Response to "updated" Indian inter-academy report
On 19th March 2010, following an intense debate first around the regulatory clearance for commercial cultivation of Bt Brinjal in India (first GM food crop in the country to have reached that stage and first such GM food anywhere in the world) and subsequently on the decision to impose a moratorium on the release of Bt Brinjal in India announced on February 9th 2010, the Minister of State for Environment and Forests Mr Jairam Ramesh, along with Dr Kasturirangan, Member, Planning Commission requested six Science Academies in India to prepare a report on the subject of biotechnology in food crops with focus on transgenic crops and on the Biotechnology Regulatory Authority Bill which is supposed to be in the offing.
This author has no access to the exact nature of the request that Mr Jairam Ramesh made to the Science Academies and can only presume that he turned to them for a scientific review related to safety of GM crops since the post-moratorium-decision controversy centred around how 'science' should drive decision-making (implying that some sort of 'politics' had driven the moratorium decision).
As reported in the media at that time, there was supposed to be a "detailed review" covering all aspects of biotechnology in food crops by the Science Academies. The INSA President was quoted in some media reports as saying that there will be a "detailed review to study the issue absolutely thoroughly".
Given that six science academies were involved in this exercise, the general expectation from the process was a rigorous, scientific review of existing evidence on GMOs in our food and farming, and of concerns raised specifically with regard to Bt Brinjal during the debate around its imminent approval. When civil society groups tried to approach INSA for sharing material and taking part in the process, they were told that this process is not open to the public by INSA in Delhi; however, relevant material was printed out and couriered to INSA, to be included in the process of review.
On 20th September 2010, a report released by the President of Indian National Science Academy to all fellows of INSA over email, had this to say:
"You would perhaps recall the discussions we had sometime ago on GM Crops, in pursuance of a suggestion by Shri Jairam Ramesh and Dr. Kasturirangan. The report prepared on the basis of the written comments given by Fellows of the Academies, the documents brought to attention by them and above all the discussions at the June 1 meeting, is attached. I am grateful to all who contributed to the preparation of this report".
For all practical purposes, this was THE report! However, it was a shoddy report which brought much disrepute to Indian science itself when it was revealed that important parts of the report were left to be written up by some GM crop developers who chose to 'copy and paste' from earlier PR material. It was a shameful episode which forced Indian scientists to defend themselves and show if they were indeed scientific and independent. The Minister for Environment & Forests clearly pointed out that he had no use for such reports since he had requested for a broader scientific view (and not views which he already knew). Interestingly enough, the then Science & Technology Minister was forced to say that Bt Brinjal commercialization decision would be a political decision ("we value their opinion greatly but ultimately it will be a political decision", he is quoted to have said!).
However, despite the fact that this was clearly a shoddy, unscientific, disreputable and non-credible job done, "Academies stand by their findings", shouted the headlines in many papers. The Academies sought to explain their 'bad science' as a case of missing scientific references without acknowledging that there is a deeper problem here indeed that they have not chosen to peruse available scientific literature or think of a better process than the one that they organized to come up with their report and were in a great hurry to just put forward a set of recommendations including that of a limited release of Bt Brinjal.
The fact that the Academies have been firm on their so-called "findings" come what may, is the crux of the problem with the updated report too. For instance, on the day that the Academies' report became controversial on plagiarism charges, a new detailed analysis on Bt Brinjal biosafety by Prof David Andow of University of Minnesota was released into the public domain. The 'updated' report makes no reference to this analysis, for example. In the last several months, various new reports were released which also made it to media columns about the impacts of GM crops, from India as well as abroad. There is no evidence of these being incorporated into the process that the Academies ran for coming up with their 'findings'.
CAN THIS BE CALLED A SCIENTIFIC REVIEW OR A REPORT BASED ON SCIENTIFIC EVIDENCE ON GM CROPS?
We need to first look at the process adopted by the Academies for coming up with their report. It would not be amiss to bring up the not-acknowledged-enough-and-acted-upon issue of conflicting interest in the Indian scientific establishment, reflected also in regulatory setups. As an India Today piece called "Egg on the Academies' Faces over Eggplant" (September 30th 2010) points out:
"Presidents of at least two other academies - The National Academy of Agricultural Sciences and the National Academy of Sciences ( India) - had a direct conflict of interest with the issue at stake. Both of them have been vocal supporters and recipients of funds for development of GM crops. Dr Mangala Rai, who heads the agricultural academy, has co-chaired a multi-million dollar funding mechanism called Indo-US Agriculture Knowledge Initiative set up to promote GM crops in India. Board members of AKI include representatives of Monsanto, Walmart and ITC. Dr Asis Datta, President of the National Academy of Sciences, has developed GM potato and tomato with liberal grants from the Department of Biotechnology during the past two decades".
The Updated Report clarifies that the conclusions and recommendations (of the report) arose out of the Brainstorming meeting on June 1st 2010. "The report is not meant to be the result of a new scientific investigation. It is meant to convey opinion on the basis of investigations already conducted", it says.
June 1st meeting: If the June 1st meeting formed the crucial process for the inter-academies report, it is pertinent to look at the ones who made the 'introductory presentations' before the 'in-depth discussions' and what were the presentations on. Eight presentations have been put up on the INSA website four of these are from people involved closely in India's regulation of GM crops (Dr H S Gupta who was a member of RCGM, in turn frequently represented by GM crop developers like Dr Ananda Kumar and Dr K C Bansal in the RCGM meetings; Dr Manju Sharma who was Secretary, DBT; Dr V S Chauhan, who was member of GEAC and Dr V P Kamboj, Chair of RCGM). The presentations were not based on any scientific evidence cited; in a couple of cases, they consisted of a reiteration of the biosafety studies done on Bt Brinjal and the conclusions of the crop developer and the regulators. In at least two presentations, industry data for GM crop adoption is used as evidence for bio-safety?! Certain popular arguments that GM crop proponents often put up, not backed with scientific reasoning or evidence, were obviously brought up in two of the presentations - consumption of Bt corn in many countries without confirmed and authenticated ill effects to the public, for instance, is seen as the greatest proof of safety of Bt gene! Two of the presentations were on NBRA and BRAI proposals.
Further, about seventeen of the 46 persons present in the June 1st brainstorming meeting are either associated with GM crop regulation in the country or GM crop development, which is more than one-third of the group. While it is to be expected that the ones involved in regulation or into GM crop development will be more interested in this issue and therefore show it through their participation in the June 1st meeting, it can be safely said that this is no representation of the scientific community that the six Science Academies actually consist of. It is also unclear how many of the 47 present actually participated in the 'in-depth discussions'. It is mentioned however that 'the recommendations represent a synthesis of the opinions of an overwhelming majority of participants'.
Another issue with the updated inter-academy report is related to around 119 references that were incorporated after the controversy on plagiarism erupted (some of which are just links to websites). It is interesting to note that many of the published reports that people who have concerns with GM crops either on the environmental or health front usually cite are not part of the references listed by the inter academy report. This also includes several reports that emerged in the past one year or so.
A last point to highlight about the report is that this report is not anything by which the immediate fate of Bt Brinjal in India could or should change since it is not part of a regulatory decision-making process and also for the simple reason that it did not come up with any fresh analysis on Bt Brinjal's biosafety apart from reiterating what crop developers and regulators have been saying.
In fact, in a situation where many biosafety studies get done either by GM crop developers or by funding provided by them and in a situation where IPRs are used to restrict and direct GM crop research worldover as the Nature Biotechnology report illustrated (Vol. 27, No. 10, October 2009, called "Under Wraps"), the inter-academy process should have actually highlighted the challenges posed by conventional methodologies of scientific review (a meta-analysis, for instance) for an issue like transgenic crops, to sift through truly "independent research". The Science Academies should have come up with innovative but rigorous methods of understanding the independent scientific evidence at hand before coming up with their recommendations. However, as repeated reports and articles suggested, it appears that the Science Academies had come up with foregone conclusions into which everything was retro-fitted.
WHAT DOES THE INTER-ACADEMY REPORT NOT ADDRESS?
The report mainly takes a foregone view (called the "approach") that transgenic technology is more precise than conventional breeding in its gene transfer, that it is not very different from Nature's processes and the risks are not more than that of human interventions in the form of agriculture in any case, that risks have to be calculated against supposed benefits and managed. Another basic premise is that of supposed benefits from the technology including on the productivity front and therefore, in a Malthusian approach, a rationale for the need for this technology is proffered. This pre-decided approach is then sought to be supported through some arguments which are quite fallacious as some of the arguments go ('no authenticated reports of ill effects from the countries which eat GM corn, and therefore, GM corn is safe', is one such argument; along the same lines, one can argue that there are no authenticated reports that rule out the correlation between increase in various illnesses in countries like the USA and GM crops; further, this also pre-supposes that most GM corn in the USA is consumed in the human food chain and that GM ingredients in small quantities in processed foods in the USA could be equated with GMO foods like Bt Brinjal, for instance).
At this stage itself, if the report does not clearly address some important issues, it is obviously allowing itself the unscientific privilege of being non-rigorous and biased in terms of picking up various concerns almost whimsically (for instance, for the ones who oppose GMOs in our food and farming, the very S&T of transgenics is questionable in its precision, predictability and ability of the developers to control the technology but these shortcomings of transgenic technology are not picked up for discussion) and discounting them opportunistically with select literature, and the recommendations therefore do not merit any consideration:
- If transgenic technology is indeed more precise and is not different from conventional breeding or Nature's processes, the Science Academies should argue for a case to dismantle all regulation around this technology; it should be remembered that the nature of unpredictability, novelty, imprecision and irreversibility of this technology as used in our farming systems is in itself something that global scientific world does not have any consensus on (it is a scientific fallacy in any case to argue that Nature's processes have gene constructs introduced in other (unrelated) organisms consisting of bacterial genes, viral promoters, antibiotic resistant markers and so on as is the case with current GM crops). That is the reason why the Indian regulatory regime is also based on the recognition of the risks posed to health and environment from modern biotechnology including transgenics (EPA 1989 Rules) and that is why even international protocols exist around this technology, including ones binding on India. The Science Academies should also be able to argue a rigorous case as to why this is a raging controversy around the world and not just in India if it is such a straightforward case on the scientific front and why the best of scientific minds and institutions are debating this to this day.
- The Science Academies should sieve through all the scientific research available right now and then segregate that evidence which is truly based on 'independent research' one that is not created by GM crop developers/marketers and one that is not funded/controlled directly or indirectly by them. They should then do a rigorous scientific review/analysis based on independent findings and then come up with their report, after also running a satisfactorily rigorous process of inquiry within the Academies.
- The Science Academies should also re-look at any apparent contradictions within their findings and recommendations for instance, the reservations sounded on antibiotic resistant marker genes does not necessarily go with the recommendation for limited release of Bt Brinjal which consists of such ARM genes. Is there a sound justification for this? Similarly, admitting that there is no post-commercialisation monitoring present at this point of time and not recommending one such process for Bt Cotton before moving into Bt Brinjal's limited release is an apparent contradiction of sorts. A third example is where the report talks about how "care needs to be taken for cultivation of transgenic as well as non-transgenic crops near the Centres of Diversity and impact assessment should be a regular activity", and then knowing fully well that India is a Centre of Diversity for Brinjal, asks for a limited release of Bt Brinjal.
- What is not clear is the reason for the haste with which the report was prepared and the reason for the haste being advocated for the release of GMOs like Bt Brinjal. If the problem also lies in lack of strategic planning and establishing priorities in the area of transgenics (the inter-academy report recommends an independent high-powered expert committee for this purpose and for overseeing efforts involving transgenics), in existing regulatory regimes (which does not have post-introduction monitoring as of now), why not wait for things to be set right before rushing into a limited release?
- The recommendation on the limited release is such that it is effectively all about further testing of Bt Brinjal in any case ("The performance in the field, in all its aspects, should be monitored by an independent committee which should not include the suppliers or their representatives" and "appropriate isolation distance should be maintained although no deleterious environmental effect is anticipated"). How do the Academies intend to ensure containment of such limited release in a country where Bt Cotton spread on thousands of acres way before it was approved by the regulatory authorities and has witnessed such regulatory failures subsequently too (unless the Acadamies do not really mean what they say when they talk about 'Limited Release')? What are the various aspects that should be monitored and why?
- The conclusions of the Science Academies on Bt Cotton are worth questioning (the benefits of Bt Cotton include change in pesticide use pattern and decrease in yield loss which increases overall yield leading to environmental and socio-economic benefits). Two papers of the University of Reading (did the Academies question the funding for these research projects?) are cited in support of the conclusions, ignoring other official data on insecticide costs on cotton that the CICR's Director had put in his paper presented to Mr Jairam Ramesh (attached in the Annexure to the Minister's moratorium decision note) and all the data presented on the cost of cultivation per hectare or per quintal over the years, in different cotton growing states in India by the Government in response to repeated Parliamentary questions which does not reflect this positive picture that the inter-academy report projects. The Reading group's research has already been responded to elaborately by other authors like Glover (2009, 2010). Regarding overall chemical use coming down in countries like the USA, there is contradictory data available from different sources and surely the Academies are aware of the existence of data showing the overall agri-chemical use in USA going up after the advent of GM crops.
- It is very important that the Science Academies sieve through the data available on production and productivity increases through GM crops given that they admit that no GM crop has been created with intrinsic yield increase potential so far. Why then the optimism in a Malthusian approach around yields and why was this not analysed some more to arrive at a more real picture with regard to productivity, including in terms of protection from crop losses?
The first section on "How to produce GMOs", while presenting a brief bland theoretical overview of how r-DNA technology works in creating GMOs does not mention the main issues around the technology from where the safety concerns flow that of instability, unpredictable changes from the molecular level upwards and the irreversibility of a living technology that is released into the environment. This section fails to acknowledge several papers on the mutagenic implications of the transformation or the issues with particular genes deployed in GM crop creation including in the case of Bt Brinjal.
The section on "How much transgenic crops?" relies on industry data and conveniently fails to acknowledge the fact that the largest single grower of GM crops to this day is the USA, that a large area is held collectively with just a handful of countries in the Americas and that in most countries of the 25 countries which have allowed one GM crop or the other, the area under GM cultivation is quite negligible. It is important to underscore and analyse this argument around "How much transgenic crops" since it is important to acknowledge that a vast majority of countries around the world have not gone in for GM crop cultivation including for reasons related to biosafety concerns around this technology.
A section on "Regulatory System" follows the one on approval and adoption of transgenic crops worldwide so far. This brief section presents a bland overview of the existing regulatory regime in India without any acknowledgement of the shortcomings or improvements possible.
A subsequent section on "World Food Requirement" enunciates oft-repeated Malthusian arguments around how food production has to improve through productivity increases and by how much and concludes that judicious use of agricultural biotechnology is called for in this context. A fundamental problem with this conclusion is that it assumes that transgenics (agri biotech is what is mentioned but transgenics is what is actually discussed) would increase production and productivity without going into either scientific evidence on this or ground level experience over the years.
Fate of transferred DNA - discounts studies on non-specificity of action of the new toxins including only on particular types of insects or phenomenon like horizontal gene transfer or with the process of transformation itself. The section on 'Generation of recombinant viruses' is also superficial and ignores some scientific evidence on this front. In fact, the one study that is cited here by the report actually is pointing to unexpected outcomes of virus infestation on silencing the viral promoter in a GM plant! A study (Wintermantel and Schloez, 1996) that shows that such viral recombination possibilities might exist is not cited.
On antibiotic resistance, it concludes that in one study, there was no transfer of antibiotic resistance to gut bacteria. However, there are other studies which show that HGT is a distinct possibility! The report suggests ways of utilizing newer techniques and products to overcome the shortcoming of using an antibiotic resistance marker gene.
On implications for biodiversity: the phenomenon of mono-cultures is acknowledged as a problem and conservation of varieties in gene banks is advocated, which many farm activists point out is not the answer! "Transgene could contribute to loss of biodiversity when it enhances invasiveness or susceptibility of target species through pollen flow", the report admits. But such gene flow is not unique to transgenic crops, it goes on to say. The recent report on GM canola establishment and persistence in the USA in the wild (August 2010), including the discovery of plants with "stacked traits" (single individuals with both traits), even though canola varieties with multiple transgenic traits have not yet been released commercially is worth mentioning here. Further, the analysis of Prof David Andow of the Bt Brinjal Environmental Risk Assessment is worth mentioning here. It is apparent that on the biodiversity implications, the Academies decided to discount any concerns since they decided to take an 'approach' that said that GM crops are not any different from other conventional crops.
On Insect resistance development, the report deals initially with an acknowledgement of the problem; however, this is followed by some more techno-centric recommendations for refuge and stacked genes etc., and some recommendations at the molecular level. It is interesting to note that there is a discounting of the fact that pest management is possible without technologies like synthetic pesticides and Bt crops which end up putting pressure on pest population to select for resistance and that approaches like NPM can actually control pests without resorting to killing each pest. Further, Bt crops are an anti-thesis in many ways to IPM approaches though the report argues for looking at this technology as part of an IPM approach.
On food safety issues, the report speaks in support of the existing safety protocols which are based on the principle of substantial equivalence while ignoring the critiques of this approach.
The conclusions, quaintly called as "Summary", in general are wishy-washy and have some broad conclusions which are questionable. The recommendations do not merit much response, given that the 'approach' itself is faulty and also given the contradictions between findings and recommendations.
This inter-academy report, even in its updated version, does not add to the credibility of the processes that the Academies chose to run or the actual report. The shoddy, biased and unscientific nature of the earlier report has not been addressed in any way and the author feels that the Academies have lost an opportunity to show themselves in a rigorous, independent light in front of Indian citizens by this hasty, foregone-in-its-conclusions product.