seed production with high purity. CMS systems are either unstable or their restoration to fertility is inadequate.

A more versatile hybrid seed production system is based on the use of transgenes –

Barnase and barstar as explained below.

2.       Contrary to the claim here, CMS does work well, as per several senior mustard breeders in India.

3.       Several CMS-based hybrids have been released from public and private sector entities. Many yield better than DMH-11.

4.       The highest rapeseed yield is in those countries which have opted for CMS hybrids and not GM based hybrids.

5.       All types of male sterility are subject to breakage. The Central Compliance Committee ( which reviews the field trial) field visits noted this problem. In fact, trial protocol and data recording during trials should have been standardized on this aspect and reported back, which was not the case except in Ludhiana trial.

6.       In fact, the crop developer and later the GEAC Sub-Committee falsified their findings when they concluded that no male sterility breakdown was observed.

7.       Mustard breeders in India have shared with members of the Coalition that the reason why Dr Pental and his team do not want to use the existing CMS options is that he wants to work with his own exclusive lines, reducing choices for this team. However, this constraint does not exist for other breeders.

8.       All this discussion on barnase and barstar conveniently keeps silent about BAR gene, which is herbicide tolerant. We discuss this serious concern later in this note. GEAC is continuing its oversmart game of hiding important information in this FAQs also by not bringing this up here.

genes into wild populations; the persistence of the gene after the GMO has been harvested; the

susceptibility of non-target organisms (e.g. insects which are not pests) to the gene product; the

stability of the gene; the reduction in the spectrum of other plants including loss of biodiversity; and

increased use of chemicals in agriculture.

It is worth noting that Environment Risk Assessment Guidelines in Indian regulatory system were prepared and released only in 2016. The question that then arises is how testing of GM Mustard happened, and was allowed all along without these guidelines in place.

2.       Comparatively less tests have been carried out compared to even Bt. Brinjal which was placed on an indefinite moratorium for want of more tests and proof of safety.

3.       The study protocols were designed by crop developers, rubber stamped by regulators. What is the expertise that CGMCP has in evolving protocols or conducting studies like pollen flow? The studies were conducted by the crop developers themselves, without any blinding, without proper statistical analysis, related to agronomic performance, impact on bees, on pollen flow, on outcrossing with other related species etc. etc.

4.       Studies that are being shown to have been conducted by National Institute of Nutrition have been outsourced to a private entity.

5.       Protocols to test a herbicide tolerant crop do not exist in India, have not been developed by the regulators even though they are appraising numerous HT crops in the pipeline. NO TEST HAS BEEN CONDUCTED ON GM MUSTARD THE WAY A HERBICIDE TOLERANT CROP SHOULD HAVE BEEN TESTED. ON JUST THIS COUNT, ALL THE MEAGRE SO-CALLED TESTS DONE SHOULD STAND NULL AND VOID.

6.       The Biology of GM Mustard (basic document supposed to be in place with the regulator before any GM research begins), was prepared only in 2016. So how can it be said that safety studies were done as prescribed by the Govt.

basic traits: resistance to insect damage; resistance to viral infections; and tolerance towards certain

herbicides. GM crops for hybrid seed production for heterosis breeding (e.g. rapeseed/canola) and with

higher nutrient content (e.g. soybeans increased oleic acid) have been also studied recently.

2.       In fact, to accommodate HT crops, MRLs have been revised upwards of chemicals like Glyphosate by up to 400%! Glyphosate has now been classified as a Probable Human Carcinogen by WHO.

3.       To this day, 91% of global GM area is within 5 countries. Majority of countries do not opt for cultivation of GM crops and this is cleverly not being put out by the MoEFCC in its FAQs, talking only about “kind of GM foods that are on the market internationally”.

So a technology which has been touted as a panacea to reduce chemical usage has become the vehicle for increased chemical usage jeopardizing environmental, human and animal health.

So far, there is no evidence suggesting that the transgenes could be transferred to humans or animals through consumption of GE food.

Can the seeds of this GE mustard be directly consumed?

Will it be safe to consume leaves of this GE mustard?

toxicity and allergenicity in humans and animals and found that the introduced proteins do not have any

toxicity.

2.       Many tests that ought to have been done were not taken up for GM mustard in the name of changed guidelines.

3.       There was no health expert in GEAC subcommittee which evaluated the dossier as also no genetic toxicologists in the panel.

4.       No chronic toxicity testing has been done. Several feeding studies done for other crops’ assessment weren’t done with GM mustard.

5.       Analysis that could be done with little information available shows that toxicity cannot be ruled out. There have indeed been significant changes discovered between study and control group animals, but have been disregarded.

2.       No scientists from Ayurveda or ISM disciplines are members of GEAC or Sub-committee.

3.       Mustard has a big use in Ayurveda! Various uses are documented in Caraka Saṃhitā, Suśruta Saṃhitā, Bhela Saṃhitā and Kāśyapa Saṃhitā.

me a monster?

2.       Crop developers, GEAC and MOEFCC should produce evidence to support their statement that there has been more than a decade of history of safe use of these 3 proteins – which evidence that they hold shows that these proteins have not caused any illnesses after consumption?

3.       Human body is full of microorganisms. Most of them are beneficial. Recent study has establishes relation between gut bacteria and functioning of the brain. It may not alter human genome but it could definitely alter microorganisms associated with human health. This has not been tested in the case of GM mustard and therefore, no conclusion of safety can be drawn.

4.       Sub-Chronic Toxicity Studies reveal statistically significant differences in biochemistry parameters, histo-pathological differences and body weight gains. However, these are being brushed aside as irrelevant.

5.       Chronic impact studies have not been taken up.

6.       Bar protein might degrade during cooking, but leaves and seed cake are fed without cooking to animals.

2.       There is no taste test carried out.

3.       “Expected to” is not scientific spirit and is not a definitive and conclusive answer, it is only speculation.

conventionally grown varieties in India.

Will milk produced by cattle having this GE mustard in diet be different in colour and other nutritional value?

In compositional analysis, this GE mustard is found to be substantially equivalent to commercially cultivated mustard varieties (Varuna and RL1359). Hence, this GE mustard will have same nutritional value. Therefore, milk produced by cows after the consumption of this GE mustard, if any, will not changes in terms of colour and nutritional value.

Some of these questions are being raised and answered merely to distract the public from raising real issues and obfuscate other pertinent matters (like the one related to color etc. – we challenge GEAC to show who has raised this question at all with them).

Based on the Global reports of history of safe use and other reported scientific literature, it is assessed to be safe for animal grazing on it.

2.       Feeding studies have not been done.

3.       The sub-chronic toxicity tests do raise safety questions which have been brushed aside in safety conclusions.

4.       There are no global reports of history of safe use.

5.       There are scientific studies that point to problems with animals feeding on GM feed.

“Mustard is a food for humans and animals. Yet no feeding trials were done. It is clearly stated that “No feeding studies are required for granting environmental release” pg 70. And even though the oilcake is fed to cows, the assessment states “No livestock feeding studies are recommended”. Pg 66. Without feeding trials, there is no assessment of safety. The claim of safety without trials is unscientific. The assessment basically states it’s own redundancy when it comes to bio safety protocols. Not having carried out any feeding trials, the assessment concludes – without any scientific basis – that GMO mustard does “not pose any risk of causing any adverse effects on human and animal health and safety “ pg 74. Or, they have no clue, because observation and inference were “not recommended”.”  Response to AFES document from Dr Vandana Shiva, Executive Director, Navadanya

Before concluding that there are no adverse effects, evidence has to be presented scientifically to support the statement. Does GEAC or MoEFCC or crop developer have any? Is lack of evidence to be taken as proof of safety?

2.       What exactly is “history of safe use of these proteins in other countries”? Is lack of evidence a proof of safety? Is there actually proof that the various health problems witnessed in countries that have opted for GMOs are not related to GM food consumption and cultivation?

3.       Is the Canadian consumption of canola oil the same as the Indian consumption of sarson da saag?

4.       If regulators want to rely on canola results elsewhere in the world, why do we need regulation and testing in India?

are no such evidence of leachates of these protein in ground water. Further, it has to be noted that

these proteins are not stable for a long period and gets degraded after release in the soil.

2.       Glufosinate , the herbicide to which GM Mustard is engineered to be tolerant to is persistent and mobile in soils; toxic to beneficial soil micro-organisms incl. nitrogen fixing bacteria ; toxic to some aquatic organisms ; may increase nitrate content in soils and increase risks of nitrate leaching

2.       Nectar quality will not only get affected by the transgene proteins but also herbicide used on HT GM crop.

mustard fields?

2.       Importantly, impact of Glufosinate on honeybee was not assessed even though this is a herbicide tolerant crop.

3.       No pollination deficit study was conducted on GM Mustard apart from merely reporting that there was no change in bee visit. It is essential to conduct pollination deficit study comparing organic, conventional, GM hybrid and even available non GM hybrid mustard varieties across seasons, years and locations.

2.       The CGMCP is keenly interested in evolving HT crops, whatever might be their statements about the HT status of this crop – their projects reveal this clearly.

3.       At the testing stage, no tests have been carried out to assess the impact of this

2.       DMH-11 F1 and its parental lines are 100% HT crops. This HT crop is engineered to be tolerant to glufosinate, a patented herbicide of Bayer Company (which has taken over Monsanto recently). This herbicide is not even registered for use in mustard under the pesticides regulatory regime in India.

3.       HT trait will also be there in farm-saved seed and seeds produced in contaminated neighboring fields.

4.       In India pesticide/herbicide use is not controlled nor need based. Giving HT crop in the hands of Indian farmers is very risky. Saying “herbicide usage is not recommended for realizing yield potential” does not mean anything in reality,  as Indian regulators have no control over what farmers do at their level.

5.       The TEC has examined the issues in relation to HT, particularly with regard to sustainability and the likely socioeconomic impact on major sections of rural society. On both these counts, based on the reasons presented in the section on Herbicide Tolerance, the conclusion of the TEC is that HT crops would most likely exert a highly adverse impact on sustainable agriculture, rural livelihoods, and environment. The TEC finds them completely unsuitable in the Indian context and recommends that field trials and release of HT crops not be allowed in India.

2.       Further, in case of normal outcrossing of GE mustard with neighboring non-GM mustard fields, the F1 progeny of the contaminated crop could contain 25% male sterility.

3.       Addition of DMH-11 pollen in subsequent generations (one farmer continuously being non-GM with farm-saved seed in each generation, while others shift to GM mustard hybrid) will increase the male sterility percentage.

4.       If Varuna –Bn (one of the parent plants) outcrosses with non-GM mustard it will produce 50% male sterile off spring.

5.       Neighboring non-GM farmers will not be able to save seed – upto 25% of their crop will be male sterile when out-crossing occurs; further damage could be caused due to  accidental glufosinate sprays.

6.       In effect, this forces farmers to not save their own seed and shift to GM mustard hybrid.

2.       The Protection of Plant Varieties and Farmers’ Rights Act (PPVFRA) of 2001, under Section 29 (3) classifies GURT and Terminator as a technology that is injurious to the life or health of human beings, animals or plants and lays down that no variety of any genus or species which involves GURT will be registered.

GM foods and their safety should be assessed on a case-by-case basis and that it is not possible to make general statements on the safety of all GM foods. GM foods currently available on the international market have passed safety assessments and are not likely to present risks for human health. In addition, no effects on human health have been shown as a result of the consumption of such foods by the general population in the countries where they have been approved.

2.       If GEAC and India are indeed following a case by case approach for assessment of GMOs, they should not have allowed this GM mustard to be developed with taxpayers’ funds, and come this far at all. It is an unneeded GMO, which is a dangerous herbicide tolerant GMO.

3.       There is no evidence to conclude that currently available GM foods are not causing any health problems to the populations consuming them. How do we know that the incidence and increase of certain kinds of illnesses in countries like the USA are not related to GM foods consumption? There hasn’t been labeling or segregation in the US for GM food to identify the problems that have occurred and to be able to correlate it to GM food. The absence of collection of data cannot be taken as proof of absence of harm.

4.       There is certainly evidence to show that HT GM crops are resulting in large environmental health crisis in their cultivation in South American countries.

conducted with edible plant parts (leaf and seed) no toxic effects were observed on reproductive organs of rats.

With the labeling laws for GM crops being completely ignored by the FSSAI there is no way for the consumer to avoid consuming these identical looking but genetically modified crops.

This will lead to contamination at various levels in food supply and seed supply and farmers and consumers will have no choice.