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

62 Bt Brinjal: The GEAC environmental risk assessmentdesk, laboratory and growth chambers, greenhouse, and field. The “desk” environment does not require working with anyliving material. The realism of the environment increases from the laboratory to the field. Second, does the work require useof Bt brinjal? In many cases, use of Bt brinjal would improve the experiment, but satisfactory conclusions could be reached if anon-Bt improved hybrid were used instead. For example, hybridisation and cross-compatibility studies would best be done withBt brinjal, but sufficiently useful data could be derived from experiments using a non-Bt improved hybrid. In these cases, Btbrinjal is not required. Third, during what stage of development of the genetically engineered crop could the ERA be initiated?We use the following stages of development of a genetically engineered plant (Andow et al. 2006) and associate ERA activitieswith these stages. This association is not required, but it is the earliest time in the development process that it makes sense foran ERA activity to be initiated.The stages are:A. Design of plant transformationB. Initial screening of transformantsC. Characterising focal events in the laboratory and growth chambersD. Characterising focal events in the green houseE. Small-scale field testingF. Large-scale field testingG. Commercial use and post-commercialisation activitiesThe results of this analysis are shown in Table 7. Several patterns can be perceived. Twenty-six ERA needs can be initiatedas desk work or in the laboratory, which obviates the need for field releases of Bt brinjal to assess risk. Seventeen of theseneeds can only be initiated in the field. Of these 17, less than half require the use of Bt brinjal, so most of the risk assessmentactivities can be done without releasing any Bt brinjal into the environment.Second, about half of the ERA needs require the use of Bt brinjal; the other half can be accomplished without using Btbrinjal plants, although two of these would provide more useful data if Bt brinjal was used.Third, 28 of these ERA needs can be initiated prior to field release. Only 8 must be initiated after field release. Becausethis report does not focus on post-commercial monitoring, only one ERA need identified here must be initiated after commercialrelease. Thus, most of the ERA needs can be met prior to field release of Bt brinjal.Some of the needs requiring Bt brinjal release in the field are conditioned on certain results being found in experimentsconducted in the greenhouse or laboratory. All of the needs evaluating fitness of hybrids and backcrosses of Bt brinjal and awild relative require Bt brinjal in the field (as a control). However, these experiments are contingent on previous findings thatthere is cross-compatibility and sufficient temporal and spatial overlap, or that there are lepidopterous pests on the wild relative.Thus, there is little need for additional exposure of Bt brinjal to the environmentto complete an ERA that evaluates serious concerns for India.Post-commercialisation monitoring (aka post-market monitoring) is a controversial topic and probably deserves an analysissimilar in depth as this report on the ERA process. Although the reasons for development and implementation of post-commercialmarketing are many and varied (see lengthy discussion in NRC 2002), two reasons stand out. First, there is a need for monitoringof specific anticipated adverse effects with significant risk, such as monitoring for resistance to Ccry1A in BFSB. This kind ofmonitoring must be set up prior to commercialisation. Because the monitoring goals are already established, long-term fundingmust be secured, a system of reporting established, and remedial responses and response triggers clarified.Second, monitoring is needed when knowledge about risk is too uncertain. In this way, monitoring can substitute for certaintyin an ERA. This second approach, however, carries with itself substantial risk. Monitoring is expensive and, over time, the costsof monitoring take on a higher perceived value, especially if the benefits from monitoring are hard to understand. One benefit ofmonitoring is not finding or avoiding an adverse effect. Absence of a problem is difficult for many people to perceive as a benefit.Consequently, over time, pressure increases to reduce or stop monitoring. This means that monitoring is a poor substitute for