to all GM food trials.
42) More recently, in May 2009, a leading US association of physicians, the American Academy of Environmental Medicine (AAEM) released its position paper on GM foods, stating that they “pose a serious health risk, … (particularly) in the areas of toxicology, allergy and immune function, reproductive health, and metabolic, physiologic and genetic health.” The AAEM called for a moratorium on GM foods, and immediate implementation of long term safety testing and labelling of GM foods. It further called upon all physicians to educate their patients, the medical community and the public to avoid GM foods.
43) The only published human feeding study revealed what may be the most dangerous problem from GM foods. The gene inserted into such food transfers into the DNA of bacteria living inside our intestines and continues to function. Thus, long after we stop eating GMOs, we may still have potentially harmful GM proteins produced continuously inside of us. Put more plainly, eating a corn chip produced from Bt corn might transform our intestinal bacteria into living pesticide factories, possibly for the rest of our lives. It is thus no surprise that the scientists working for companies like Monsanto, reportedly refuse to eat any GM food themselves if they can avoid it!
44) After four years of study and deliberation by an international panel of over 400 agricultural scientists from 60 countries, the final report of the ‘International Assessment of Agricultural Science and Technology for Development’ (IAASTD) was released in April 2008. It recommended that small-scale farmers and agro-ecological methods are the way forward, with indigenous knowledge playing an important role. It pointedly noted that GM crops are not the answer to hunger, poverty or climate change.”
45) To conclude, here is another quote from Shri Bhaskar Save, the wise old farmer: “ If only we see that there is nothing lacking in the genetic code of the myriad time-tested species gifted by Nature, we would realise that there is no need to tamper with their DNA ribbon of life. And that much saner and happier paths exist to provide for the well-being of all — Sarvamangalam!”
I do hope the above wisdom prevails on you, and you steadfastly refuse to grant sanction for the release of Bt Brinjal or any other GM crop in India.