David Andow's report on Monsanto and Bt brinjal:

Download the Full Report here.

Brief & Press Release including comments by Aruna Rodrigues

Bt Brinjal Event EE1: The scope and adequacy of the GEAC environmental risk assessment

“The GEAC set too narrow a scope for environmental risk assessment (ERA) of hybrid Bt brinjal, and it is because of this overly narrow scope that the EC-II is not an adequate ERA” ... “ most of the possible environmental risks of Bt brinjal have not been adequately evaluated; this includes risks to local varieties of brinjal and wild relatives, risks to biological diversity, and risk of resistance evolution in BFSB. – Prof David Andow

David Andow is an acknowledged international expert on the environmental risks of GM crop plants. This 80 page comprehensive critique of Monsanto's Dossier and the Bt brinjal Expert Committee II Report (EC II), is an authoritative and meticulous scrutiny of the raw data of the Dossier. Andow lists some 37 studies of which perhaps 1 has been conducted and reported to a satisfactory level by Monsanto: “Briefly, EC-II relied on dubious scientific assumptions, did not focus on realistic environmental concerns, inadequately evaluated some important environmental concerns, and ignored other real environmental concerns”. I pick out the following critical points from his definitive environmental appraisal of Bt brinjal:

Comments by Aruna Rodrigues:

  1. This risk assessment raises the key Q: on what basis did the EC II recommend Bt brinjal and the GEAC uphold that recommendation and approve it on 14 Oct. 2009? Either our regulatory bodies (GEAC/RCGM) did not bother to look at the raw data of the dossier, or are incapable of analysing such data. Either way, the Regulators and the ‘Rules’ governing GMOs pose an unacceptable risk to India’s bio-safety on the many dimensions of the irreversible risks of GM crops and in this specific case, the risks from Bt brinjal
  2. Beyond this, it is clear that the conflict of interest favouring GM crops, at the level of the STATE, not merely the proven case within the regulatory bodies, has allowed a situation where the only bio-safety dossier produced for any crop, viz. Monsanto’s Bt brinjal, is quite simply fraudulent. Much more serious is the Government Regulators' role in upholding that dossier.
  3. Can it get worse? Yes, because the claim was that the dossier complied with the ICMR guidelines for the risk assessment of GM crops, which were supposedly in compliance with the spirit and letter of our international obligations under Cartagena and the Codex. Both are false and manifestly so.
  4. What we need are 'Rules' for GMOs which DO THE CORRECT THING BY INDIA, not merely regulate this technology to the substandard ICMR guidelines, but approach it with the required sceptical analyses, an absolute requirement for risk assessment protocols for this lab-based technology which presents unique risks.
  5. Can it get even worse? Yes it can. According to Andow’s research, Brinjal farmers in India have a quite low suicide rate, because brinjal helps cash flow and buffers income variation in other crops. Yet, what will happen to these farmers with the advent of Bt brinjal, when we have crop failures projected to occur in 4-12 years because there is no recognition of ‘resistance’ of the BFSB? (In the Supreme Court, the risks for farmers, arising from ‘resistance’ has been the focus of the Petitioners for over 3 years. The Apex Regulator has actively denied the fact of resistance a thoroughly unscientific and untenable claim). We already have high rates of suicide among Bt cotton farmers attributed squarely to Bt cotton for an assortment of reasons. It would appear that the government regulator is prepared to risk our small-scale resource-poor farmers to promote GM crops and back Monsanto.
  6. There is the further problem of insect shifts which we have already seen since the commercialisation of Bt cotton and which has apparently devastated the Bt cotton crop in several States. The potential for secondary pests in Bt brinjal has been examined only “cursorily” by EC II despite the “common occurrence of secondary pests on Bt crops around the world”. Given the economic plight of our small-scale brinjal farmers, a thorough evaluation of this problem was mandatory. It should have been done first for Bt cotton before examining the similar potential of a secondary pest on Bt brinjal.
    • “Imagine if the government claims there are no risks of secondary pests, and then a secondary pest arises. The government might be perceived as favouring GM seed companies at the expense of small-scale farmers”. (Andow, pg 37).
  7. Finally, Andow’s thinking and analyses rightly go beyond science, as do the Cartagena Protocols and Jairam Ramesh, when he judged the evidence that underscored his decision to impose a moratorium on Bt brinjal; he was both “responsive” to society and responsible” to science. Andow elegantly recognises thatBrinjal plays a unique role in Indian society, and it will be important to evaluate if and how Bt brinjal may affect these values– The narrow utilitarian analysis used by the GEAC in EC-II and the Dossier assumes that the only relevant human value is related to money, – Human flourishing is reduced to whatever money can buy, and issues of equity and fairness are irrelevant to this way of thinking”. (pg 6 & 47).

For civil society, Andow’s environmental appraisal must signal a high alert. Critically, a regulator should be supported either by its own internal capacity to perform safety testing or by a specialist community of fundamental safety researchers with clear career pathways that allow them to work without the need for industry or political associations. This is presently not the case.

My own reaction is one of profound unease for our country: The Regulators' approval of Bt brinjal is a breathtaking impertinence. They thought they could use their statutory powers to pull one over the entire nation, to hand down a decision that amounted to an unacceptable betrayal of India.

Aruna Rodrigues, 15 September 2010.