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

20 Bt Brinjal: The GEAC environmental risk assessmentProduct Quality of EE-1 Bt BrinjalConclusion 2. The EE-1 transgene may be a second-rate Bt brinjal product. EE-1 was probably produced inthe late 1980s or early 1990s, its control of BFSB is low, and other Cry toxins might perform better.During the late 1980s, Monsanto developed Event 531, the cry1Ac transgene in Bt cotton Bollgard I. This transgene wasformed from a plasmid with nptII and aad, which are marker genes for kanamycin and streptomycin resistance respectively (see,e.g., Zambryski 1992). During the early 1990s, Monsanto developed Event 15985, the cry2Ab transgene in Bt cotton BollgardII (McCabe and Martinell 1993). This transgene was formed by co-transformation with two plasmids. One contained nptIIand the other uidA, which was eliminated from the final product by segregation. During the early 1990s, Monsanto developedMon810, the cry1Ab transgene in Bt maize, Yieldgard (AGBIOS 2003). This transgene was formed by co-transformation withtwo plasmids. Segregation eliminated some of the undesired elements from the final product, which contained only nptII.More recent methods used by Monsanto produce transgenes with no antibiotic markers. Because EE-1 contains both nptII andaad, this suggests that it was produced by Monsanto sometime during the late 1980s or early 1990s, before Event 15985 andMon810.As will be reviewed below, efficacy of EE-1 is low. It provides only 73% control of BFSB in the MST field trials (Dossiervol. 6) and sometimes requires an insecticide application to control BFSB. BFSB is in the family Crambidae in the orderLepidoptera. Several other stem boring Crambids have been targeted for control by other Bt crops. These include Ostrinianubilalis (European corn borer), Diatraea grandiosella (southwestern corn borer), Diatraea saccharalis (sugar cane borer), andChilo partellus (spotted stemborer). Bt maize typically shows 100% control for all these Crambid species.There may be a better transgene than Ccry1A for control of BFSB. Mon810 is based on the Cry1Ab toxin, which affects thehigh level of control of Crambids. A comparison of susceptibility in O. nubilalis to Cry1Ab and Cry1Ac suggests that it is moresusceptible to Cry1Ab than Cry1Ac (Denolf et al. 1993, Marçon et al. 1999). Thus, it is possible that a more modern transgenebased on Cry1Ab would control BFSB better and reduce concerns associated with the marker genes.Given these considerations, it seems clear that the applicant (either Monsanto or Mahyco) has invested little in thedevelopment of a useful Bt brinjal product for India. Indeed, an inflammatory characterisation of the process so far would bea case of “transgene dumping.” It would seem in India’s best interest to require a modern transgene that exhibits much betterefficacy against BFSB. Such a request, if fulfilled, would eliminate several risk issues associated with inadequate transgenecharacterisation of EE-1 and would diminish other environmental risk issues, especially related to resistance evolution in BFSB.