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

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2 Bt Brinjal: The GEAC environmental risk assessmentBrinjal fruit and shoot borer (BFSB) causes significant economic damage to brinjal throughout India for all farmers, probablyaveraging about 30% yield loss (a comparison of yield with pest management versus no pest management). Its perceivedsignificance by farmers often lead them to overestimate the loss to BFSB, precipitating an over-use of insecticides significantlybeyond that justified by the actual economic significance of BFSB. Real losses from BFSB are higher for large-scale commercialproducers than for small-scale resource-poor producers because of the way damaged fruit can be used by the small-scale resourcepoorfarmers. EC-II vastly over-estimated losses to BFSB.Some management for BFSB is practiced by all brinjal farmers. Most farmers overuse synthetic insecticides by a considerableamount. Insecticide use can be reduced substantially using integrated pest management (IPM). Useful alternative productionsystems for control of BFSB are being tested, actively used, and promoted in India. These include IPM, traditional pestmanagement, organic production and other locally-derived methods that reduce costs associated with external inputs.Main Conclusion:Main Conclusion: The potential advantages of hybrid EE-1 Bt brinjal seem marginal and uncertain for mostThe Indian potential farmers, advantages and the of environmental hybrid EE-1 Bt brinjal risks (including seem marginal socioeconomic and uncertain risks) for to most Indian Indian farmers, and and consumers theenvironmental remain very risks uncertain, (including despite socioeconomic efforts by risks) the EC-II to Indian to assess farmers these and risks. consumers The potential remain very advantages uncertain, can despite beefforts better by the estimated EC-II to by assess careful these consideration risks. The potential of the advantages context of can different be better kinds estimated of brinjal by farmers careful consideration in India. Several of thecontext significant of different environmental kinds of brinjal risks have farmers not in been India. considered Several significant and nearly environmental all of the risks others have have not been considered inadequatelyand considered. nearly all of the These others can have be better been inadequately characterised, considered. eliminating These the can excessive be better uncertainty, characterised, and eliminating most of this the canexcessive be done uncertainty, without releasing and most Bt of brinjal this can into be done the field. without Once releasing these Bt risks brinjal are better into the characterised, field. Once these risk risks management are bettercharacterised, measures may risk management be developed measures to address may be the developed remaining to address uncertainties. the remaining Until the uncertainties. risks can be Until better the understood risks can bebetter or managed, understood there or managed, seems little there reason seems little to approve reason to commercial approve commercial use of hybrid use of Bt hybrid brinjal Bt at brinjal this time. at this time.Transgene CharacterisationConclusion 1. The EE-1 Bt transgene needs to be characterised more fully 1) to demonstrate that there isonly one transgene insert in Bt brinjal, 2) that the transgene expresses the intended Cry protein, 3) that it doesnot interrupt a functioning plant gene, 4) to provide expression levels in additional plant tissues, and 5) todemonstrate empirically that the marker genes are not expressed in Bt brinjal.The description of the transgene in Bt brinjal EE-1 is inadequate to support environmental risk assessment. There is at leastone transgene incorporated into EE-1 Bt brinjal. It is not known that there is only one transgene incorporated into the brinjalgenome, that the one known inserted transgene expresses the intended gene product, or that the transgene does not interrupt afunctional plant gene. Additional transgenes, expression of an unintended product and interruption of a plant gene could createadditional environmental risks that have not been considered or assessed.Adequate characterisation of expression of the transgene is essential for effective environmental risk assessment. The descriptionof the chimeric Cry1A protein (Ccry1A) is inadequate for this purpose. The amino acid sequence of Ccry1A as expressed inbrinjal is needed. The expression level of Ccry1A in pollen of Bt brinjal EE-1 is needed. There is no need to use Cry1Ac, aprotein that is not identical to Ccry1A, in any the experiments used to support risk assessment, as was done in EC-II and theDossier. The expression level of the marker genes is assumed to be low. This should be demonstrated empirically.Conclusion 2. The EE-1 transgene may be a second-rate Bt brinjal product. EE-1 was probably produced inthe late 1980s or early 1990s. More recently produced commercial transgenes have significant improvementsover EE-1. EE-1 has relatively low control of BFSB, and other Cry toxins might perform better.
Summary and Conclusion 3The EE-1 transgene does not kill nearly all young BFSB larvae. This is unlike other transgenes used to control otherlepidopteran pests in the Crambidae, the same family as BFSB. Indeed all other target pests in the Crambidae are controlledby a Bt transgene with >99% mortality. Control of lepidopteran pests in other insect families is not as good, but it should bepossible to get much better control of BFSB if the proper transgene were used. EE-1 is a very old transgene, and while it maynot be exactly transgene dumping, India would do better to wait for a more efficacious transgene before seriously consideringapproval of Bt brinjal.Conclusion 3. The EC-II assessment does not comply with scientific aspects of transgene characterisationdescribed in the Guideline for the Conduct of Food Safety Assessment of Foods Derived from Recombinant-DNA Plants (Codex Alimentarius, 2003, CAC/GL 45-2003).The GEAC would like to conclude that the EC-II report is in compliance with India’s international obligations under allrelevant treaties, but especially the Codex Alimentarius. The Codex has a key role in the World Trade Organization (WTO),and compliance to Codex would mean that India is compliant with related obligations in the WTO. The lack of compliance ofEC-II to Codex highlights a serious deficiency in the EC-II assessment.Environmental Risk AssessmentConclusion 4. Most of the possible environmental risks of Bt brinjal have not been adequately evaluated;this includes risks to local varieties of brinjal and wild relatives, risks to biological diversity, and risk of resistanceevolution in BFSB.This conclusion is supported by the following three conclusions. Briefly, EC-II relied on dubious scientific assumptions, did notfocus on realistic environmental concerns, inadequately evaluated some important environmental concerns, and ignored otherreal environmental concerns.Conclusion 5. Brinjal has considerable valuable genetic diversity in India that could be threatened by geneflow. EC-II, the Dossier, and the Supplemental Materials are inadequate for concluding that Bt brinjal has nosignificant effects on the biological diversity or weediness of brinjal or its wild relatives.EC-II and the Dossier argued that Bt brinjal does not outcross enough to create environmental risks, but this is dubious. Itis highly likely that cultivated brinjal (Solanum melongena), including local varieties and landraces have crossed with feralpopulations of S. melongena, and it is possible that cultivated varieties can revert to wild phenotypes and establish feralpopulations. Therefore, the possible effects of intraspecific gene flow from Bt brinjal to other varieties and populations of brinjalshould be examined. In addition, there is likely to be natural crossing between Bt brinjal and wild species related to brinjal.Hybridisation with perhaps as many as 29 wild relative species needs to be evaluated carefully and the consequences of anyhybridisation that occurs needs to be evaluated.There is insufficient evidence that 1) wild or weedy relatives of brinjal would not obtain a fitness benefit from a Bt transgeneshould gene flow occur; 2) wild relatives of brinjal will not suffer reduced genetic diversity from the introgression of the Bttransgene; and 3) non-GM brinjal will remain uncontaminated by Bt brinjal. All of these risks need to be evaluated.
Page 1 and 2: Table of Contents 1Bt Brinjal Event
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Page 5: Summary and Conclusion 1Summary an
Page 9 and 10: Summary and Conclusion 5Event EE-1
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Page 13 and 14: Context and Need 9standards for ER
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Page 17 and 18: Context and Need 13the reported yie
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Bt Brinjal The scope and adequacy of the GEAC environmental risk assessment

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