———- Forwarded message ———
From: GM Free India <indiagmfree@gmail.com>
Date: Thu, 5 Mar 2020 at 15:00
Subject: Inputs on Preparation and Formulation of Guidelines for Import of GM Animal Feed including DDGS
To: <ravis.prasad@nic.in>
Cc: <sricha@ias.nic.in>, <mefcc@gov.in>, <tk.kathula@nic.in>, Lalitha Gowda <lrgowda2k11@gmail.com>, Sachinandan De <sachinandan@gmail.com>, <sachinandan@ndri.res.in>, <sbakshi.fssai@gmail.com>, <sbakshi@fssai.gov.in>, <secyahd@nic.in>, <dir.ndri@gmail.com>, <giriraj.singh@sansad.nic.in>, <girirajbihari@gmail.com>, <office.sanjeevbalyan@gmail.com>




Shri Ravi S Prasad,


Genetic Engineering Appraisal Committee,

Ministry of Environment, Forest & Climate Change,

Government of India.


Date – 5th March 2020


Dear Sir,


Subject: GEAC’s 138th meeting on 11/11/2019 – Preparation and Formulation of Guidelines for Import of GM Animal Feed including DDGS – reg.


This is regarding the preparation and formulation of guidelines for import of GM animal feed including DDGS, for which GEAC in its 138th meeting took a decision to receive comments and inputs from all (GEAC) members on the report of the Sub-Committee chaired by Dr Lalitha Gowda. At the outset, we urge you to ensure that the report of the Sub-Committee be put out in the public domain so that citizens know what the regulators are actually discussing.


We write to you from the Coalition for a GM-Free India to strongly urge you not to allow GM animal feed for import as we are in no position to tackle the health and economic impacts of such a decision. Any import of GM animal feed will constitute a stealth GM food not tested in India.


To this day, regulators have not tested for Bt cottonseed oil, nor for HT soybean oil / canola oil which have flooded our food chain. This is a grave lapse on the part of the regulators, wherein they assumed that a one-time testing for glyphosate residues is all that they needed to do in terms of risk assessment!


It is also important to note that there is no labeling regime in place for upholding consumer right to know what they are consuming. Such labeling in fact will be virtually impossible to enforce in India.


HEALTH IMPACTS: In terms of health impacts of GM crops on animals, as you might be aware, from the biosafety dossiers that GEAC itself has from various GM crop developers, impact on animals upon consumption of GM feed, that too from a few short-term studies, has been adverse.


For Bt cotton, for instance, from the developer/applicant’s own reports and data, the Supreme Court’s Technical Expert Committee (TEC) in 2013 observed that cows that had been given Bt cotton feed showed indications(in the second phase of the treatment) of a possible declining trend in daily milk yield. The TEC noted that this would need further examination including additional studies in order to draw any firm conclusions in the absence of data reporting in greater detail in the reports. Significant differences between Bt and non-Bt cotton fed rats were seen in size of spleen, heart and uterus in females whereas in males, highly significant average lung weight differences were observed. The TEC notes that it is rather rare that a tissue like heart shows reduction in weight and has a similar trend between genders but more pronounced again in females.


In the case of Bt brinjal, Mahyco’s own data from a 14-day acute toxicity study on rats showed significant differences in AST levels of rats. “AST levels in both males and females were significantly different between Group 2 (non-transgenic brinjal) and Group 4 (transgenic Bt brinjal) treatments”, noted the TEC report, saying that “AST is a marker of organ integrity and increased AST could indicate damage to liver or heart”. In the 90-day sub-chronic toxicity study also in rats, serum, blood and organic parameters showed significant differences between non-transgenic and Bt transgenic treatments for female rats.


In the past, late Dr Pushpa Bhargava (the Supreme Court appointed Special Observer in the GEAC), had also raised grave concerns with regard to the GEAC’s handling of the phenomenon of sheep and other animal poisoning after grazing on remnants of Bt cotton crops in certain districts of Andhra Pradesh.


It is a separate matter of grave concern that GEAC’s so-called Sub-Committees and Expert Committees did not take into account findings from crop developers’ dossiers or from the field, that GEAC approved these GMOs and did not spot these issues. It is clear by now that these issues were only observed when testing was done, bio-safety dossiers for these were made available to public and independent experts scrutinized the reports and data.


In an annexure to this letter, we are also attaching more references to published studies on the subject.


Economic Impact: Import of GM animal feed from elsewhere will negatively impact our local producers too. For instance, every year US government subsidizes US farmers tens of billions of dollars for animal feed. Opening India for GM feed imports will be disastrous for our farmers. This will lower market prices for our farmers which will further discourage domestic production of animal feed leading to a vicious cycle. At a time when agrarian distress is acute, GEAC should not undertake steps leading on to further problems for our producers.


Another recent analysis of global pesticide sales data from 2018 found that $4.356 billion of highly hazardous pesticides were used on soyabean and maize with an estimated three-fourth of world’s soyabean and maize production ending up as animal feed. This further illustrates the danger from these to animals and humans alike. https://unearthed.greenpeace.org/2020/02/20/meat-soya-animal-feed-pesticides-hazardous/

The reports of India’s intent to permit imports of GM Animal Feed as also animal feeds from animal origins (eg bloodmeal) pose a threat not merely to India’s livestock, but also to humans via the entire food chain which includes milk and milk products, eggs, and meat: chicken, mutton, pork and beef. The GEAC states it has done sufficient studies to prove the safety of GM animal feed, which is a complete untruth.

From 2005 onwards soon after Bt Cotton began to be cultivated commercially in India, and the first reports of animal morbidity and mortality post grazing on harvested cotton fields, began to pour in from different parts of the country, there has been absolutely no conclusive evidence produced by the regulatory authorities that the mortality of animals exposed to Bt toxin / protein via grazing on Bt cotton plants, was due to other causes and not Bt protein. Above all, except for 2008, where Bt toxicity testing was specifically requested and the concerned institution the Indian Veterinary Research Institute  responded stating their inability to test for the Bt protein as they lacked facilities, there is no information on whether animal tissues were tested for Bt toxicity in the previous two years. The absence of protocols and technical facilities to test for and prove/ disprove the role of Bt toxin in animal morbidity/mortality after ingesting Bt cotton, resulted in the non–testing for the toxin/ immune response. The non-testing resulted in “non-detection” and a negative result.
The negative result of having not detected Bt toxin” was subsequently passed off as proof of safety.

Presenting circular arguments of safety as “fool proof evidence, is a clear case of fraud on the part of all the regulatory bodies in India. It is scientifically untenable that without performing any tests to conclusively rule out Bt protein as the cause of death in animals, its non-testing was and continues to be cited as evidence that Bt toxin is safe. This circular argument of “safety” continues to be the basis for GEACto brush of animal deaths as being “unsubstantiated”, and for it to have reversed its decision to carry out further risk assessment tests. This also forms the basis of their assurance to the citizens of India of the safety for animals to be fed GM animal feed, and thus the proposal to import GMO animal feed from the USA.

2) Subsequent studies on the effects of Bt toxin on Sheep, were carried in 2007 by a Veterinary University in Andhra Pradesh, and in 2008 by the Central Sheep and Wool Research Institute. Whilst neither of the studies were designed keeping in mind the field observations of the how symptoms were observed in sheep which had been repeatedly exposed to Bt toxin, and were one time studies, and the researchers chose to conclude that no untoward impacts/ effects were detetected, despite the reality of troubling results, which raised several unanswered questions as follows:

The 2007, season-long study by the Sri Venkateshwara Veterinary University found:

  1. i) The presence of higher toxic heavy metals in Bt plants (842.25 ppm of lead in Bt cotton as compared to 134.62 ppm of lead in non-Bt cotton after 45 days), which is 6.25 times higher after 45 days, as compared to the non-Bt cotton.
  2. ii) The liver marker AST which is known to increase after hepato-cellular injury, as the author of the experiment indicates, increased in the protocol by 37% in Bt treated sheep in com- parison to the untreated group of sheep fed on regular cotton, by the second month.

The feeding trial study carried out by CSWRI in 2008 designed for only a 3 month period, with a first time exposure of animals to Bt toxin, detected a higher liver weight, testicular weight and fat deposits in sheep fed on Bt diet. These results only served to re-inforce the urgent need for more systematic, comprehensive long-term studies on the effects of GMOs on animals.

The inconclusive nature of Bt toxin in Bt cotton and its impact on animals continue to remain. Is Bt toxin acting as a stress factor that is eliciting in a select fashion, a morbid possible allergenic response in the sheep, goats, and other animals, manifested as cold cough, nasal discharge in animals? Is the intense stress a trigger for Pasteurella haemolytica, in some of the animals with resultant death? Is the stress factor Bt toxin? Is it some unknown / new to- xin? Is it a new allergenic protein? Is it macro / micro mineral imbalances in the Bt cotton plant, (eg excess or deficiency of Nitrate, Nitrite, Selinium, etc) as a result of the Bt protein, which elicits a response from the animal?

There are a host of contradictions within the “safety” parameters. There is clearly total failure and inability of our existing public research institutions and National Regulatory Bodies (GEAC), to investigate/ test/ rigorously examine, prove or disprove these field observations, preferring to dismiss the reports as “unsubstantiated”, “exaggerated, and unscientific”, refusing to conduct a single field-based study and instead placing the onus of “proof” on shepherds, farmers and civil society groups who had reported the problem.

There is a clear need for new risk assessment and bio-safety protocols: chronic and long- term toxicity and allergenic tests and inter-generational studies so as to deepen our understanding on long-term implications for human and animal health to understand the unintended effects which often only come to light after several years of exposure of the organism to the GM technology (in this specific case GM cotton containing Bt toxin). There is a clear need to put into place a reliable and citizen accountable Regulatory and Monitoring mechanism, that will respond to problems when they are experienced, and not ignore / dismiss. There is an urgent need that India sets up independent labs for testing which are fully functional and certified to international standards. These must be capable of conducting all the required tests. Standardized and exhaustive testing protocols. India institutes capability/capacity for independent oversight, outside of the Regulatory mechanism that is free of  any kinds of biases.

  1. II) Regarding the imports of animal blood meal into India, it is the scientific evidence of the threat of feeding animal tissues to animals, and its subsequent effects on human health, which must form the basis of our ban on its imports. The outbreak of Bovine Spongiform Encephalopathy (BSE) or the Mad Cow Disease in the 1980s occurred because the diseased cattle were fed animal tissue. As a result, the World Organisation for Animal Health (OIE) and several countries, for instance Australia, have a total ban on feeding any form of ruminant feed containing animal tissue or blood meal to ruminants. The natural preference of a ruminant is a plant based diet. So feeding a ruminant an animal tissue is not physiologically and anatomically a natural fit, unlike a carnivore.  There are cultural ramifications of this as well in India. The UK went against this natural order by feeding herbivores a non-vegetarian diet.  The ensuing mad cow disease was caused by this. It spread to whole herds, which had to be destroyed. This also spread to humans. Similarly BSE has been reported in US as well. We in India should not be emulating such an example.


Any attempt to legalise GM animal feed imports is wrong in principle and unsafe, based on available evidence. We therefore strongly urge you not to allow GM animal feed for import. The downstream impacts are serious, greatly escalating the contamination of our food chain. As mentioned earlier, we are in no position to tackle the health and economic impacts of such a decision. In fact, we urge GEAC to first set right the serious shortcomings in the current biosafety assessment regime (as listed in annexure to this letter attached here).



Sridhar Radhakrishnan,

Coalition for a GM-Free India


Coalition for a GM-free India 

Website: www.indiagminfo.org, email : indiagmfree@gmail.com,  Facebook pageGM Watch India