GM mustard about to be approved for use: 10 facts that ought to worry you

On 11 May 2017, the environment ministry's Genetic Engineering Approval Committee (GEAC) recommended the commercial use of indigenously developed genetically modified (GM) mustard.

India is now just a step away from allowing the first food crop to be genetically modified.

Should we be concerned? Or should we feel assured by details like the EPA and EFSA have still not banned glufosinate essentially due to a dearth of evidence; or that some farmers are supporting herbicide tolerant (HT) mustard while yet others are opposing it; or that it is regressive or politically motivated to not give technology a chance?

What is GM mustard?

The genetically engineered mustard hybrid – DMH-11 – has been developed by the Centre of Genetic Manipulation of Crop Plants (CGMCP), of Delhi University, in collaboration with National Dairy Development Board and Department of Biotechnology (GoI).

DMH-11 is a herbicide tolerant (HT) mustard plant that has been developed by crossing a local Indian breed, Varuna, with EH-2, an East European strain known for its higher yields.

This hybridisation is achieved by means of the three gene combination (derived from soil bacteria) – barnase, barstar, bar.

The barnase gene, that confers male sterility, is inserted in Varuna making it male sterile and consequently a female parent. It is crossed with EH-2 which has the fertility restorer - barstar gene, to produce hybrid plants and seeds when these two lines are crossed.

There is a third gene in this HT mustard variety – the bar gene. The function of the bar gene is supposed to be that of a 'marker'. The bar gene synthesises an enzyme which confers tolerance to glufosinate in a plant.

Glufosinate is a broad-spectrum herbicide, similar to Monsanto's 'Round-up' (glyphosate), which indiscriminately eliminates weeds and, indeed, any plant that does not incorporate the bar gene and is hence not 'herbicide tolerant'.

Essentially, this is done to mark out the GM crops from the non-GM progeny. The ones that are non-sterile are eliminated with a glufosinate-herbicide spray. This is done ostensibly in order to ensure that pollen-free, sterile GM plants can be grown for hybrid seed production.

However, the problem is that this herbicide tolerance exists in the plants that farmers will grow when they plant GM mustard hybrid seed. This would then mean greater chemical usage by farmers, as has been seen in other countries too.

Interestingly, glufosinate is a patented technology of Bayer CropScience, and marketed worldwide as 'Liberty Link' and 'Basta'.

Why we need it – the claims

Why do we need genetically engineered mustard? Here are two broad sets of claims that have been made by the developers in Delhi University:

1. The developers claim a 28-30% increase in productivity, with the use of HT Mustard which in turn is supposed to reduce annual import bill of over Rs 60,000 crore of edible oils.

2. Biosafety Studies have been conducted. The level of risk in terms of associated toxicity and allergenicity to humans and animals by DMH-11 has been found to be “nil or negligible”, as stated by the report titled “Assessment of Food and Environment Safety of GE Mustard” (AFES, 2016: 105-06) created by a GEAC sub-committee.

10 facts to contest these claims

However, here are 10 facts that would help contest these claims:

1.The DMH-11 variety has been tested against older varieties of mustard crop – Varuna (developed in 1975) and Kranti (1982). HT variety of mustard should have been tested against the latest superior varieties and hybrids that were mandated as for all trials.

2.Though comparison across different trials in not correct, given the fact that GM mustard has not been compared against the right checks, when data from other trials is used for yields, it is seen that at least four varieties of non-GM mustard hybrids are shown to have higher productivity than DMH-11 (2,626 kg/hectare). NDDB's DMH-4 gives a 14.7% higher yield (3,012 kg/ha), followed by NDDB's DMH-1 (11.35%), Pioneer's 45-S-42 (7.35%) and NDDB's DMH-3 (3.54%).

3.The only report that has been put in the public domain is the “Assessment of Food and Environment Safety of GE Mustard” report. This AFES report – as stated by a member of GEAC and a noted molecular biologist and Supreme Court appointee in GEAC, Dr.Pushpa M Bhargava – “is not the biosafety study, it is only an assessment of the main study. The information is scanty”. It is scanty because the Environment Ministry has refused to disclose data of field trials and biosafety on grounds of confidentiality, choosing to ignore CIC and SC Orders on the subject.

Despite CIC directive, biosafety dossiers and raw data submitted by developer have not been shared

4. The Central Information Commission (CIC) directed the Environment Ministry to release all data relating to the bio-safety of GM Mustard by an order in April, 2016 following an RTI application filed by Ms. Kavitha Kuruganti. Relying on Divya Raghunandan v. Department of Biotechnology, the Ministry cannot claim confidentiality in matters of public interest. Despite the CIC directive, the full biosafety dossiers including raw data submitted by the crop developer, have not been shared by the regulators. Data relating to GM crops ought to be made available at every stage so that informed decisions can be made by associated regulatory and government bodies and by the public.

5.The AFES report only attests to the negligible toxicity and allergenicity of the three genes – bar-barstar-barnase – using mainly available bio-informatics databases. There is no independent study or cross- referencing of biosafety studies related to the use of glufosinate in the AFES report. To remind, glufosinate is a herbicide that enables the marker gene – bar – to mark the GM crop from the non-GM ones. Glufosinate is a herbicide that is not approved for use in mustard crop in India.

6.A pesticide risk assessment of glufosinate ammonium conducted by European Food Safety Authority (EFSA, 2005) classified Glufosinate as a Category 2, R61 “Toxic: may cause harm to the unborn child” and Category 3, R62 “Possible risk of impaired fertility”. (p. 14). It also reported increased kidney weight in rats in long term assessment of toxicity of glufosinate.

7.

Various studies that rule carcinogenicity, neurotoxicity or maternal toxicity do so on the basis of two strict parameters – “Accepted daily intake” (ADI) and “no-observed adverse effect levels (NOAEL)”. In other words, the absence of side effects of bodily harm will hold only if the oral intake or exposure to glufosinate is below the identified risk threshold. Based on studies conducted on rabbits, the EFSA states the NOAEL for women of child bearing potential i.e. 0.021 mg/kg bw/day.

Based on studies conducted on dogs, the NOAEL of 4.5 mg/kg bw/day was accepted. (EFSA, 2005: 2). The WHO/FAO recommended ADI for glufosinate is 0.02 mg/kg body weight.

Beyond these levels, neurotoxicity, deformities, retardation, teratogenic effects (birth defects) may result. Can we expect proper dissemination, monitoring and regulation of glufosinate application?

The question of daily intake is tied to levels to glufosinate residues that our food may carry

8.

The question of daily intake is tied to levels to glufosinate residues that our food may carry. The aforementioned tests were conducted by EFSA on three crops: maize, apples and potatoes. Most of the residues (of glufosinate) were found in the shoots and leaves of the three crops which are not the parts commonly consumed. In apple and maize, no residues were found at the time of harvest, but residues of parent glufosinate were found in potatoes. Uptake of glufosinate is through the leaves and stem which are in direct contact with the spray. Now mustard is a plant whose seeds as well as leaves are consumed. In HT mustard, it may be very likely that leaves and seeds carry residues well above the accepted daily intake.

9.The US Environmental Protection Agency (US EPA) classifies glufosinate ammonium as “persistent” and “mobile”. In one study, residues of glufosinate were found in the edible parts of spinach, radishes, wheat and carrots planted 120 days after glufosinate had been applied. (US EPA, 1988. Glufosinate Ammonium: Review and assessment of individual studies and environmental fate assessment). In sandy soils, which overlie many aquifers, glufosinate has been found to be highly persistent due to lack of biodegradation.

10.It has been reported that trace amounts of glyphosate (a cousin of glufosinate) has been found in in bread and beer, causing anxiety among consumers. The herbicide residue has also been found in cookies, crackers, popular cold cereals and chips commonly consumed by children and adults, according to Food Democracy Now and the group’s “Detox Project,” which arranged for the testing at the San Francisco-based Anresco lab. The report can be accessed here. Glyphosate is under particular scrutiny now because in 2016, WHO’s International Agency for Research on Cancer (IARC) classified it as a probable human carcinogen.

How big is the concern?

If there is no real, demonstrable need, or if there is a production deficit that can be achieved by tweaking policy measures (as was done in the 1980s through the Oilseeds Technology Mission which reduced our imports to merely 3% of the total edible oil requirement) why should we mount a technology horse whose exact course cannot possibly be known.

After all, it's better to be safe than sorry.