Thursday, 7 January 2016

Bt brinjal

GM developers rely heavily on aiding the developing world when promoting their wares to policy makers, the general public and investors. I'm pretty skeptical, partly because of the scientisticism that pervades this view.

I am nevertheless keen to understand the opposing views. This is the only reason I keep interacting with the skeptics despite their visceral antipathy to my skepticism on this topic: the best test of one's hypotheses are to expose them to those who most loathe them.

Which brings us to the controversy over Bt brinjal (eggplant) in India.

The first serious paper I read on this topic was this economic assessment (pdf, 2011).  It is very positive about Bt brinjal but isn't actually a complete cost benefit analysis (CBA) because it only compares Bt brinjal with pesticide-heavy methods. File it alongside this investigation (pdf, 2008) of different organic treatments for brinjal in India. Both tell you something about how to optimise within a paradigm but neither attempt a head-to-head comparison between organic/biodynamic/biological and GM systems.

Digging into the controversy a bit further led me to Ronald Heering who cites India's GM regulator, the Genetic Engineering Approval Committee (GEAC) to state that
No hazards from the insecticidal protein were found through standard safety protocols; GEAC findings conformed to the European Union's general conclusions quoted above
Ronald's paper also informs us that the Minister wasn't convinced by the regulator's report and the whole project got stopped for political reasons, which really got me interested. Here's the regulator's report - it relies on data/analysis supplied by the developer and raises no real concerns.

Given the name of the regulator ("approval committee"), the concept of regulatory capture and Ronald's view that India seeks to actively promote GMOs, there are reasonable grounds for wondering about the robustness of the GEAC's assessment.

The next layer down is this report by Jack Heinemann which digs into the scientific evidence that the Bt brinjal developer presented to the GEAC in India. Jack explains that the accepted international scientific conventions for evaluating products of genetic engineering are produced by the Codex Alimentarius Commission (Codex) and then cites (Table 1) six ways in which the GEAC's assessment fell short of these standards. He goes on to cite specific weaknesses in the developer's evidence.

So where does all this leave an objective but interested observer?

  • Hurdles for intervention in another country's policy should be pretty high, though there are different levels of intervention of course, and different levels of interest. Apartheid in South Africa was enough to make me break a few rules in 1981, but some people can't even remember which side they were on.
  • India is the worlds largest & most diverse democracy. It is consequently bogged down in bureaucracy. A few million westerners suddenly getting behind a campaign to admit a GM product is very unlikely to be effective.   
  • You need big money to change government policy. The Gates/Monsanto team is pushing on in Kenya but this is for cotton & maize. I haven't seen them caning the Indian government on Bt brinjal but I could easily have missed that.
  • There is a natural experiment underway because Bangladesh has embraced Bt brinjal while India has not. We will hopefully learn about the farming economics of the product from this experiment, at least relative to conventional pesticide-intensive methods. Noting of course that production economics is only one part of the story.
  • The science around Bt brinjal appears contested. I'd have thought that if it really is a no-brainer then the promoters would just go the whole hog on the science, not leave out bits that seem quite important.

For these reasons I don't advocate pressuring India to approve Bt brinjal

1 comment:

  1. I'd like to add some additional context to your brief discussion of the Bt brinjal history.
    1. Bt brinjal was evaluated not once, but twice by GEAC. It engaged two expert review committees (EC I and EC II) that were tasked with reviewing the primary data in biosafety studies conducted and supplied by the product’s developers and making a recommendation to GEAC. Development lead was Mahyco (a Monsanto subsidiary in India). In August 2007, EC I largely accepted the applicants’ assertion of safety based on their data of Bt brinjal, but made some additional recommendations to be satisfied before commercial approval could be granted. EC II was convened in February 2009 to answer criticisms, from international and Indian scientists, of the conclusions of safety based on the applicants’ dossier, as well as concerns expressed from civil society. GEAC accepted the recommendation of EC II, detailed in their report of October 2009, that Bt brinjal be approved for commercial cultivation.
    2. My report was just one that examined the work done by GEAC. The Minister received many others from scientists both inside and outside India. (He names 9 from outside India in his decision overturning the GEAC decision.) The most significant, in my view, was from lead author Prof David Andow at U Minnesota, who wrote in collaboration with Indian scientists. His expert report is available on the web (e.g. http://www.gmwatch.org/files/Andow_Report_Bt_Brinjal.pdf). He makes many important observations about the risk assessment. But to me, the most compelling was this: “The EE-1 transgene may be a second-rate Bt brinjal product. EE-1 was probably produced in the late 1980s or early 1990s. More recently produced commercial transgenes have significant improvements over EE-1. EE-1 has relatively low control of BFSB, and other Cry toxins might perform better. ”
    Why was this important? Entomologist Andow argued that using the EE-1 event would likely accelerate resistance evolution. “The EE-1 transgene does not kill nearly all young BFSB larvae. This is unlike other transgenes used to control other lepidopteran pests in the Crambidae, the same family as BFSB. Indeed all other target pests in the Crambidae are controlled by a Bt transgene with >99% mortality. Control of lepidopteran pests in other insect families is not as good, but it should be possible to get much better control of BFSB if the proper transgene were used. EE-1 is a very old transgene, and while it may not be exactly transgene dumping, India would do better to wait for a more efficacious transgene before seriously considering approval of Bt brinjal.” Like me, Andow concluded that "The EC-II assessment does not comply with scientific aspects of transgene characterisation described in the Guideline for the Conduct of Food Safety Assessment of Foods Derived from Recombinant-DNA Plants (Codex Alimentarius, 2003, CAC/GL 45-2003)."
    Subsequently, the Supreme Court of India convened an Expert Technical Committee composed of scientists from the industry and academia. The Expert Committee validated the Minister’s decision and recommended even more stringent oversight of future developments (http://www.newindianexpress.com/business/news/Supreme-Court-committee-says-no-to-GM-crops/2013/07/23/article1697835.ece). Thus, unlike assertions made by some commentators, the Minister’s, and later the Supreme Court’s process, was based on science, while in addition the Minister consulted widely with the state governments.
    Jack Heinemann

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