The document discusses several concerns regarding GM crops in India based on the experience with Bt cotton. It notes that the genetic transformation process is imprecise and that the regulatory system for GM crops needs to be more transparent and accountable. It also summarizes various studies that have found unintended effects of Bt cotton on soil health, animal health, pest resistance development, and pesticide usage. The document calls for assessing the relevance and impacts of GM technologies in India more rigorously before further commercial approvals.

1. Concerns on GM crops
learning from Bt cotton
Ramanjaneyulu
Centre for Sustainable Agriculture

2. Decisions on GM crops
• Environmental Risk Assessment: The process of Genetic transformation
is imprecise hence needs a relevant risk assessment frame work based
on the ecological and socio-economic conditions of adoption.
• Relevance of technology: India being a country of small farmers and
small farms, the relevance of the technology should be assessed in the
conditions and against the available best technologies.
• Transparent and Accountable Regulatory system: The processes
adopted by the regulatory system should be transparent and
accountable for the decisions being taken in assessing the potential risks.
• Socio-Economic Impact: The socio-economic impact of any technology
should be assessed in specific context. This impact assessment should
also include the impacts of seed prices and the IPRs involved.

3. GE is imprecise
“Cut & Paste” - Insertion of alien genes for
creating specific traits
One gene = one trait expression?
Gene regulation within genome not fully
understood or replicable
Transgene insertion – the process & the
transgene – changes & associated risks
Transgene location - can’t be directed and is
unstable
Unexpected and unintended traits - Coding
for proteins of unknown functions discovered

4. GE Science: Unintended consequences
Alterations to the toxicity or nutritional value of a
cultivar – allergens, toxins, vitamins, anti-oxidants
etc. (food safety)
Changes that have ecological implications –
BIODIVERSITY, increased outcrossing, effects on
beneficial insects, soil organisms, pest resurgence,
new diseases etc.
Changes that have implications for food security –
stress intolerance & crop failures

5. Learning from experiences
BT COTTON IN INDIA
2002 to 2012

6. Soil Health
 Farmers in AP, Karnataka, Punjab
reporting yield decrease in crop
grown after Bt cotton
 Several complaints
 Recent paper from IARI Sarkar. et.al,
2008 Transgenic Bt -Cotton Affects
Enzyme Activity and Nutrient
Availability in a Sub-Tropical Inceptisol
J. Agronomy & Crop Science (2008) ISSN 0931-2250
• similar studies from Australia and
China
• Susceptibility to drought and heavy
rains
• Planning commission report on
Vidharba says ‘Bt cotton not suitable
for rainfed areas’

7. Life of Bt crops: Resistant development
• Bt technology works similar to
pesticides
• Toxin present all through the
life of the plant hence
resistance development is
faster
• Government conditionality on
maintaining ‘refuge crop’-
responsibility of the company
• Monsanto already declared
that Pink bollworm developed
resistance.

8. Animal morbidity
 Sheep, goat and cattle morbidity reported from
AP, Maharashtra, Punjab, Haryana after feeding
on bt cotton
 Miscarriages reported from Gujarat
 2007: Animal Husbandry Department of AP asks
farmers not to graze animals on Bt Cotton – “as
yet unidentified toxin” causing morbidity
 AP government writes to centre not to permit
the Bt cotton till proven safe
 GEAC was asked to take up a study they no
followup
 Biosafety data on Bt brinjal shows possible
problems
Sheep/Goats/Cattle reported to have
• Anorexia, nasal discharge, cold, cough,
• respiratory distress (in some cases)
• Occasionally red urine
• No Fever

9. Animal Husbandry Dept.’s Advisory
Media Announcement
It has come to our notice that in several blocks of the district,
animals are falling sick after grazing on Bt Cotton fields. After
harvesting cotton completely from the fields, there is a long
tradition in the district of grazing animals in those cotton
fields. However, because Bt Cotton is being grown in large
tracts and because of a yet-unidentified toxic material in
these plants, it has come to our notice that animals which are
grazing on these fields are exhibiting symptoms like shivers,
convulsions, running nose, bloat, bloody diarrhea etc., and
are dying. Therefore, we appeal to farmers not to graze their
animals on Bt Cotton fields. We request farmer brethren to
please do approach the nearest veterinary doctor and get
treatment, if any animal has grazed on such fields accidentally.
Sd/- M Venkataswamy
Joint Director
Animal Husbandry Dept
Adilabad.

10. Dept of Agri Biotechnology, ANGRAU to VBRI
– 10/7/06

11. Dept of Agri Biotechnology, ANGRAU to VBRI – 10/7/06

12. Letter to GEAC from AH Dept Director, AP
Govt. on 9/5/2007

13. Human health
 Skin allergies reported by farmers
and agriculture workers while
working in cotton fields during boll
burst stage
 2005: JSA – Bt Cotton in India –
human allergies
[Ashish Gupta, Ashish Mandloi &
Amulya Nidhi, 2005: “An Investigation
report on Impact of Bt Cotton on
farmers’ health”]
 2007: Dr Manvir Gupta’s pilot study
in Punjab

14. Ecological Balance disturbed: increasing pests and diseases
New diseases
Sucking pests

15. Studies on Resistance management
• Genetic Engineering Appraisal Committee (GEAC) had imposed refugia conditions
(http://envfor.nic.in/divisions/csurv/btcotton/bgnote.pdf). But, the conditions were put
without any basis. For example the refuge strategy should be developed only after
considering
– the recessive/dominance factor of resistance
– the initial frequency of the resistant allele and
– the mating behavior of the insect moth. In addition differential plans based on whether
refuge crop is sprayed or unsprayed were never mentioned.
• Fakruddin et al (2002) of Dept. of Biotchnology, UAS, Dharwad and Dept. of Entomology,
Collage of Agriculture, Raichur revealed the resistance of H.armigera to Cry1Ac toxin in 11
distinct geographic populations representing the entire South Indian Cotton Ecosystem.
• Kranthi et.al, (2005) reported that the quantitative levels of Cry1Ac and the seasonal decline
in expression differed significantly among the eight commercial Bollgard hybrids tested.
• Ranjith et.al (2010) has established that the bollworm, the major cotton pest in India is not
only thriving on both the single gene Bt cotton( Cry1Ac) and the double gene Bt cotton
(Cry1Ac & Cry2Ab). The authors said that it has been demonstrated that the bollworms not
only survive after feeding on Bt cotton plants, they are able to complete their lifecycle and
reproduce and create the next generation of resistant pests.

16. Resistance development
• Resistance to Pink Bollworm: In March 2010 Monsanto India
admitted in a press release that Bollgard1, the Bt cotton with the
single protein Cry1Ac, has developed resistance to pink
bollworm(Pectinophora gossypiella). Resistance was confirmed in
four districts in Gujarat - Amreli, Bhavnagar, Junagarh and Rajkot.
• The resistance development in bollgard also has an implication on
other varieties and hybrids being developed by public sector
institutions in cotton and other crops as well using the same/similar
genes.
• The issues of resistance was not discussed either by the company or
CICR (which is supposed to have reported on resistance every year)
or GEAC (which is supposed to have reviewed the reports) during Bt
Brinjal consultations; this clearly amounts to withholding of
information.

17. Pesticide usage remains high

18. Pesticide Usage, Pest Resistance, New Pests
• At farmer level, pesticide usage drops in first two years
but rises back to pre-Bt level
• Increased use of low-volume pesticides which require a
much smaller quantity per acre.
• Monsanto says bollworm becomes resistant to Bollgard-I
• Resistance monitoring studies done at CICR have
demonstrated bollworm resistant
• Emergence of secondary pests: susceptibility to sucking
pests, mealy bugs, whiteflies and miscellaneous insects
• Pesticide expenditure increases: From Rs 597 crore in
2002 to Rs 791 crore in 2009”.

19. Increase in Cotton Yield: The Full Picture
700
Pre-Bt Cotton Period During Bt Cotton Period 140%
600
70% Increase Only 2% Increase
554
521 524 517 120%
503
500 470 472 481
90% 100%
399 84% 85% 85%
400
80%
308 302 62%
300 278
60%
41%
200 40%
18%
100 20%
6%
0% 0% 0% 1%
0 0%
Data for % area under BT for 2010-11 and 2011-12 are estimates
and for 2005-06 is interpolated Yield in kgs per hectare % area under BT

20. Reality of Cotton Yields
• Maximum yield increase happened by 2004-05 when Bt
cotton was 5.67% of the total cotton area.
• In the Bt cotton period, no sustained yield improvement
• Dr. Keshav Kranti, Director CICR: “The main issue... is the
stagnation of productivity at an average of 500 kg lint per
ha for the past seven years... unaffected by the increase
in area of Bt cotton from 5.6% in 2004 to 85% in 2010.”
• Other factors improving the yield (ref Dr.Kranti):
– Increased use of better-yielding hybrids (from 40% to 85.5%)
– Expansion of irrigated area under cotton
– Bringing new lands under Bt cotton
– Years of better rainfall and low pest incidence

21. Some recent findings
• In an article in the June 2011 issue of the Journal of
Biosciences, ‘Detrimental effect of expression of Bt endotoxin Cry1Ac on in
vitro regeneration in vivo growth and development of tobacco and cotton
transgenics,' Delhi University scientists reported that the expression of
the Cry1Ac endotoxin has detrimental effects on the development of
transgenic plants. The plants that showed appreciable CryIAc expression
were phenotypically abnormal: they were malformed. This suggests
preferential selection is at work while transgenic plants mature: those that
express low level of Cry1Ac have better chances of coming through
compared with ones expressing appreciable levels of the gene
(http://www.ias.ac.in/jbiosci/jun2011/363.pdf).
• A recent study (2011) from Canada published in the Journal ‘Reproductive
Toxicology’ has shown that Bt proteins have survived the human digestive
system and passed into the blood supply and found in the unborn babies
(http://www.ncbi.nlm.nih.gov/pubmed/21338670).

22. Genetic Contamination inevitable
• Contamination of centres of genetic diversity. E.g.
Cotton, rice, brinjal –India is centre of origin/diversity
• Unsolicited gene transfer to farmers’/other varieties
• Co-existence not possible: e.g organic cotton in
India, LL rice in US, Maize in CIMMYT

23. What happened with Bt Bikeneri Narma?
• IPRs related to the event never studied
• The event BNLA-106 was reported to have been contaminated with
Mon-531 event
• 2005: this was communicated to the then Director of CICR
• 4th-5th May, 2008: After commercial approval by GEAC samples were
sent for testing to Awasthagen which confirmed presence of Mon-
531 in eight of the samples
• 21st May, 2008: a meeting chaired by DDG (crop sciences) concluded
that ‘possible presence of Mon-531 is not an issue any more
because of the strong molecular evidence produced by Dr. Anand
Kumar, NRCPB
• 2009: MAHABEEJ reported that the BN Bt seed was not pure with
respect to several traits including Cry1Ac
• December 2009: Meeting chaired by DDG (CS) decides to stop
production and commercial sale of BN Bt and Bt NHH-44

24. Monopolyzing market
• Spread often is not measure of success
• 11.0 mha, ranks second in the world in production and first in area
• In $ 1 billion cotton seed market occupies 60 % by value
• Monopolising markets: 95 % controlled by one company
– Seed prices increased from Rs. 450/packet to Rs. 1800/packet. Bt
Brinjal was priced at Rs. 50,000/kg
– AP govt MRTP case to reduce seed royalty reduced to Rs. 100/packet
– Seed companies questioned the state powers in court
 Public sector withdrawl
– More than 100 cotton varieties/hybrids were denotified. Last three
years not even 1 kg of seed is sold by any organisation across the
country
– Non Bt cotton seed withdrawn from market both by public and
private sector

25. Other important issues
• Relevance of technology and crop choices
• Testing against the best pratices
• Open air Field trials permitted before
biosafety tests are done
• Agronomic trails are not comparing against
the best practices
• Conflicts of interest and Corruption

26. So what we request
• Relevance of a particular technology in particular crops should be
assessed first before giving permission for any GM research in the
country.
• The biosafety testing protocols needs to be revised as suggested by
Dr. Pushpa Bhargava to ensure long term safety
• Ban all the GM field trails till all the systems are put in place and
also allow open field trails only after the appropriate biosafety tests
are done
• Field trials for agronomic evaluation should be made against the
best possible alternatives for the problem for which GM technology
is used and after assessing the socio economic and ecological
impact of the technology.
• Suggest moratorium of at least 10 years on commercial release of
all GM crops till all the systems are in place for independent
research and regulation