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

Summary and Conclusion 1Summary and ConclusionThis report evaluates the scope and adequacy of the environmental risk assessment (ERA) for hybrid EE-1 Bt brinjal requestedby the Genetic Engineering Approval Committee (GEAC) in response to the Maharashtra Hybrid Seeds Company Ltd.,Mumbai (Mahyco) application for permission to commercialise hybrid EE-1 Bt brinjal. The assessment is reported in the Report ofthe Expert Committee (EC-II) on Bt Brinjal Event EE-1. Event EE-1 expresses a genetically engineered crystalline (Cry) proteintoxin from the soil bacterium Bacillus thuringiensis Berliner (Bt). The Cry toxin is similar but not identical to Cry1Ac. It isa chimeric protein of Cry1Ac and Cry1Ab, and designated Ccry1A in this report. EE-1 was inserted into improved brinjalhybrids, which are modern cultivars of Solanum melongena L. [Solanaceae: Leptostemonum]. It was developed to control thebrinjal fruit and stem borer, Leucinodes orbonalis Guenee [Lepidoptera: Crambidae], which is abbreviated BFSB in the rest ofthis report. This report does not address the potential risks of hybrid Bt brinjal as human food or animal feed, and does notfully analyse the need for, requirements of, and methodologies for post-commercialisation monitoring of hybrid Bt brinjal.The report is based on an analysis of EC-II, the eight volumes of supporting information to the EC-II, which are referred to asthe Dossier in the rest of this report, Supplemental Materials submitted to the GEAC by Mahyco, which comprise 13 technicalreports, and publicly available scientific literature on Bt brinjal, BFSB and brinjal.The main thesis of the report is that the GEAC set too narrow a scope forenvironmental risk assessment (ERA) of hybrid Bt brinjal, and it is because ofthis overly narrow scope that the EC-II is not an adequate ERA.Context and NeedThis report holds the EC-II environmental risk assessment (ERA) to the standard of assessing outcomes about concreteenvironmental risks of Bt brinjal, and does not dwell much on the more narrow concern of whether the EC-II ERA meets theregulatory standards of the GEAC. By doing so, this report points out where the scope of the EC-II ERA is too narrow andchallenges the adequacy of the ERA framework established by GEAC and under which Bt brinjal has been assessed. At manypoints in this report, the EC-II is criticised not for whether it has accomplished what it set out to do, but whether it set outto do the right thing in the first place. Such errors of omission are sometimes invisible, especially when everyone focuses onpotential errors of commission. However, these omissions are probably more critical for India, in that serious concerns are leftunexamined.Brinjal plays a unique role in Indian society, and it will be important to evaluate if and how Bt brinjal may affect these values.Brinjal is one of the most important vegetable crops in India, especially for the rural and urban poor. About 61% is grown inthe three eastern states of West Bengal, Orissa and Bihar by small-scale resource-poor farmers. These States have banned theuse of Bt brinjal. India is the centre of the world’s biological diversity in brinjal with over 2500 varieties grown in the country.Some local varieties have significant religious and cultural value.EE-1 Bt brinjal is proposed as a hybrid, and is unlikely to fit well in the small-scale production systems relying on openpollinatedvarieties (OPVs) of brinjal. For small-scale resource-poor farmers it is critical for creating economic security, primarilyby facilitating cash flow, insuring against income variation from other crops, and providing families with needed food andnutrition. It may fit in large-scale commercial brinjal production systems that already use brinjal hybrids. Brinjal is producedfor net income by large-scale commercial producers.