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“Assessment of Food and Environmental Safety (AFES)” On The Proposal for Authorisation Of Environmental Release of Genetically Engineered Mustard (Brassica Juncea) Hybrid DMH-11 and use of Parental Events (Varuna Bn3.6 And EH2 Modbs2.99) For Development of New Generation Hybrids
Full name*: Dr. GV Ramanjaneyulu
Affiliation*: Agricultural Scientist and Executive Director, Centre for Sustainable Agriculture and Expert Director at Sahaja Aharam Producer Company
Postal Address*: 12-13-445, Street no-1, Tarnaka
Pin code: 500017
Email address: firstname.lastname@example.org
- Brief Comments on AFES on GE Mustard
|As per recent Supreme Court orders, regulators are to engage in dialogue with all stake holders and this process is still on. Hence this feedback is being sent.
|Without full access to full bio-safety dossier, it is not possible to give comprehensive feedback. Pending availability of the same, following may be considered as partial comments.
|The technology for introducing male sterility using bar, barnase and barstar from Bacillus amyloliquefaciens (which uses barnase for protection from microbial predators and barstar to protect itself from barnase ) gene link to bar gene which confers resistance to the herbicide Glyphosinate is not new. Proagro earlier in November 2002 and April 2003 applied a GM mustard hybrid with the same technology and GEAC rejected the application with the following comments
· Pollen flow studies as reported by the company showed transgenes escaping upto 35m, while the ICAR trials indicated pollen flow upto 75 meters. “Considering the agro-climatic conditions and small land holdings of Indian farmers, the Committee was of the view that the non-GM mustard seed from the adjoining fields is likely to get contaminated by the male sterility barnase, barstar, neomycin and bar genes. This factor may affect the stability of the properties of the non-transgenic varieties”.
• While the company showed seed yield increase ranging from 16% to 23% over the best check Varuna indifferent GM hybrids, ICAR results showed only 5% upwards.“
• ICAR under whose supervision the trials are supposed to have taken place clarified that it did not supervise the number of trials that the company claimed, and that it conducted trials only at 4 locations which is not adequate.
• “Mustard being an edible crop, important policy issues related to labeling, traceability etc., need to be put in place prior to commercial release”
• Trial studies conducted by the company also indicated that the presence of barnase gene is about 0.31%.
• The use of Bar gene as a marker gene, increased weediness and consequent use of more toxic persistent herbicides were discussed. Further studies should be conducted by ICAR to address all biosafety issues including resistance to herbicide
• The Committee noted that mustard being an edible crop, further studies to establish health safety aspects need to be conducted
The current application GE Hybrid DMH-11 is no different. While GEAC has not raised the same questions while the problems were similar.
|ENVIRONMENTAL SAFETY ASSESSMENT STUDIES
|GE hybrid DMH-11 is inferior in vigour to the handmade conventional hybrid VEH2-F1 as mentioned in the text but the fact is not considered for experiments.
Page 77: “Shoot and root weight: Shoot and root weight were recorded as fresh and dry weight of the seedlings after 15 days after sowing, The data revealed significantly higher shoot and root weight in hand-made non-GE hybrid (VEH2-F1) as compared to the GE hybrid DMH-11 under field conditions.”
COMMENTS: It can be surmised that the GE hybrid DMH-11 is inferior in vigour to the handmade conventional hybrid VEH2-F1. Therefore the conclusions drawn in page 103 (reproduced below) are invalid. “Conclusions: ..Based on the agronomic and phenotypic parameters it can be concluded that presence of transgenes in the hybrid does not lead to any unintended effect on the agronomic parameters.”
|The yield of ‘male sterile line Varuna-barnase’ is equivalent to fertile Varuna. This is not possible.
Page 86: “From the biology document of B. juncea it is very clear that it is mainly a self-pollinating crop and its pollen is relatively heavy and sticky and generally not carried to great distances by wind. Insects, particularly bees, are the primary cross-pollinators. The highest rate of cross-pollination occurs with plants in close proximity and more so in situations where there is a physical contact with the neighbouring plants. In B. juncea the rate of out-crossing up to 11 to 17.5% have been reported. “
COMMENTS: ‘Varuna bn 3.6’ is a male sterile GE variety. Self pollination is ruled out. However, as per the data presented in the report in page 102, the yield of GE ‘Varuna barnase’ is equivalent to that of non-GE male fertile Varuna, thereby indicating the possibility of fertile pollen on Varuna-barnase or the occurrence of unbelievable 100% natural insect/bee-assisted cross pollination, which is in stark variance with available reports. Presuming that 100% insect aided cross-pollination occurs in fields, production of pure hybrid seeds under such circumstances is impossible, since insects and bees travel long distances and can pollinate the GE ‘Varuna barnase’ male sterile plants with any B. juncea pollen from anywhere.
|How insect pollination is restricted to 20 meters is a mystery
Page 86: …”Therefore, DMH-11 pollen travelled only up to 20m, as no Basta resistant seedlings were observed in the progeny of PUSA bold plants beyond 20 meter distance from the boundary of the inner plot.”
COMMENT: It is not clear how and why insects and bees can restrict themselves only to 20 metres distance of pollination. Insects travel far and wide sometimes several kilometres to effect pollination.
SUGGESTION: Genetic purity of the DMH-11 must be examined before any inferences are made.
|Male sterile genes can flow through pollen from GMS-based-hybrids and Barnase-barstar-based hybrids and not through CMS hybrids. Conclusions on page 86 are contrary to facts and are misleading
Page 86: “In farmer’s field, one of the concerns is that the crossing could occur between intra-specific varieties growing in adjoining fields. In case of DMH-11, the crossing with neighbouring B. juncea would be similar with other non-GE hybrid/varieties and no further effects are expected due to presence of the transgenes”
COMMENT: Misleading conclusion “In case of DMH-11, the crossing with neighbouring B. juncea would be similar with other non-GE hybrid/varieties and no further effects are expected due to presence of the transgenes”
|POSSIBILIOTY OF SPREAD OF STERILITY BARNASE gene INTO CONVENTIONAL VARIETIES AND ITS CONSEQUENCES
1. Barnase-Barstar based GM hybrid produces 8 kinds of fertile pollens of which 12.5% contain the Barnase gene alone and another 12.5% contain both the Barnase and Barstar genes. These 25% of pollens are likely to have detrimental consequences in native varieties due to outcrossing. The above facts are based on Mendelian Genetics. Based on the Population Genetics, the following inferences can be drawn.
2. At least 1.5% of yield will be lost with the farm saved seed of the variety which is contaminated with pollen from Barnase-Barstar GM mustard hybrid. This inference is based on standard presumptive condition of 15% out crossing in Mustard (Brassica juncea).
3. The yield losses can increase progressively every year with the farm saved seeds of non-GM variety as long as pollen contamination continues to happen from the GM mustard hybrid. If herbicide is used on the GM hybrid crop, the frequency of sterile genes will continue to increase at an enhanced rate.
4. Barnase is a dominant gene which causes male sterility in plants wherever the gene is present in the absence of barstar, unlike GMS system which is recessive in gene action and takes one generation of selfing to express itself albeit in lesser frequency compared to Barnase-Barstar system.
5. Chances of gene escape through pollen are almost nil in case of CMS as sterility genes are contained in cytoplasmic organelles.
6. Due to possible gene outflow through pollen in case Barnase-Barstar system, the detrimental male sterile genes can get into mustard germplasm including wild and weedy relatives and hence, there are potential and irretrievable risks for crop diversity and varietal diversity, which is unacceptable as per PPVFRA. The naturally occurring biodiversity and varietal diversity of Brassica spp. should never be compromised through genetic contamination of detrimental genes such as Barnase.
7. GM canola in Canada is cultivated in large tracts of land with 100% seed replacement ratio. This precludes the possibility of any contamination with the varieties since the farm saved seeds are not used. On the other hand, in India, it is extremely common for varieties to be cultivated in close proximity of hybrids in a mosaic pattern of small size farming system. Therefore, comparison of Indian mustard farming conditions with Canadian conditions will not be appropriate.
8. India with its rich diversity for mustard and its relatives the contamination can lead to a serious problem. Containment impossible and contamination inevitable
|Herbicide tolerance is introduced into the DMH-11
1. BarN genes used for selecting male sterile female plants confers tolerance to glufosinate a herbicide from Bayer (commercially traded as Basta).
2. There are number of documents which show the potential impact of Glufosinate on human beings, pollinators and environmemnt. The papers are attached.
3. Glufosinate tolerant rice (called liberty link) when accidentally contaminated rice in USA has caused huge losses and the entire export consignments were forced to withdraw.
4. The Technical Expert Committee appointed by Supreme Court as well as the Parliamentary Standing committee on GM crops have inequivocally said India should not allow herbicide tolerant crops
|EVALUATION OF AGRONOMIC PARAMETERS FOR GE HYBRID DMH-11 AND THE PARENTAL LINES
|Agronomy trials are flawed.
Appropriate varietal and hybrid checks were not used in the trials. Based on the data available, there is hardly any proof in the data to draw inferences to substantiate the claims that the GE hybrid DMH-11 can confer any additional advantage over the conventional hand-made hybrid VEH2-F1 and cytoplasmic male sterile based hybrids, DMH-1, NRCHB-506, in either yields or cost of hybrid seed production.
SUGGESTIONS: DMH-11 hybrid (Varuna bn 3.6 x EH2 modbs 2.99) should have been compared for agronomy performance with the conventional non-GM VEH2-F1 hybrid (Varuna x EH2).
Trials should have been conducted to compare the agronomic performance between the conventional hand-made hybrid VEH2-F1 and cytoplasmic male sterile based hybrids, DMH-1, NRCHB-506.
Trails did not include other agronomic innovations like System of Mustard Intensification where substantial yield improvements were observed in conventional varieties.
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