Field Trials of GMOs – a story of violations of, and blatant disregard towards Biosafety
The story of open air trials of GMOs in India is a story of blatant violations of biosafety norms, disregarding of federal polity, unscientific protocols and permissions, hasty approvals, lack of monitoring abilities, general apathy towards the hazards of contamination and other issues, lack of institutional oversight mechanisms, no liability clauses ever invoked when there are violations etc. etc.
Here, we sum up some of the main issues with regard to such open air field trials, with a constant threat of contamination looming large over our food, seeds and environment. Remember, such trials, whatever name they come with, are the first time that the GMOs are released into the environment and brought out from contained conditions. This means that this is where the uncontrollable and irreversible part to this living technology begins.
* There is no Policy Directive being utilised on when some applications for transgenics will be entertained, what crops and which regions need to be striclty kept outside of any kind of transgenic research and release as recommended by the Task Force on Agricultural Biotechnology. Almost all applications for Field trials are permitted without any discretion. GEAC mainly acts as a Clearing House, even though it has been renamed as Genetic Engineering Appraisal Committee (from being Genetic Engineering Approval Committee earlier).
This is what the aforementioned Task Force had to say about transgenics:
Report of Task Force on Agri-Biotech (headed by Dr M S Swaminathan, the recommendations of which were accepted by the Ministry of Agriculture in 2004 and the report available here).
Chapter II. Application of Biotechnology in Agriculture – Point 1.6:
- Biotech applications, which do not involve transgenics such as biopesticides, biofertilizers and bio-remediation agents, should be accorded high priority. They will help to enforce productivity in organic farming areas
- Transgenic approach should be considered as complimentary and resorted to when other options to achieve the desired objectives are either not available or not feasible
- Transgenic research should not be undertaken in crops/commodities where our international trade may be affected
- Such areas of biotechnological applications, which can reduce employment and impinge on the livelihood of rural families, should be avoided. (4. Choice of Research Problems)
This report also cautioned against transgenics in crops for which we are the Centre of Origin/Diversity. Mega- biodiversity centers and hot spots of agro-biodiversity viz., Western and Eastern Ghats and NE Region should also be preserved, as per the report.
However, in India, all applications for transgenics are entertained by our regulators acting as a Clearing House.
* Biosafety assessments and open air release happen simultaneously, thereby releasing potentially risky organisms into the environment before any risk assessment is done. Untested and unknown organisms are what get released in each of these field trials, essentially.
* No review of Biosafety data is taken up after the first level of Field trials and before the second level of field trials start.
* Field trials are being permitted in ecologically sensitive regions. For eg. Western Ghats. Field trials have been permitted in close proximity of invaluable germ plasm collections like the rich rice collection in IGKVV, Raipur. Similarly, in several agricultural university campuses, where a variety of germplasm is preserved and maintained, field trials are being permitted.
* While Field trials are also used for assessing agronomic benefits, comparisons with best available technology is not done. For ex. transgenic pest resistant crop are not compared with NPM practices.The very evaluation or assessment framework is faulty. Further, often times, field trials are documented to have been planted in the wrong season and the wrong location whereby the results are not to be relied upon. It was also found in civil society investigations that crop developers abandon failed fields during the field trials, to come up with better averages!
* Monitoring is no one’s baby, mostly done by the crop developers themselves, a case of conflicting interests. It has been documented that if at all monitoring teams do visit field trials, it is not rigorously or randomly done. The visit is organised by the crop developer to the location they choose, at a time that they want! In any case, no monitoring reports exist of field trials in the public domain and civil society investigations have shown that no such monitoring takes place in the first instance. GEAC has been caught in the past unaware of whether a trial has even been planted or not, and if yes, where!
* Field trial permissions are being given for 2 years/season in one go these days. In recent meetings, GEAC had accorded permissions for field trials in sites presenting “multiple choice” to crop developers, in addition to giving one-time permission for trials upto 2013!
* Although there is a direction from the Supreme Court that GEAC needs to give approvals for all environmental releases of GM crops including Field Trials as per the EPA 1989 Rules, to this date RCGM under DBT gives permission letters. GEAC rubber-stamps RCGM recommendations for Field trials.
* There is a complete absence of a liability regime that will act as a deterrent for violations & contraventions by GM crop developers or even the regulators.
* No assessments of contamination are done after the Field Trials.
* SBCCs (as laid down in the EPA 1989 Rules) have not been formed in many states like Bihar where FTs have happened. DLCs almost completely absent; SBCCs & DLCs non- functional.
* The local panchayats/gram sabhas are not consulted for a prior informed consent about Field trials.
* Biosafety violations have been found repeatedly in field trials – isolation distance not always maintained – Kolhapur maize trial; Guntur Bt okra trial; Jharkhand Bt rice trial; West Bengal trials.
* Regular contamination has been happening of food/supply chain from such field trials: Even during Bt cotton field trials (RFSTE findings); later, with Bt brinjal and Bt okra (CSA findings). Volunteer plants tested positive in Jharkhand (Gene Campaign’s lab testing for Bt rice).
* No destruction of GM material as prescribed. (recent violations in a Monsanto GM maize plot in Bijapur, for eg.)
* Information on trial not given to farmers, Panchayat or State Govt. (in AP, WB, Bihar, Chattisgarh)
* There have been instances of planting before permission is issued…(Andhra Pradesh…)…
* Data collection is not as per prescribed norms/frequency as has been seen in the case of Bt brinjal trials, as acknowledged by the Expert Committee I.
* In the case of GM rubber trials permitted in Kerala and Maharashtra (in bio-diverse and eco-fragile regions), the same terms and conditions as annual/seasonal crops were prescribed as the protocol in a “copy and paste” job reflective of the regulators’ untrustworthiness!!…