25 REASONS TO SAY NO TO GM MUSTARD
Do you remember how
citizens collectively ensured that GMOs (Genetically Modified Organisms) like
Bt brinjal, which are unneeded, unwanted and unsafe, do not enter our food plates
or our farms back in 2010? That was when the Government of India placed an
indefinite moratorium on the release of this Bt brinjal, a GM food crop, taking
cognizance of the many reasons why it should not be allowed for commercial
cultivation. Back then, the government said it was placing the GMO on an
indefinite moratorium being “responsive
to society and responsible to science”. Further, 15 years of Bt cotton
cultivation in India exposed the hype and lies around this GMO too – the insect
for which Bt cotton has been created has developed resistance, and farmers are
using more pesticides than ever before on cotton crop in the country. We have
also seen how one Multi-National Corporation – Monsanto – has gained a
monopolistic control over the cotton seed market in the country. And farmer
suicides continue unabated in the country, most of which are by (Bt) cotton
farmers.
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| GM Mustard field |
The ostensible reason for
creating this GMO and seeking its approval is yield increase. In reality, there
are existing non-GM options for improving yields, including by creating hybrids
based on non-GM “CMS technology”. In many countries of the world, it is CMS
hybrids which have been contributing to yield growth. The real reason is to
make the job of seed manufacturers easy, combined with the use of herbicide
technology. What is more unacceptable is that it is one set of scientists who
are not part of the mainstream agricultural research systems, who want to use
their own exclusive CMS lines, who are expressing their constraints with that
CMS (ignoring other possibilities that exist for all public sector scientists)
and opting for GM technology in developing these mustard GMOs.
The applicants show that through
genetic engineering and insertion of bacterial genes into mustard plant, male
sterility (barnase gene), can be
introduced into selected varieties which will then prevent self-pollination. This
then gives an opportunity to create hybrids by crossing this male sterile
(female) line with selected (male) lines. The male line also has bacterial gene
(barstar) introduced, to restore
fertility in the offspring produced by crossing the male sterile lines with the
male lines. Offspring between these two parents can bring “Hybrid vigour
(heterosis)” into the progeny. Of serious concern is the fact that a herbicide
tolerant gene called bar (which is
also sourced from another bacteria) has also been tightly clubbed with both
barnase and barstar genes in each parental line - which will then be inherited
by the hybrid offspring - in this genetic engineering experiment. This opens up
the possibility for herbicide use as the GM mustard would be herbicide tolerant
(HT).
It is said that more than
100 crores of taxpayers’ funds have been spent to develop and test these GMOs,
with funding to CGMCP from National Dairy Development Board (NDDB) and
Department of Biotechnology (DBT) in the Ministry of Science & Technology.
Ironically, the NDDB has wound up its edible oil business related to Dhara
brand and has stopped its funding to the project now, while citizens have been
kept in the dark about taxpayers’ funds being used for thrusting a GM food crop
onto them.
Here, we give you 25
reasons why you should say NO to Delhi University’s GM mustard and to ensure
that Indians are not made lab rats in an irresponsible and irreversible
experiment unleashed on them.
1. Transgenic technology is unsafe:
Genetic Engineering is an unnatural and imprecise breeding technology with
living organisms, and there is enough evidence that it is an unstable, unpredictable,
irreversible and uncontrollable technology being deployed in our food and
farming systems. This then has implications for our health and environment. Further,
increased riskiness in agriculture, lack of choices for farmers and consumers,
market rejection are all consequences of the environmental release of GMOs.
More on the adverse impacts of GM crops/foods is available as a compilation of
scientific papers at: http://indiagminfo.org/?p=657
2. GM HT crops cause numerous adverse
impacts, for farmers, agri-workers and consumers: Herbicide Tolerant GM crops like the
current GM mustard result in numerous adverse impacts. These include health
impacts including from the use of chemical herbicides. For instance,
glyphosate, a widely used herbicide whose use has increased manifold after
glyphosate-tolerant GM crops have been introduced on a large scale in countries
like US, Canada, Brazil etc., was classified as a probable human carcinogen by WHO in early 2015, after decades of claims
by promoters that it is a safe product. Rapid emergence of “Super-Weeds” (weeds that cannot be killed by herbicides anymore)
has been well documented. Impacts on
non-target organisms and also on soil
health are well-documented. It is also important to note that in countries
like India where the largest number of female workers in the economy earn their
livelihood mainly by manual de-weeding of “weeds”, use of herbicides and HT crops will displace women from their
existing livelihood opportunities without alternatives being available.
Weeds are also not always plants to be destroyed, but are food and fodder as
well as medicines in many cases. Bringing in herbicide-based GM crops will also
discourage the use of mixed-cropping
as non-GM HT crops will be destroyed by the herbicide sprays on the main crop.
Mixed cropping and agro-diversity are particularly valuable in sustaining our
natural resources in the age of climate change. It is also important to note
that one of the leading causes for litigation between farmers in countries like
the US is supposed to be damage caused to neighboring crops due to herbicide
drift. Given our smallholdings in India, such damage to neighboring crops is a distinct possibility here too. HT
crops also mean greater chemical
residues in consumer food.
3. GM mustard is a back door entry for HT
crops: All these 3 GMOs
that Delhi University scientists have applied for, are herbicide-tolerant.
Shockingly, other than reveal that the bar
gene has been put into all 3 GMOs as a herbicide-resistant marker gene, the GMO
application does not declare the crops as being herbicide-tolerant. Nor has the
risk assessment been taken up as in the case of risk assessment that should be
done for HT crops which recognizes risks from the genetic engineering process
as well as from the increased use of herbicides, and any “combination” effects as
well! The intentions of the DU scientists to introduce HT crops are evident
from their published papers and to present this crop only as a high-yielding
transgenic crop and not a HT crop is intentionally misleading. We are aware
that many HT crops including of many MNCs are waiting to get a green signal and
GM mustard is a ploy to make their entry easier. It is appropriate to mention
that many GM patents are held by world’s largest pesticide companies, and
promoting herbicides is certainly intrinsic to their profitability. It
therefore does not matter whether the seed is developed by a public sector
institution or a private company, as it will inevitably increase herbicide use.
4. GM mustard yield increase claims are
wrong & unverified: There is ample evidence already put
out in the public domain that the testing of GM mustard was deliberately designed to create favorable
results for DMH-11, to the point of violating decisions taken by regulators
in their meetings, and violating
conditions imposed in the permission letter for trials. Convenient
protocols were adopted by the applicants to compare GM mustard with very old low
yielding varieties, instead of comparing it with other hybrids. They could
consequently show that GM mustard yields upto 28% higher than what it has been
compared with. It is now well established that wrong “Checks” were used to make GM mustard look good. Its yield increase claims can thuse be
described as rigged and wrong. If such yield increases are only against
parental lines, it can only prove a point around “hybrid vigour” or “heterosis”
and nothing more. There is nothing additional here for farmers or consumers.
There are several non-GM hybrids as well as well-performing latest release
varieties already available in the market in India for farmers, and this GM
mustard is unverified against these hybrids and varieties for its yield claims.
5. Release of high yielders
non-significant in their contribution to increase production of oilseeds and
reduce oil import: The applicants of this GM mustard claim
that approval for their transgenics will lead to increase in India’s yields and
production of rapeseed mustard and will thereby bring down the country’s edible
oil import bill. However, official records show that release of hybrids into
the market has not resulted in either production increases or in import bill
declines. The simplistic and exaggerated benefit claims lie hollow in the face
of such evidence.
6. DU’s GM Mustard must be rejected as the
grounds for rejecting Bayer’s GM mustard by Indian regulators in 2002 remain
valid here and now too: In 2002, a similar GM Mustard, with
bar, barnase and barstar genes, was rejected by Indian regulators when Bayer’s
subsidiary ProAgro sought a commercial cultivation approval for the same on
several grounds: the ICAR (Indian Council of Agricultural Research) declared
that it was not satisfied with the testing that the GMO underwent and the
results. It was also noted there was no safety testing on mustard as a
vegetable (it is not just an oilseed – seeds and leaves are directly consumed
in our food). Regulators also could not answer questions around how to regulate
the spread of GM mustard to regions where it is not needed. Most importantly,
it was acknowledged that ProAgro’s mustard was a herbicide tolerant mustard. Though
the crop developer kept saying that herbicide tolerance was only used as a
marker technology and that was not the primary reason for commercialization of
the GM mustard, the regulators rightly recognized that it would still be a
problem since end-use regulation of illegal herbicide use on this GMO would be
impossible. All these reasons apply equally with DU’s GM mustard!
7. This GM mustard is a Trojan Horse for
other GMOs: This GM mustard is being pushed by GM lobbyists as a
public sector GMO to create an aura of acceptability. It is as though when it
comes to biosafety, public sector GMOs will automatically become safer than
private sector GMOs! Public sector GMOs are in fact as unsafe as private sector
GMOs. Moreover, the developers can eventually assign the patents to anyone,
including profiteering MNCs. Given huge public opposition to GMOs in our food
and farming, it is apparent that corporations like Monsanto which were far
ahead in the regulatory pipeline with their products like GM maize have
withheld their applications to allow this GM mustard to be approved first on
this “public sector” sentiment, so that there is easier entry for all other
GMOs in the pipeline. We must recognize DU’s GM mustard for what it is: a
Trojan horse!
8. This GM mustard will only benefit
agri-business profiteering: Currently, patents claiming the bar gene are mostly in the hands of
Bayer Crop Science, the German MNC (which is reportedly trying to buy up
Monsanto to become the world’s largest agri-inputs corporation). It is also
interesting to note that Glufosinate
ammonium, which is the herbicide to which GM mustard has been made tolerant
to, is mainly sold by Bayer in India. It is clear that this so-called public
sector GMO is hiding the fact that it is herbicide tolerant and is thereby
meant for benefiting corporations manufacturing/selling herbicides. It is also
apparent that even the technology is for facilitating ease of seed
manufacturing and not to benefit farmers or consumers. Farmers already have
non-GM mustard hybrids to choose from, for heterotic (yield) advantage.
9. State Governments, including leading
mustard-growing states, do not want even field trials; Farmers Unions,
Scientists and others have objected strongly against GM mustard:
Major mustard growing states in India like Rajasthan, Madhya Pradesh and
Haryana did not want even field trials of this GM mustard to take place in
their states. Other states like Gujarat, Bihar, Odisha, West Bengal etc., have
taken a policy stand not to allow GM food crop cultivation in their states (not
even field trials). In India, agriculture being a State Government subject as
per the Constitution, this is an important factor to consider when discussing
approvals related to GMOs. It was one of the main factors behind the Bt brinjal
moratorium too. It is clear that the Central government has no mechanism by
which it can prevent the entry of transgenic seeds into states which have a
policy against them. How can the federal spirit be upheld then, and wouldn’t a
decision by the Centre become unconstitutional if they insist on approving GM
mustard?
More
than 55 large and active farmer unions of the country have already put out
statements against GM mustard approval. Scores of scientists have written to
the government against permitting any release of GM mustard. Ordinary citizens
have been writing in the thousands to the government resisting the approval of
GM mustard. This itself should be a strong reason for rejecting GM mustard.
10. Male Sterility Trait could impact farm
livelihoods: It is seen that the barnase gene introduced through genetic engineering to induce male
sterility and the subsequent transmission of such sterility into GM mustard
hybrid will not be limited only to these lines. The male sterility trait will
also get expressed in the contaminated crop of neighboring non-GM mustard crop
when the non-GM farmer saves seed from her/his crop that has outcrossing from
the barnase-bar parent or barnase-barstar-bar hybrid. It is only natural to
expect that the GM mustard hybrid adopting farmer will go in for such a GM
hybrid season after season, impacting the farm saved seed of the neighboring
non-GM farmer on a continuous basis. The yields of the non-GM farmer could be
affected to an extent because of this contamination by the male sterility trait
and sooner or later, this farmer will be forced to turn to the market for
external seed. This is quite apart from such a need arising due to any
herbicide drift related damages of the neighbor’s non-GM crop. This then is a
scenario where more and more non-GM farmers will be compelled to adopt
externally sourced seed, affecting their seed sovereignty as well as diversity.
11. India is a Centre of Diversity for
Mustard: As was seen in the case of Brinjal, India happens to
be a Centre of Diversity for Mustard. There are scientists who argue that India
is the Centre of Origin too. Starting from the 2004 report of an Agriculture
Ministry’s Task Force led by Dr Swaminathan, to the 2013 report of a Supreme
Court Technical Expert Committee, there are clear recommendations against genetically
modifying those crops for which we are the Centre of Origin/Diversity. This was
one of the main reasons for the government’s moratorium on Bt brinjal. GM
contamination can destroy the rich genetic heritage of India’s mustard
diversity and bring in disastrous monocultures.
12. Containment of GM mustard impossible –
Contamination inevitable: Numerous instances from all over the
world, as well as the statements of the GM mustard crop developer himself, are
evidence that containment of this GM mustard will be impossible, and
contamination inevitable. Biological as well as physical contamination will be
the consequence from allowing this GM mustard into our farms. This then has
serious implications for organic farmers and their organic status, amongst
other issues like persistence, weediness, superweeds emerging etc. As much as
12 to 19% of the neighboring non-GM/organic crop could be contaminated
depending upon the level of outcrossing. It is worth noting that the Supreme
Court of India in its 2007 Orders in a Public Interest Litigation (WP 260/2005)
related to GMOs has instructed the government to prevent contamination,
including from field trials.
13. Organic Farming will be directly
impacted: Contamination will mean that certified organic farmers
will immediately lose their organic status. In fact, even mustard oilcake for
soil amendments will be affected, once GM mustard is approved, which will also
jeopardise the organic certification of a farmer.
14. Governments should not force their
citizens to eat GM food: By both contamination (through pollen
flow as well as physical admixtures), and by deliberate marketing practices, GM
seeds will spread rapidly till virtually no non-GM variety of the crop is
available. Given that there will be no segregation system which can keep GM
mustard separate and contained, away from other mustard, approval of GM mustard
or any such GMO will mean that consumers’ right to know what is in their food,
right to informed choices and right to safe food will be violated. They will be
left with no choices about whether they want to consume GM mustard or not. There
will also be no labeling possible and consumers will not be able to distinguish
which mustard is GM or non-GM, to exercise their choices. Similarly,
contamination will mean that farmers will be left with no choices either.
15. Genes used in GM Mustard make it a GURT
(Genetic Use Restriction Technology): Through the use of GE, a
barnase gene to confer male sterility has been inserted in one of the parental
lines of the GM mustard hybrid. India’s Protection of Plant Varieties &
Farmers’ Rights Act describes GURT as a technology that is injurious to the
life or health of human beings, animals or plants and the Act does not register
any such varieties. Meanwhile, the complete picture of IPRs on various genetic
materials and processes used in creating these 3 GMOs remains unclear. The
terms and conditions of any Material Transfer Agreements entered into, for the
R&D of GM mustard are not in the public domain.
16. Mustard is used in Ayurveda and GM
mustard’s impacts on Indian Systems of Medicine is unassessed:
Mustard is used both as food and medicine in Ayurveda. Mustard seeds and oil
are used singly as well as in various formulations for a variety of treatments.
The impact of GM mustard on such uses is unstudied and unclear.
17. GM mustard will impact honey bees and industry
adversely: Bees and other beneficial insects are major
pollinators and any adverse impact on them will eventually result in reduced
yields – of not just mustard but other crops too. This GM mustard has potential
adverse impacts on honey bees. Studies (sponsored by GM seed industry at that!)
from elsewhere indicate this. This will impact crop production in general and
also honey production. It is seen that honey industry is a sunrise industry in
India, and mustard is one of the major sources for Indian bee keepers. Bee
keeping with mustard creates a win-win situation by increasing yields of
mustard by about 20-25%, even as it supports honey production and additional
income for the beekeeper. However, GM mustard could result in adverse impacts
on honeybees, lower honey production, contaminated honey and export rejections
too. The impacts will be from transgenic pollen contamination as well as
herbicide residues in honey.
18. Opting for healthy oil consumption or
catering to increasing oil consumption?: The per capita oil
consumption in India has already crossed the per capita recommended oil intake.
While it may be true that a large proportion of poor population in the country
are not able to meet the per capita recommended dosage, the solution does not
lie in attempting to increase supplies to meet exponentially-growing demand,
but supplying healthy edible oil to poor households through the Public
Distribution System and discouraging the unhealthy overconsumption by other
sections.
19. GM mustard data shrouded in secrecy: The
so-called regulation of this transgenic mustard so far has been highly
secretive and opaque. It is unclear what the regulators are trying to hide, and
to protect whom. Test results have not been shared in public despite Supreme
Court and Central Information Commission Orders that require the regulators to
put out data for public scrutiny.
20. Testing of GM mustard deliberately
misleading, unscientific, inadequate and unreliable:
It is seen that several tests that are required to assess risks and impacts
have not been performed for this GM mustard. Further, in a narrow set of tests
that were taken up, study protocols and tools lack rigour. It is also seen that
test results indicate something and conclusions claim something else. In some
cases, data presented is unbelievable from an ecological viewpoint. Data
analysis is poor. The little analysis that was possible by independent experts,
based on limited access to information, already shows clearly that testing of
GM mustard has been deliberately misleading, unscientific, inadequate and unreliable.
21. Conflict of Interest reigns supreme:
It is seen that the regulatory decision-making body has not yet cleaned itself
of elements of conflict of interest with one member from the GM applicant team
also serving as a regulator in GEAC! It is also clear from information gathered,
including through RTI, that test protocols were prescribed by the crop
developers themselves. While crop developers claim that their tests were
undertaken and supervised by ICAR’s Directorate of Rapeseed Mustard Research (DRMR),
DRMR in an RTI reply disowned the same. In a secretive regulatory regime, with
rampant conflict of interest, with tests and test results apparently misleading
and unreliable, citizens cannot trust the regulators’ and applicants’ benefit
claims or safety certificates.
22. Supreme Court Technical Expert
Committee says NO: The matter of GM crops’ risk assessment
regime and environmental release is sub-judice in India. The Supreme Court is
yet to pronounce its views and orders on the recommendations given by the
Technical Expert Committee that it had set up in a Public Interest Litigation
on the subject. A majority report (5:1) of the independent experts of the TEC
(the dissenting note is from a scientist whose organization is financially
supported by the GM industry) has explicitly asked for a ban on Herbicide
Tolerant Crops in India, citing several reasons. This is not the first committee to have said
so. A Task Force set up by the Ministry of Agriculture had earlier recommended
the same. Further, the TEC report said NO to transgenics in crops for which we
are the Centre of Origin/Diversity.
23. No liability regime in place: This
application and other applications related to GMOs are being allowed to
progress by Indian regulators even in the absence of any liability regime,
which will take care of penalties, compensation and redressal for affected
parties and remediation where required. Since citizens and their environment will
bear the brunt of the adverse impacts of GMOs, it is essential to clearly
establish before any clearances are given, who will be responsible for the environmental
release of such GMOs. The regulators? The crop developers? The government?
Through what mechanisms and procedures, and under what clauses of which
statute?
24. This GM mustard is unneeded:
This risky new technology is being sought to be thrust on farmers and consumers
in the name of improving yields. However, just as there is evidence that yield
increases have actually not been established with this GMO, and that release of
even non-GM mustard hybrids has not changed the production scenario in any
appreciable way, there is also evidence that simple agronomic changes that
adopt the principles of System of Root Intensification (SRI) or System of Crop
Intensification (SCI) – being called as System of Mustard Intensification (SMI)
by some – can lead to significant yield improvements and alternatives such as
these need to be invested upon. Wasting 100 crore rupees of taxpayers’ funds on
hazardous unwanted technologies is unwarranted when effective and safer
technologies already exist.
25. India’s oilseeds production can indeed
be improved significantly, without transgenics:
Oilseeds production improvements require political commitment to begin with,
not a hazardous techno-fix. On the technical front, large scale promotion,
support and adoption of SMI as well as relay sowing in rice fallows of India, can
increase mustard production. Similarly, provision of emergency/protective
irrigation systems coupled with participatory water management at the community
level will improve and stabilize production of oilseed crops like groundnut and
soybean. On the policy front, export-import policies related to oilseeds and
edible oil should favour Indian producers for higher production to accrue, not
price them out; further, land use policies should incentivize cultivation of
oilseeds on larger areas; there is also a need to revise the price support and
procurement policies related to all oilseeds, to encourage farmers to grow
more. On the institutional front, plugging the last mile extension gaps with
the existing technologies should lead to significant production improvements.
If the Indian government is indeed keen on improving oilseeds production, all
these options should be explored seriously for sustainable results.
Conclusion: The
above are some important reasons why we need to resist the possibility of GM
mustard being approved in India, in whatever direct or indirect manner. It is
being said that the parental “events” will be approved while the hybrid GM mustard
application will be rejected. This is a spurious approach given that any
approval to the parents will only generate HT offspring, with all other reasons
above still remaining valid and unaddressed.
The
opposition to GMOS in our food and farming systems today stands vindicated with
Bt cotton and Bt brinjal experience in India. The lies and the hype of Bt
cotton stand exposed today, 15 short years after commercial cultivation was
permitted after the spread of illegal cultivation that the regulators could not
control. Cotton yields have stagnated, after growing in the most impressive
fashion in years when Bt cotton was not widespread in its cultivation.
Secondary pests have proliferated while bollworm has developed resistance.
Pesticide use has increased. India stands 31 out of 72 countries when it comes
to cotton yield, and 23 countries are ahead of us without the use of GM cotton. On Bt brinjal, the fresh analysis
taken up by the Supreme Court’s TEC shows us that the Government of India’s
decision to place the GMO on an indefinite moratorium was absolutely scientific
and correct. Concerned citizens are by now tired of this constant unscientific
push for GMOs, including by governments which have promised something else in
their Party Manifestos before elections!
While GM canola area is
declining globally in the recent past, Indian government is contemplating this
GMO’s commercialization! There is now conclusive evidence on the impact of
herbicides on our health and environment. Much more evidence has emerged in the
recent past, after the Bt brinjal moratorium in India, on the various adverse
impacts of GMOs on our food and environment. Meanwhile, no biosafety
information on this particular GM mustard has been put out in the public
domain, despite express Supreme Court and CIC orders to the regulators. In the
past, our regulators have compromised on testing related to public sector GMOs,
and there is nothing since then to instill greater confidence
about the regulatory regime and the regulators. It is for each of us to act to
keep our health and environment protected from unsafe, unwanted, unneeded and
risky technologies.
Say NO to this GM
Mustard. Say NO to GMOs in our food, farming and environment.
Let us ensure that
only farmer-controlled, safe, affordable and sustainable technologies are
promoted as real solutions in Indian agriculture.
YOU CAN SEND A
PETITION TO THE ENVIRONMENT MINISTER COMMUNICATING YOUR REJECTION OF GMOs IN
GENERAL AND GM MUSTARD IN PARTICULAR BY WRITING TO MOEFCC@NIC.IN.
Issued in Public Interest by the
Coalition for a GM-Free India.
Visit www.indiagminfo.org for more
information and a more detailed Briefing Paper on DU’s GM Mustard.
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