Bt Brinjal The scope and adequacy of the GEAC environmental risk assessment

Summary and Conclusion 7Conclusion 11. Bt brinjal will require extension support to maintain any social benefits, and it may lead to lossof local brinjal varieties, and inhibit government plans to creates a strong vegetable export market. These risksshould be considered prior to commercialisation of Bt brinjal.Bt brinjal is not a panacea and will require new scientific information to maintain benefits for society even over relatively shorttime periods of 5-10 years. This implies that India will need a geographically extensive extension service that is prepared toprovide timely information about new demands for pest control as Bt brinjal is commercialised. Without this support, many ofthe potential social benefits of Bt brinjal will likely be lost soon after commercialisation.Bt brinjal may also have several indirect socioeconomic effects that merit assessment. These include and indirect loss of brinjalvarietal diversity, interference with vegetable export market expansion, and increased economic risks to brinjal farmers.Timing of Needed Environmental Risk Assessment ActivitiesAlthough the GEAC and Mahyco have already invested considerable time and effort into environmental risk assessment (ERA)for EE-1 hybrid Bt brinjal, much of the effort was misdirected and did not assess actual adverse environmental consequencesin India. The needs for ERA that are outlined here are developed with an eye towards improving oversight of geneticallyengineered crops in India, and redirecting efforts to issues that actually matter to India.Nearly all of these needs can be assessed without releasing Bt brinjal into the environment. Even those needs that require therelease of Bt brinjal in the environment are conditioned on certain results being found in prior tests conducted in the laboratoryor greenhouse. Thus, there is little need for additional exposure of Bt brinjal to the environment to complete an ERA thatevaluates serious concerns for India.This report does not cover post-commercialisation monitoring because this is a very complex issue. There are two main classesof justifications for monitoring: 1) a need to monitor specific, anticipated adverse environmental effects with significant risk,and 2) a need to compensate for uncertainty about specific or undefined adverse environmental effects. If one is not sure thatsomething bad will happen, monitoring can substitute for this uncertainty because by monitoring, one can detect the bad thingin time to mitigate, avoid or remedy the situation. However, there will be continual pressure to reduce the cost and effectivenessof this second kind of monitoring rendering it unstable even on medium-range temporal scales. An in-depth analysis of theseissues would be a welcome addition to the literature on ERA for genetically engineered organisms.