Submission to parliamentary committee on agriculture regarding GM crops

Memorandum to the Committee on Agriculture with views on “Cultivation of Genetically Modified Food Crops – Prospects and Effects”. Presented at the sitting of the Committee on October 19, 2010 by Sunita Narain, director of Centre for Science and Environment

Published: Friday 10 August 2012

The issue of genetically modified food crops, must be considered in terms of India’s ability to regulate new technologies, the credibility of the scientific system that allows the use of these new technologies and most importantly, the issues of price and control of new technologies that take agricultural decisions out of the hands of farmers.

  Sunita Narain dealt with the following key concerns in her submission: 

  1. The case of Bt-brinjal: the need for credibility of public science to work for public good
  2. GM crops: scientific research will have to be publicly funded to do public research for public interest
  3. GM crops need a strong regulatory and liability regime
  4. GM crops need the right of consumers to decide
  5. GM crops need systems to keep seeds out of control of companies
  6. GM food crops evaluation in term of yield and productivity
  7. GM food crops need to be assessed in terms of implications for the cost of agriculture and if ‘affordability’ of food will be compromised

1. The case of Bt-brinjal: the need for credibility of public science to work for public good

Bt-brinjal was being introduced without any recognition that this was the first time the world would introduce GM technology for a vegetable of near daily use, eaten in all our homes, often uncooked. Currently most other GM crops used widely across the world are either eaten in processed form (soya) or used after industrial refining (corn or rapeseed oil). Therefore, in this case, simplistic correlations—that genetically modified crops are safe, or known to be so—should not have been applied.

There are still questions regarding the scientific tests done to establish the safety of this gene-modified vegetable on our health. There are two issues that need to be deliberated:

  • If enough has been done to study the chronic impact of eating this daily vegetable on our bodies and health?
  • Who has done these studies?

The studies by Monsanto-MAYCO – the owner company – show the bulk have looked at acute toxicity, a lethal dose 50 or more, a dose at which there would be mortality of 50 per cent or more. The company has also done studies on allergic reactions and skin irritation. On the other hand, studies on sub-chronic toxicity are few – 90 days on rats, rabbits and goats. The question that then emerges is: are the studies good enough to understand the long-term impacts of ingesting Bt-brinjal? The company says yes, maintaining 90 rat days are roughly equivalent to 20-21 human years1.

The scientific community is however not convinced that these studies are adequate to prove the safety of Bt-brinjal. The recent report of the inter-academy panel shows how poor and misleading science can be in these cases. The report has been widely criticized for being poor in science – containing no references or attribution or even citations. It makes sweeping statements, unsubstantiated claims and even shockingly lifts material for global biotech industry.

This report runs contrary to another recent analysis on Bt-brinjal – by David Andow, from the department of entomology, University of Minnesota. This report suggests that in fact, the EE-1 transgene may be a second rate Bt-brinjal product. He also says that environmental risks have not been adequately evaluated, including the effect of gene-flow on biological diversity. He believes there is a risk to natural crossing between Bt-brinjal and wild species2.

There is the big issue if we as consumers can ‘trust’ the research? Is it impartial and credible? In this case, as in most, research has been conducted by Mahyco-Monsanto. There are also clear cases of conflict of interest among members of the Genetic Engineering Approvals Committee, with links to the biotech industry. Therefore, is this system credible enough for us to trust?

2. GM crops: scientific research will have to be publicly funded to do public research for public interest

The issue of GM crops raises fundamental concerns about how we structure and organize scientific research for public interest. Currently, all research is funded by companies and then presented to regulators for clearance. This leads to an enormous lack of credibility – people cannot believe what the companies say has been done. And, given the horrific and scandalous track record of private research misguiding policy in the case of drugs or food, why should this be surprising?

It is clear we need a new system: research must be publicly funded and openly scrutinized. The money must come from companies, but in the form of a tax/or cess, which is collected into a fund to pay for independent research. Without that, even good research will be tainted by bad public faith.

But this is contrary to what is happening in the country. Today, in fact, in the name of public-private partnerships, agribusiness companies are getting access to public research and public facilities. This will compromise the integrity and independence of public research further.

For instance, Rajasthan government is close to signing a memorandum with Monsanto, which gives this company access to research and scientific facilities and public infrastructure in all agricultural research universities and state seed corporations. How will this affect the independence of scientists when it comes to deciding upon future technologies?

This is a big issue of concern globally as well. In the US, for instance, lawyer, Robert Kennedy jr has written extensively about how corporations ‘work’ with scientists. Kennedy calls them ‘biostitutes’ — prostitutes to serve industrial interests and how this partnership between science and industry compromises public health. It is clear that new technologies like GM crops, which have serious implications for health and risk to the environment, will need science in the public interests. More importantly, it will need scientists without conflict of interest.

3. GM crops need a strong regulatory and liability regime

The lesson of Bhopal is that high-risk technologies also need liability regimes, which will safeguard public health. All such technologies must pay the real cost of their present and future dangers. Only then will we, as a society, try and understand the risks better. Only then will we, as a society, make better technology choices. More importantly, the issue of corporate liability is crucial for only then will powerful companies worry about the implications of their actions they take, today, on tomorrow’s generations. Today, they think of short term and run-away profits – in chemicals, GM foods, nuclear energy or mining and drilling in a ways where no one (or science) has ever gone. We need very tough corporate liability so that companies think twice before they expose us to dangers.

4. GM crops need the right of consumers to decide

India does not have a food labeling system to distinguish the GM food from other crops. Consumers have no choice but to eat this food. Furthermore, it is virtually impossible to set up a labeling system for a vegetable, in a country the size of India, where tests would have to be done on the farms of GM and non-GM crop growers.

Labeling of food also demands the country must have a laboratory network and a functioning regulatory system, so that GM-content can be analyzed and told to consumers. This is far from the set-up we have in the country. CSE, for instance, tried to get edible oil checked for GM traces but was turned away by most laboratories in India: they could not test or had limited facilities; the tests were prohibitively expensive or not possible. With Bt-Brinjal, therefore, arises the similar problem of wanting ‘modern’ technology without ‘modern’ facilities to ensure safety and regulation.

If the functioning of the Food Safety and Standards Authority is any indication then regulatory regimes in India, including what is being proposed for biotechnology are easily open to corporate capture. In this situation, can be allow high risk food to be introduced in the country?

5. GM crops need systems to keep seeds out of control of companies

There are unresolved and critical issues of the control of seeds in the hands of farmers with the introduction of such monopolized technologies. As in the case of Bt-cotton, there is little public research on varieties, rather than hybrids, where farmers can reuse the seeds.

There are also connected issues of price of seeds for farmers. Take the issue of genetically modified Bt cotton, where Andhra Pradesh and other state governments have been fighting a battle against monopolistic and exploitative pricing of seeds. In 2006, AP used the Essential Commodities Act (ECA) to slash the price of GM cotton seeds by more than half. Other states have followed this example. But in December 2006, the Union government quietly amended the ECA to exclude cotton seeds from the list of essential commodities. This enabled Mahyo and other multinational seed companies to challenge the states on their jurisdiction in fixing cotton seed prices. In 2007, in response, AP passed Act 29 to regulate the sale and price of cotton seeds. Gujarat passed an ordinance along the same lines. But the Union agriculture ministry has been working overtime to come to the rescue of multinationals. In 2009, it filed an affidavit in the Gujarat High Court saying “cotton seeds were out of the purview of any regulatory and quality control mechanisms” and “no administered control system should be introduced in the sale of seeds.”3

In this situation, what confidence can we have that the government will indeed protect the interests of farmers against powerful agri-business companies? In this situation can we really afford to introduce GM crops, where seeds are almost completely controlled by these same powerful companies?

6. GM food crops evaluation in term of yield and productivity

A recent report of the Union of Concerned Scientists in the US has evaluated the productivity and yields of GM crops in their country. In the US, we know that GM soybean is grown on over 90 per cent of the cropped area under that crop; 63 per cent of the corn crop is GM. The report, which has carefully assessed the data on yields – both intrinsic and operational – has come to a damning conclusion. It finds, GE soya has not increased yield and GE corn has increased yield only marginally on a crop-wide basis. The increase in yield – substantial over the last 15 years – has not been the result of GE traits but because of traditional breeding or improvements of other agricultural practices.4

This research needs to be carefully done in India has well, where our basic reasoning for introducing GM food crops is improvement in productivity and yields. It is also important to evaluate this in terms of continuous productivity increases and evidence suggests that pest resistance grows and that these crops are also susceptible to changes in monsoon and other factors.

7. GM food crops need to be assessed in terms of implications for the cost of agriculture and if ‘affordability’ of food will be compromised

It is time policy-makers recognized two critical facts. One, that growing food will cost money and two, that we in India cannot afford expensive ways of growing food. If the western world has flooded the food market, it is not because their ways of farming are more efficient or their farmers are more learned, but because their governments pay obscene amounts as subsidy to underwrite the costs of growing food. The European Union doles out US $51 billion each year to its farmers to keep them in the market. European sugar farmers—whose produce our government imports often—are paid four times the world market price. Then the surplus is dumped in world market using an additional US $1 billion in export subsidy, which depresses global prices. The situation in the corporate-run US farms is similar.

In India, policy must be designed to increase the minimum support price so that farmers are paid for the costs they incur.

Today farmers invest huge amounts of private capital into building the infrastructure for their operations unlike any private company or industry. They pay for building irrigation facilities—more than half the irrigated land is groundwater irrigated. Some 19 million wells and tubewells have been built with private capital. This cost must also be accounted for in the food bill.

But as yet, policy has been caught between a rock and a hard place. On one side are poor farmers who need to be paid for growing food. On the other side are vast numbers (also farmers) who cannot afford the price of that food. As yet, the policy has been to subsidise food, not pay farmers. The public distribution system is designed to buy vast quantities of food grain and supply it to people. It depends on keeping the price of procurement as low as possible. That’s what the minimum support price is all about. But India will have to design policies to pay farmers the real cost of growing food.

The challenge of reaching cheap food to vast numbers still remains. That’s why the policy must recognize the need to cut the cost of growing food as well. As yet, we are obsessed with crop yields, not realizing that high-input agriculture is based on just one principle: increased cost of production. This can work where consumers are affluent enough to pay the price or governments are rich enough to subsidize farmers. It will not work in India.

India has to find ways of valuing agriculture, which is low-input but gives relatively low yields. It is here that policy must be innovative. We must invest big time in marginal agriculture. This means doing watershed development to recharge groundwater and decentralized water harvesting to improve irrigation. This also means better seeds and procurement of locally grown food at good prices for food distribution programmes. This will build local food sufficiency.

It is in this context that India must evaluate the introduction of GM food crops. Even if GM increases productivity (which itself is questionable), the issue is at what cost does it do so? Will farmers be able to get the price of their produce, if the cost of inputs increases? On the one hand, there is the need for ‘affordable’ food for feeding vast numbers of people in the country. On the other hand, there is the international trade, where the rich countries continue to subsidise their farmers, depressing and distorting the price of food.

These factors must all play a role in our decision to introduce GM or not. It is not a simple matter of a technology. This is a matter that concerns our food and our future.

1Anon 2009, Report of the Expert Committee (EC-II) on Bt Brinjal Event EE-1, Submitted to GEAC, Ministry of Environment and Forests, New Delhi, October, mimeo

2Latha Jishnu 2010, Sham Science in Down To Earth, October 16-31,

3Latha Jishnu 2010, Seeds of Strife in Down To Earth, August 16-31

4Doug Gurian-Sherman 2009, Failure to yield: Evaluating the performance of genetically engineered crops, Union of Concerned Scientists, MA







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