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Today's topics: * Greenpeace concern over dead cattle, demands GM food ban. - 1 messages, 1 author http://groups.google.com/group/BM_discussion/browse_thread/thread/8b8c1c66e100111a * Indian farmers slam decision to conduct GM Bt Brinjal trials. - 1 messages, 1 author http://groups.google.com/group/BM_discussion/browse_thread/thread/6c9fec6a00a3df8b * Research warns about toxic effects of GM crop and other dangers. - 1 messages, 1 author http://groups.google.com/group/BM_discussion/browse_thread/thread/40ced34e3992342b * All about "Right to Information Act" - 1 messages, 1 author http://groups.google.com/group/BM_discussion/browse_thread/thread/4a8a898fdf905d0f * Trika Yoga Meditation - 1 messages, 1 author http://groups.google.com/group/BM_discussion/browse_thread/thread/1390b7bfd2f1f2ec * Letter to Health Minister, India, seeking active review of GM policy. - 1 messages, 1 author http://groups.google.com/group/BM_discussion/browse_thread/thread/468dadd1b2aae23b ============================================================================== TOPIC: Greenpeace concern over dead cattle, demands GM food ban. http://groups.google.com/group/BM_discussion/browse_thread/thread/8b8c1c66e100111a ============================================================================== == 1 of 1 == Date: Wed, Jun 14 2006 1:20 am From: Jagannath Chatterjee Greenpeace cattle seek Indian agriculture minister's attention Rahul Kumar OneWorld South Asia , 13 June 2006 http://southasia.oneworld.net/article/view/134775/1/1893 New Delhi: Dressed as cattle Greenpeace protestors tried to seek an audience on Tuesday with Indian agriculture minister Sharad Pawar over the mysterious deaths of livestock in the south Indian state of Andhra Pradesh, allegedly due to consumption of genetically modified crops. Though the minister's office refused Greenpeace an appointment on Tuesday, it did respond by saying that the minister will meet representatives from the organization on Wednesday to discuss the issue. The activist organization was protesting against the death of nearly 1,600 cattle in the south Indian state of Andhra Pradesh in April this year. An investigation by a non governmental organization (NGO), Centre for Sustainable Agriculture (CSA), says that the death of sheep was linked to prolonged consumption of Bt cotton stalks and leaves that were left in the fields after the cotton harvest. Greenpeace is demanding that the agriculture ministry should order an investigation into the death of the sheep and withdraw all permissions for the commercial release of existing GE crops till the investigation is complete. The protestors met animal husbandry secretary PMA Hakim, a senior official in the Indian government, who told Greenpeace that he has asked for investigations in the death of the cattle. Greenpeace campaigner Rajesh Krishnan reacted: "Hakim has asked the Indian Council of Agricultural Research (ICAR) for an inquiry but the Indian government's response has all through been informal. Instead of conducting an inquiry itself, the central government has asked the Andhra Pradesh to inquire into the deaths even though the state government does not have the expertise to study such a bio-safety disaster." The protestors were holding a banner on behalf of the dead animals that read: "Did GM crops kills us? Don't legalise GM foods." The protestors also carried signboards with dead sheep and cattle with the message Do not eat GM foods. The Greenpeace memorandum read: "GE cotton was approved after the company and the government claimed that all safety tests had been done. Two months ago a report by the CSA documented a grave incident where around 1,600 sheep had died after grazing on GE cotton fields in Warangal district of Andhra Pradesh. The NGO makes a strong case for GE cotton being the cause of death." The memorandum said: "While cause for the deaths of sheep remain unresolved we believe that GM crops must be viewed with caution and the health of the nation must be put before corporate profit We have come to know from the 67th meeting of the Genetic Engineering Approval committee (GEAC) that brinjal with the same Bt gene whose safety is presently under question is now being considered for large scale field trials." Krishnan said: "The impacts of GM technology on human health and biodiversity remain unpredictable, untested and irreversible even then the government is on the verge of approving large scale field trials of genetically modified brinjal. This will be the first GM food crop in India." Krishnan added: "Clinical trials in the US have proven that GE corn killed cattle and people developed allergies. The company responsible for this had to pay $100 million compensation to the affected farmers. Unfortunately there is no consumer choice in the US. Once the crops reach the market there is no way a consumer can distinguish between GM and non-GM foods." He added that clinical trials on rats in Australia have shown immunological and respiratory problems, apart from allergies in the animals. Greenpeace has demanded that there should be an investigation on the mortality of sheep and the terms of reference should be made public. "The health impacts of GE crops should be assessed by doing an exhaustive long term health impact study. All field trial permissions for new GMOs be stopped including Bt brinjal and all permissions for commercial releases of existing GE crops should be withdrawn," said the memorandum. "Our ideal is not the spirituality that withdraws from life but the conquest of life by the power of the spirit." - Aurobindo. __________________________________________________ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com ============================================================================== TOPIC: Indian farmers slam decision to conduct GM Bt Brinjal trials. http://groups.google.com/group/BM_discussion/browse_thread/thread/6c9fec6a00a3df8b ============================================================================== == 1 of 1 == Date: Wed, Jun 14 2006 2:18 am From: Jagannath Chatterjee Indian Farmers' Leader, Dr Krishan Bir Chaudhary's letter to GEAC chairman on the proposed field trials of BT BRINJAL Dr Chaudhary's contact mobile : 09810331366 BHARAT KRISHAK SAMAJ ( FARMERS§ FORUM INDIA ) Chairman: A-1,Nizamuddin West, Dr. BAL RAM JAKHAR New Delhi-110013 Governor, Madhya Pradesh Phone:24359508, Telefax: 24359509 Executive Chairman Email:[EMAIL PROTECTED] Dr. KRISHAN BIR CHAUDHARY Former Chairman, State Farms Corporation of India May 31, 2006 To Shri B S Parsheera Chairperson, Genetic Engineering Approval Committee [GEAC] Ministry of Environment & Forests Paryavaran Bhawan, CGO Complex Lodhi Road, New Delhi Dear Shri Parsheera Sub: Bt Brinjal Large Scale Field Trials  Consideration of application for permission by GEAC This is with regard to the Agenda Item No. 4.2 in the GEAC meeting dated 1/6/2006 which says that GEAC will consider permission for seed production and Large Scale Trials of Bt Brinjal of 4 Mahyco hybrids in this meeting. In this regard, we would like to bring to your notice that the GEAC is yet to act and fix liability on the various biosafety violations and irregularities brought to your notice by civil society organizations, including on a Bt Brinjal limited field trial in Andhra Pradesh. While turning a blind eye to the harsh realities related to serious regulatory failures, you seem to be ready to go all out to support the industry in its profit-making endeavours. Given that there are many studies on adverse health effects with many GM crops from all over the world, what is the assurance that the right questions have been asked in this case to arrive at the right answers with regard to the safety of these crops? We have found that Bt Cotton, which was upheld through your tests to be safe to human health [amongst other things] is indeed causing a lot of health problems amongst farm workers and ginning factory workers. Similarly, there were recent reports on the mortality of livestock after grazing on Bt Cotton. It is not clear how GEAC is assessing such possibilities as part of its biosafety testing regime nor how is it acting at least on such reports by commissioning detailed independent investigations once these preliminary reports are out. It would be disastrous for this country to rush into approvals just because a prescribed set of tests for a prescribed period have been completed as per some procedures laid down. There has never been a serious public debate initiated on the adequacy of such a biosafety regime and even though there is a Supreme Court case pending precisely on this matter, the GEAC seems to be in a great hurry to approve even GM food crops like vegetable crops, for reasons that are not clear at all. This is especially surprising in all those crops where safer, inexpensive and farmer- controlled options like IPM, NPM and Organic are in place, successfully practiced and established all over the country. The data presented by the company on various studies done in Bt Brinjal was put up by the GEAC only this morning [31/5/06] and considering that this is a very important food/vegetable crop of the country, there should be at least 90 days allowed for feedback on the biosafety tests and their findings. Secondly, the data put up is not adequate for an intelligent and scientific debate to take place since it only has findings without details of the research design and protocol in each case. We demand that full reports on each test be presented and not just findings. We also demand that the GEAC show its accountability to the public by sharing what improvements have been made in its biosafety protocols, in its monitoring systems and in its accountability systems, before giving any more permissions for trials, given your proven inability to ensure biosafety in this country. Here, we would like to remind you that it was during such field trials that illegal Bt Cotton and rapid contamination of the Cotton chain began in this country and GEAC could only wring its hands in helplessness. The dangerous and unscientific manner in which field trials take place in this country tell us that we are only one step away from a huge bio-disaster wreaked on Indian agriculture. To sum up, we once again demand that the complete set of data on Bt Brinjal including the testing protocol [and not just findings] be put up for public feedback, that at least 90 days be provided for such feedback, that such feedback be taken on board with all the seriousness it deserves, that clearly-needed improvements be made in the testing regime and monitoring systems and shown to be made to the public before any permission for any more trials in the open environment are given in the country. Yours Sincerely, Krishan Bir Chaudhary (Executive Chairman) ---------------- Suresh Motwani Agronomist ISAP RC - Central Cell: 09329450167 Email: [EMAIL PROTECTED] Web: www.isapindia.org "Our ideal is not the spirituality that withdraws from life but the conquest of life by the power of the spirit." - Aurobindo. __________________________________________________ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com ============================================================================== TOPIC: Research warns about toxic effects of GM crop and other dangers. http://groups.google.com/group/BM_discussion/browse_thread/thread/40ced34e3992342b ============================================================================== == 1 of 1 == Date: Wed, Jun 14 2006 2:30 am From: Jagannath Chatterjee Genetically modified crops highly toxic to humans - insects seem to thrive on them << http://perdurabo10.tripod.com/id451.html Uh Oh; The Bugs Are Eating Those "Pest Killing" Crops Two research teams in England and Venezuela have discovered something alarming about the new genetically modified crops filled with insecticide. The insects not only eat them, they seem to thrive on them. Scientists at Imperial College in London and the Universidad Simon Rodrigues in Caracas found that the insects that the chemical additive was supposed to kill were not only feeding on the poison, but the stuff seems to help them thrive. That the biotech companies added genes from a naturally occurring poison, Bacillus thuringiensis (Bt), which is widely used as a pesticide by organic farmers, means that the mutation by insects to survive the poison is a potential threat to the organic farming industry. Environmentalists believe the resistance developed quickly because the insects are constantly exposed to the chemical in the plants, instead of being subjected to occasional spraying. This is bad news for not only the struggling agricultural industry but for over 6 billion world food consumers as well. With the world population exploding and the instability of weather because of global warming, world agriculture is in danger of falling short of producing enough food for everybody. The GMO experimentation with Bt fell under fierce criticism by growers world-wide who warned that the excessive use of the chemical would eventually generate stronger chemical-resistant pests. Not even the strongest critics dreamed that the insects would be feeding and thriving on the plants engineered with Bts. But there is more bad news about those modified crops. Lots of it. Prominent scientists from seven countries recently produced an Independent Report on GM agricultural practices during a public conference in London. The report, titled The Case for a GM-free Sustainable World, called for a ban on GM crops. The conclusions: --GM crops failed to deliver the promised benefits. There have been shown no increase in yields or a significant reduction in herbicide and pesticide use. In fact the United States lost an estimated $12 billion over GM crops because of worldwide rejection of them. --The GM crops are posing escalating problems on the farm. The group found that transgenic lines are unstable. Triple herbicide-tolerant volunteers and weeds have now emerged in North America, creating severe problems for farmers who suddenly have no inexpensive solution to weed and pest control. The fear is that superweeds and bt-resistant pests have been created. --Further extensive transgenic contamination, especially for corn, seems to be unavoidable. It has been found in maize even in the remote regions of Mexico. Tests showed that 32 out of 33 commercial seed stocks in Canada, where GM corn is prohibited, were contaminated anyway. Corn pollen remains airborne for hours and can be carried by the winds for miles. Thus there can be no co-existence of GM and non-GM crops. --GM crops are not proven safe. In fact, its regulation was fatally flawed from the start. The principle of "substantial equivalence," a vague and ill-defined rule, gave companies like Monsanto complete license in claiming GM products equal and as safe as non-GM. --Dangerous gene products are incorporated into the food crops. For example, Bt proteins, added to 25 percent of all GM crops, are harmful to many non-target insects, and some are potent allergens for humans and other mammals. --GM foods are increasingly used to produce pharmaceuticals and drugs. These include cytokines, known to suppress the immune system and are linked to dementia, neurotoxicity and mood swings; vaccines and viral sequences like as the 'spike' protein gene of the pig coronavirus, in the same family as the SARS virus; and glycoprotein gene gp120 of the AIDS virus that could interfere with the immune system. The fear is that this last gene could recombine with viruses and bacteria to generate new and unpredictable pathogens. --Crops engineered with suicide genes for male sterility, promoted as a means of preventing the spread of transgenes, actually spread both male sterility and herbicide tolerance traits via pollen. --Broad-spectrum herbicides are found to be highly toxic to humans and other species of animals. Glufosinate ammonium and glyphosate, used with herbicide tolerant GM crops that currently account for 75% of all GM crops worldwide, are both systemic metabolic poisons. Glufosinate ammonium is linked to neurological, respiratory, gastrointestinal and haematological toxicities, and birth defects in humans and mammals; also toxic to butterflies and a number of beneficial insects. Glyphosate is the most frequent cause of complaints and poisoning in the UK. Its exposure nearly doubled the risk of late spontaneous abortion. Children born to users of glyphosate had elevated neurobehavioral defects. It caused cell division dysfunction that may be linked to human cancers. The report warns that genetic tampering with foods may be inadvertently creating super-viruses and bacteria that could spark unstoppable world-wide plagues. "Newer techniques, such as DNA shuffling, allow geneticists to create in a matter of minutes in the laboratory millions of recombinant viruses that have never existed in billions of years of evolution," the report warns. The report concludes: "sufficient evidence has emerged to raise serious safety concerns, that if ignored could result in irreversible damage to health and the environment." "Our ideal is not the spirituality that withdraws from life but the conquest of life by the power of the spirit." - Aurobindo. __________________________________________________ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com ============================================================================== TOPIC: All about "Right to Information Act" http://groups.google.com/group/BM_discussion/browse_thread/thread/4a8a898fdf905d0f ============================================================================== == 1 of 1 == Date: Wed, Jun 14 2006 6:35 pm From: "Moderator BharatUdayMission" For everything you ever wanted to know about the *"Right to Information Act" *, please visit www.nyayabhoomi.org. You will find here 1. An RTI HANDBOOK - download and use 2. Complete "bare Act" as it was enacted 3. Success stories 4. Form for application 5. Useful contacts 6. And a lot of other related information For any specific help, you may write to me. *RAKESH AGARWAL* [EMAIL PROTECTED] *CELL: 09873 222 222* -- "We have only one Passion The Rise of a Great Nation." www.bharatudaymission.org ============================================================================== TOPIC: Trika Yoga Meditation http://groups.google.com/group/BM_discussion/browse_thread/thread/1390b7bfd2f1f2ec ============================================================================== == 1 of 1 == Date: Wed, Jun 14 2006 10:22 pm From: "Virendra Qazi" Respected Friends, Pranam! Venue: Lalleshwari International Trust C - 2 / 2284, Vasant Kunj, New Delhi - 110070. Ph: 91 - 11 - 26133936. Date & Time: 18th June (Sunday) Morning 8 to 9 am. Trika Yoga Meditation is based on the technique as per Vighan Bhairav. It has two stages. First mind is infused with very compatible and vibrating feelings. Second stage is inward journey to seek inner bliss and divine energy. This spiritual technique has quick effect and we get results which are normally achieved after much efforts. Soon one can feel a great relaxation, alertness and energitic brain and deep fixation of happiness. This event has been prompted by a leading Specialist of Neuro Sciences. He conducted "Transcranial Topler" test on brain with the latest developed machine. The results are amazing. Regards, Virendra. ============================================================================== TOPIC: Letter to Health Minister, India, seeking active review of GM policy. http://groups.google.com/group/BM_discussion/browse_thread/thread/468dadd1b2aae23b ============================================================================== == 1 of 1 == Date: Thurs, Jun 15 2006 12:43 am From: Jagannath Chatterjee To: June 14, 2006 Dr Anbumani Ramadoss Hon'ble Minister for Health & Family Welfare Government of India. From: Members of Coalition for GM-Free India Respected Sir Sub: Bt BRINJAL HUMAN HEALTH HAZARDS AND BEYOND We are a group of concerned civil society organizations, representing lakhs of Indians, approaching you to intervene into the matter of Bt Brinjal, which is on the verge of obtaining permission for large scale trials and seed production in this country. This would be the first time that a GM food crop could be allowed to be released into the open environment for this stage of research. This is the first time in the world that a GM crop would be grown as a vegetable with the Bt toxin incorporated into it and consumed with very little processing. It is not out of place to remind here that it was during large scale trials that Bt Cotton's illegal proliferation began in this country and the regulators only watched with helplessness. Things have not improved an iota since 2001 when such contamination began with Bt Cotton in this country. There are grave concerns with regard to these various developments and since the Health Ministy's mandate is to protect the health of all Indians and since the Ministry constitutes one of the important regulators of GM in agriculture in India [by virtue of the presence of the Ministry's representatives in the GEAC, expected to play a very important role in decision-making related to GMOs] we approach you to seek your positive intervention in the issue. We would like to begin by stating that while we welcome the fact that GEAC has offered, for the first time more than a decade after GM crop research began in India, to put up data related to findings from biosafety tests on Bt Brinjal, the entire process run was completely unacceptable. The data that was put up, as presentations by M/S Mahyco to the GEAC, is completely inadequate for any intelligent and scientific feedback to be provided. This also showed the world how GEAC, in which the Health Ministry representatives are expected to play a pro-active role to protect the health interests of Indians, takes its decisions. It is clear that a body that should ask basic, scientific questions related to health and environmental implications in addition to socio-economic implications for our farmers, has decided to function as a mere `bureaucratic approval' body and runs its processes only on such company-produced meaningless presentations. We provide our feedback on Bt Brinjal hereunder. Below, we bring up biosafety issues as well as more fundamental issues beyond biosafety. Much of this feedback should also serve as a feedback on the serious shortcomings of our biosafety regime in general and why there is a need to invoke the precautionary principle on GM crops. Numerous studies worldwide have raised serious questions about potential health impacts of delta-endotoxins. Key assumptions used as the basis for safety claims have been overturned and several adverse findings suggest that GM foods are unsafe. GM-fed animals had problems with their growth, organ development and immune responsiveness, blood and liver cell formation as well as damaged organs [bleeding stomachs, excessive cell growth, inflammation in lung tissue], sterility problems and increased death rates including among the offspring. Risks are increased by the fact that the genes inserted into GM food not only survive digestion, but transfer into body organs and circulation. Transgenes or their fragments have been found in the blood, liver, spleen and kidneys. 1. The Bt gene is a known toxin that impacts human health and livestock health adversely: Introduction or creation of a new or known allergen or toxin is a potential consequence of genetic manipulation, as experience worldwide shows. v When Bt Cotton was introduced in India, the same set of tests that are now being applied for Bt Brinjal have apparently been run by the company involved and everything was proclaimed to be safe. However, the human health effects of Bt Cotton in India are being reported from all cotton-growing states now. Most farmers and farm workers are experiencing allergies of different kinds. Further, a recent scientific investigation made a clear correlation between the exposure to Bt Cotton and these adverse health effects [copy of the report attached Annexure 1]. v Similarly there were also reports on mortality of sheep after grazing on Bt Cotton recently [copy of the Fact Finding Team's preliminary investigation report attached Annexure 2]. While there have been no systematic investigations done in other places, there are informal reports however that livestock is being adversely impacted upon grazing on Bt Cotton fields from other places too. v While this is the case with cotton, the consequences with a food crop, that too a vegetable crop which will be consumed quite directly, are unimaginable. Never before in the world has the Bt toxin been introduced into a vegetable crop, where the toxin would be consumed in large quantities and without much processing. We are annexing several scientific papers which point out that Cry1Ac gene Annexure 3, the Bt gene being used in Bt Brinjal, has many established adverse health impacts. These published, peer reviewed papers by scientists demonstrate that recombinant Cry1Ac protoxin is a powerful immunogen (able to produce an immune response), and when fed to mice, induced antibody responses similar to those obtained with the cholera toxin. Research shows that Cry1Ac actively binds to the inner surface of the mouse small intestine. This contests the often-heard argument that Cry proteins don't affect mammals since they supposedly do not have receptors that bind the truncated toxin in the gut! The entire infamous episode of Starlink contamination [where Cry9C toxin was used] raises the question of whether other Bt toxins that were supposedly screened might nevertheless be allergens. Scientists accept that without a better understanding of food allergenicity, this question cannot be adequately answered. There are serious limitations to current allergy testing procedures for GMO proteins. For example, recent results in Australia revealed that a protein previously consumed safely in beans had become immunogenic (similar to allergic reaction) when engineered into GMO peas. The immunogenicity of the GMO peas would not have been detected by currently used tests. Therefore, new allergy tests, and careful, long-term tests, are needed to assure the safety of Bt brinjal. Other possible risk issues, such as possible unintended harmful changes in the Bt brinjal plants, can also only be addressed by careful long-term and other testing. We cannot afford to make the mistake committed by Australian regulators who discovered the GM peas case only after almost irreversible field trials. We are annexing to this letter four such infamous accidents which proved to be disastrous for human health and environment Annexure 4. v There are some nutritional and toxicological studies carried out on ingested plant GM DNA which provide information on the potential nature of the hazards of GM foods/feeds. These include: wasteful growth of gut tissues and bacterial proliferation, development of intestinal tumours, depression of the body's immune system, interference with the normal development of vital organs of the body (liver, kidneys, sexual organs, etc.) and reproduction. The seriousness of these effects cannot be overemphasized because the harm will be the most pronounced in the young, the old and in people with intestinal disorders. v The human clinical study carried out and published till date provides strong evidence of Horizontal Gene Transfer from food to humans. These studies showed that fragments of GM DNA were incorporated into the bacteria resident in the gut of human volunteers. Significant amounts of transgenic DNA is found to survive most commercial processing or in the gut of mammals, as per studies in various places. 2. The other genes introduced are toxic too: Antibiotic resistance: In creating Bt Brinjal, NptII gene has been used as a selectable marker. NptII codes for kanamycin resistance and globally, there are serious concerns with antibiotic resistance marker genes for obvious reasons when there is horizontal gene transfer to gut or soil bacteria, this could spread antibiotic resistance widely. Gene flow, especially to pathogenic organisms, related to antibiotic resistance has been established in past studies. This will imply that disease treatment would be more and more difficult. The Bt Brinjal also has an aad marker gene. Streptomycin resistant marker according to EFSA this is a potentially dangerous marker to animals and human beings and should not be used in the case of GM plants used as food. Transcriptional activity in human cells with CaMV 35 S: Similarly, use of the CaMV 35 S [cauliflower mosaic virus] promoter, used in creating Bt Brinjal is a matter of concern. Published research shows that the 35S promoter can initiate transcriptional activity in human cells, despite the promoter being a plant-specific one. A scientific paper attached throws further light on this Annexure 5. The cauliflower mosaic virus (CaMV), the viral promoter used in Bt Brinjal has similarities with the human hepatitis B virus. As all genomes of living species contain dormant viruses, there is a potential for the CaMV promoter to reactivate them raising concerns related to cancers. One of the major omissions in present day GM risk analysis is that no attempt has so far been made to investigate the obvious link between GM food and intestinal tumour development. As Dr Arpad Puzstai points out, "full reproductive experiments are required in which the reproductive performance of both male and female rats fed on GM- versus non-GM diets should be monitored for several generations because any problems with reproduction could have disastrous consequences for the environment". The problems encountered in the study of `growth factor-like' effects on young rats, was attributed most likely, to the CaMv (cauliflower mosaic virus) viral promoter, a promoter put into Bt Brinjal too. Evidence suggests that the CaMv 35S promoter might be especially unstable and prone to horizontal gene transfer and recombination with all the attendant hazards: gene mutation, cancer, re-activation of dormant viruses and generation of new viruses. Hazards from GM crops released into the environment may spread more readily through Horizontal Gene Transfer because GM constructs are specifically designed to cross the interspecies barrier. 3. Past history with corporate research shows suppression of important information: Monsanto, which is supplying the technology to Mahyco and others in the case of Bt Brinjal, is known from past experience to suppress facts that are unfavourable to the company and its potential markets. A secret study on Bt Maize showed significant harm caused to rats fed on the variety called MON 863. The study shows kidney abnormalities and unusually high levels of white blood cells. What is shocking was that the company then went ahead to conclude that these findings were irrelevant and should not be attributed to Bt Maize even though the rats fed on non-Bt Maize showed no such signs! Given such dubious history, how are the regulators relying on data produced only by the company? The agronomic data unreliable and manipulated: Going through the Annual Report of the All India Coordinated Research Project Vegetable Cultivation on ICAR-supervised Bt Brinjal multi-locational trials in 2005-06, it is clear that the data presented is manipulated and unreliable. It is not clear why at least 3 out of the 11 Centres for trials did not report back. The data was not statistically analysed and wrong conclusions were drawn based on skewed averages. It is not clear how some centers could obtain such unbelievably high yields while most of the centers were below average. Is this going to be the situation in real life too for farmers? There is no data at all on pesticide use obtained through the trials though Bt Brinjal is developed ostensibly to reduce the use of pesticides. It is also clear that there were no trials taken up to compare with safer, cheaper, farmer-controlled alternatives like organic brinjal cultivation or NPM or IPM approaches. There was not even a comparison against IPM experience from all over the ICAR establishment from more than 10 years' of work. There is a serious and objectionable conflict of interest in the fact that majority of the tests were undertaken by the company promoting Bt Brinjal [pollen flow studies, Cry1Ac protein expression, baseline susceptibility, protein estimation in cooked fruits, soil analysis, substantial equivalence studies etc. etc.]. Out of the various tests conducted, only four were conducted by public sector institutions, that too funded by the company. Where are independent studies to verify the claims of the company? Where are studies especially from the Health Ministry to confirm the safety of the product? 4. The science of GM is imprecise: It is well known that GE is based on imprecise science and is an unpredictable technology as there is little control on where the new genetic construct will lodge within one or more of the target cell chromosomes. It is also well known that tests are not conducted to assess the results from the variety of genes that are inserted along with the desired gene [the markers, promoters, terminators, metabolites etc. etc.]. Scientists do not understand the mechanisms of GE-induced changes in gene expression in sufficient detail. They do not know what to look for and these things are termed `unintended effects'. It is for this reason that on a whole range of issues, a great deal of research is required before any outcomes can be predicted in a reasonably assured manner. Unlike in other countries, in a country like India where a majority of our livelihoods depend on agriculture, any irrevocable or irreversible change to our agriculture needs to be reasonably sure that the benefits being projected are drawn from sound, long term scientific testing and that risk assessment parameters are broad-based. Elsewhere, risk assessment of GMOs also asks a very pertinent question "is it [introduction of a GMO] socially and ethically justifiable?". We are annexing a paper on such risk assessment Annexure 6 so that the regulators might at least now pick up the appropriate framework for risk assessment given that millions of farmers in this country would be affected by your decisions. This kind of assessment is very important since there is very little awareness related to GM technology in farmers and consumers. This requires that informed public debate takes place before any decisions taken. 5. The tests done here are not adequate Are we even asking the right questions? A Public Interest Litigation [PIL] on the lack of rigorous biosafety testing for GMOs in India points out that the current biosafety regime is woefully inadequate in India. A copy of the PIL petition is attached in the form of a booklet Annexure 7 for ready reference. Often, we do not even have the right questions to ask when testing for safety of GMOs. As pointed out earlier, elsewhere, biosafety regime is inclusive of such pertinent questions as "is this socially and ethically justifiable?". This requires the testing to be done against other known safer alternatives including ecological/sustainable agriculture practices. However, this was not done in the case of Bt Brinjal. Another paper Annexure 8 by Dr Pushpa Bhargava way back in 2002 outlines what the biosafety regime should constitute. Going by the set of studies that the company has been asked to do by the regulators, it is obvious that feedback has not been picked up and lessons not learnt. An annexure provides specific feedback on the biosafety claims on Bt Brinjal Annexure 9. 6. There is no justifiable reason whatsoever for experimenting on and introducing Bt Brinjal [and GM crops in general]: The GEAC or the DBT [Department of Biotechnology] has no good reason and justification to promote a GM Brinjal in this country. Pest management on Brinjal is being successfully practiced by numerous IPM, NPM and organic farmers with non-chemical, non-GE approaches with very satisfactory results all over the country. Within the ICAR stablishment, numerous research projects, including on farmers' fields, show that there are very good, inexpensive and absolutely safe results following non-chemical IPM methods in particular and IPM methods in general. Given such vast experience, why is there no political will to put the control over the technology in farmers' hands? We are attaching to this letter a collection of such experiences Annexure 10 which should provide a way forward for our thinking. We are once again reiterating that for the pest management paradigm to shift in this country, what is needed is political will and not GE-like solutions. We all know that pesticide use in fact has very little to do with pest/disease incidence any more and it has suited the pesticide industry and the regulators/agriculture scientists very well to encourage such a situation so far. To get out of this, we don't need a technology-fix but an alternative paradigm of pest management which empowers the farmers to understand their farm ecology and depend on local resources and sustainable practices for pest management. More importantly, there is no crisis with Brinjal production. In fact, due to overproduction, farmers do not get adequate market price. 7. Potential environmental hazards with Bt Brinjal: Existing evidence on environmental hazards with GM crops is enough for a precautionary principle to be invoked regarding their regulation. For instance, it was found in studies that GM crops grown in the UK were not only harmful to beneficial insects like ladybirds but could also indirectly harm other and higher life forms, including mammals, domesticated or wild animals/birds and ultimately man, both in the short- and long-term. India is a Center of Origin and diversity for Brinjal: Our pool of genetic reserves would inevitably be contaminated and this is extremely dangerous given that we are a Centre of Origin and diversity for Brinjal. We have grown Brinjal for the past 4000 years in this country and it is an extremely popular and widely consumed vegetable. Needless to say, horizontal gene transfer from Bt Brinjal into wild, related species of brinjal has serious implications for the very future of Brinjal research and cultivation in the country. The genetic diversity is important because some of the strains will be naturally resistant to lethal pathogens and pests that may destroy the crops in the future. Once lost, this lack of diversity can lead to the complete loss of the crop. Several published experiments with Bt in rapeseed and sunflower have provided preliminary data that Bt genes can indeed give some wild plants a competitive advantage. If the gene spreads in wild relatives of brinjal, its escape into the environment will be permanent. The toxin produced by the gene may then kill insects that feed on the wild plants. India is a haven of butterflies and the Cry1 Ac gene targets lepidopterans including these butterflies and moths. These insects, in turn provide food for other organisms such as birds and mammals, which may then suffer harm. For these reasons, it is important to determine the possible harmful effects of the Cry1Ac gene in sexually compatible wild relatives and their ecosystems. The Cartagena Protocol on Biosafety, the only international law to specifically regulate genetic engineering and GMOs (largely focused on transboundary movement, but whose scope also applies to the use of all GMOs), recognises the importance of centres of origin and diversity, and requires this to be taken into account during the risk assessment. How has this principle been applied in the case of Bt Brinjal in India? In the case of pollen flow, it is well known that there is ample opportunity for cross pollination in the case of Brinjal. It has been reported that the extent of natural outcrossing is from 2 to 48% in the case of India. Further, it is not clear whether there is enough data on the wild and weedy plants that are either close relatives or have some degree of cross-compatibility with these brinjal varieties. No tests have been done to check for cross-pollination with such relatives. Further, farmers from various parts of the country are reporting a decline in their soil productivity after growing Bt Cotton. While the regulatory tests related to Bt toxin presence and persistence in the case of Bt Cotton showed that the half-life of Cry1Ac protein in plant tissue was calculated at 41 days [which could then persist in the soil as other studies from elsewhere show], it is not clear how in the case of Bt Brinjal it is non-detectable in soil samples tested. Worldwide, it is generally accepted that Bt toxin does alter the soil micro-biology and that more studies are needed to understand the impact of Bt toxin on soil ecology. It is not clear if the regulators studied the impact of Bt Brinjal on ecologically sensitive areas like the Eastern and Western Ghats and considered how they would prevent the entry of Bt Brinjal into such ecologically sensitive areas. We should also consider a scenario where our predominant pest management strategy relies more and more on one gene the Bt toxin gene, across crops for a range of pests. Such a monoculture of the gene across crops and varieties is bound to spell doom sooner or later. Resistance is already predicted in the target pest and resistance management strategy suggested is a 5% refuge. However, Bt Cotton experience shows that farmers do not follow these resistance management strategies. How will this be done in the case of Bt Brinjal? If there are several GM crops grown together, the resistance build up will be faster. 8. Consumer choices and rights: Transgenic contamination (contamination of the natural environment by GMOs) by more than one method, including wind blown and by cross- pollination is an established fact, beyond dispute and there can be no co-existence between GM and non-GM crops. Segregation even at the physical level is impossible in India. What happens to consumer choices and rights in such a case? Where would be the consumer's right to choose in the case of vegetables, even if we assume that segregation upto an extent is possible and labelling could be made mandatory? Indian vegetable purchases from supermarket shelves are minuscule and obviously, labelling is not going to be an answer here. How do we then provide non-GM brinjal to Indian consumers? In conclusion, drawing from the experience with another hazardous technology like pesticides, it is obvious that biosafety and impact assessments are not carried out before irreversible release of the technology into the environment. Very often, experimentation is done at the expense of poor Indians including Indian children as scapegoats. Can India afford to make similar mistakes again? Given all the above, we demand that: 1 Since the effects of this technology/modified organism are unknown and since these are potentially hazardous, the use of this technology and release of those organisms must wait until the hazards are properly understood and the effects known. This requires the precautionary approach to be followed. 2 Biosafety testing should include testing for medium and long term effects on the environment and human/animal health, in addition to asking questions on the justification of releasing the GMO into the open environment on social and ethical grounds. For this, the regulators as a beginning, should put together all the available data on safer alternatives, as any environment assessment should, like IPM, NPM, organic etc., and compare Bt Brinjal with such alternatives. 3 Proper biosafety tests should be taken up by independent and scientifically competent bodies in a transparent manner. Such tests should be allowed to take appropriate time needed to understand the medium and long term effects instead of being hastened in the pursuit of `fast-track approvals'. 4 The results of such tests should be made public and data published in a manner that it can be closely examined by the scientific community. It shall also be presented to all primary stakeholders [farmers and consumers] in a manner that meaningful debates are possible, through for instance, mandatory public notice and public hearings etc. 5 Such reviews and debates should also look at issues beyond biosafety and delve into socio-cultural and political aspects related to GM agriculture, given that millions of our lives and livelihoods depend on agriculture here in India. 6 The GEAC, especially representatives from the Health Ministry, Environment Ministry and the Agriculture Ministry on the Committee, should take on board current scientific data [health and environmental] from elsewhere to understand the potential impact of GMOs and to ask the relevant questions in the Indian context. Based on such available data, they should lucidly justify why a precautionary principle cannot be invoked straightaway, instead of falling into the trap of the Department of Biotechnology which apparently has only one mandate of promoting GMOs. In summary, we demand that the Health Ministry as one of the most important stakeholder-regulators of GMOs in this country play its rightful and expected role in protecting the health interests of Indians, to take a precautionary approach and reject the proposal to permit Bt Brinjal large scale trials in the country. Sincerely, Sd/- Members of Coalition for GM-Free India Annexure 9: Specific feedback to the company's claims on its findings through Bt Brinjal tests and trials: It is utterly meaningless to comment on the company's claims that Bt Brinjal is safe and profitable apparently based on their studies and trials with Bt Brinjal. This is because no protocols are described for the tests nor any numbers or tables presented. However, from whatever's put up on the MoEF's website,: 1 The tests related to allergenecity and toxicity prescribed as part of biosafety testing are obviously inadequate as the experience with Bt Cotton in India shows. Despite being cleared as safe, Bt Cotton is reported to be causing widespread allergies in cotton growing belts of the country. Therefore, the protocols for such tests need to be re-looked at to capture the real adverse potential and such revised and better protocols applied for Bt Brinjal testing, especially given that it is a food crop with the toxin consumed in large quantities with no or very little processing. 2 Feeding tests done on goats do not capture the potential hazards as goats are known to be hardy animals, compared to sheep for instance. The protocol used in the case of Bt Cotton was to feed goats with cotton seed and the results apparently showed that there is no difference between feeding the goats with Bt Cotton seed and non-Bt Cotton seed. There were no multi-generational feeding tests done. What was not clear however was what the exact research protocol was - how old was the cotton seed, for instance? It is now clear that the tests did not capture the reality of farmers grazing their animals on Bt Cotton plants and not seeds. They also do not in any way predict what could happen with sheep. In the case of Bt Brinjal, there was no change in the testing regime from the Bt Cotton testing regime, despite such valuable lessons emerging from the field and despite this being a vegetable! 3 It is not enough to understand the effect of the Bt gene alone while understanding the impacts on human health and environment. It is important to capture the effects of the other genes transferred too. For this, a set of tests have to be evolved and undertaken. 4 It is surprising that the company says that the Bt toxin rapidly degrades in the soil. Published literature shows that this is not the case. There are many studies that show that Bt toxin can persist in the soil and retain its insecticidal activity. It is in any case known that the half life period of Cry1Ac toxin in plant tissue in the case of Bt Cotton is around 41 days. In such a case, why are the studies done by the company showing that the protein presence was non-detectable? At what stage of the crop was the test done? 5 What is the implication of growing Bt Brinjal in terms of the next crop, given the potential impacts on soil? 6 It is also surprising that pollen flow studies were done for just one year in two locations. Other information from India on pollen flow in Brinjal has results that should make any regulator sit up and take a cautious approach. The protocols used for devising Minimum Standards for Seed Production and Certification should be used here, since they have the worst case scenario built into the framework. 7 Such pollen flow studies should begin by listing out the wild species and related [compatible] species available in India in various regions of brinjal cultivation and check the effect of Bt Brinjal growth on such species, in a controlled environment [and not in farmers' fields]. Where is the data on associated biodiversity [like insects, birds, animals, microbes etc.] which depend on brinjal and its related crops [both wild, related and cultivated] and where are the impact studies on such associated biodiversity? 8 No detailed molecular characterization has been provided by the company. This is important, since we now know that developers cannot control where the transgene insert lands and that DNA rearrangements occur, with the potential to affect the spatial and temporal expression patterns of nearby genes. 9 Bt protoxins differ immunologically from the truncated proteins used for testing purposes. There is evidence that the toxic portion of Cry1A proteins can have a different 3-D conformation depending on whether it is part of the protoxin or in its free state. DNA structurally associated with the protoxin is released during the proteolysis process that generates the toxic fragment from the protoxin. If safety testing was performed on truncated versions of bacterial surrogate proteins rather than the full-length plant-produced Bt proteins that people are actually exposed to, such testing is absolutely indequate. It has been found often that biosafety testing does not take into account such a difference and it is not clear how the tests were conducted here. 10 It is obvious that investigations have not been carried out to check whether the bacteria in the GM agro-ecosystems have 'picked up' DNA sequence fractions of kanamycin resistance reporter genes or streptomycin-resistance reporter genes. 11 What do the "isolated instances of necropsy" findings in all treatments indicate and what is the company's explanation, in the case of Sub-Chronic Oral Toxicity studies in rats? How many such instances in Bt-treated rats and how many in non-Bt treated? 12 Where is the data on how the Bt Brinjal affects children? 13 Where is the data on the cultural diversity that exists with regard to the cooking of brinjal in this country? Brinjal is also used for medicinal purposes in India. What impact would Bt Brinjal have on such use? Where is data related to socio-cultural importance of Brinjal in different communities in India and the possible impact of Bt Brinjal on the same? 14 Where is data on quantified protein expression related to pest incidence in the complete growing season of the crop? Given that the expression of the toxin is highest in the fruit, the consumed part, what implications does this have for human health for particular hybrids? 15 Deeper investigations into what the farmers have observed during field trials of Bt Brinjal of color change in the fruits as the day passes have to be taken up. 16 There is no data that shows that pesticide use does come down with Bt Brinjal by how much? How does it compare with NPM and organic practices? FINALLY, WHERE ARE INDEPENDENT RESEARCH PROJECTS BY THE REGULATORS THEMSELVES TO OBJECTIVELY TEST FOR RESULTS ON EACH OF THE ABOVE ISSUES? ----------------------------------------------------------------------------------------------------------------------------------------------------- ---------------------------------- "Our ideal is not the spirituality that withdraws from life but the conquest of life by the power of the spirit." - Aurobindo. __________________________________________________ Do You Yahoo!? Tired of spam? Yahoo! Mail has the best spam protection around http://mail.yahoo.com ============================================================================== You received this message because you are subscribed to the Google Groups "BM_discussion" group. 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