Disclaimer: This booklet has been created by the Centre for Environment Education (CEE) specifically for participants of the national consultations. It does not represent the views of the Ministry of Environment and Forests, Government of India or the Centre for Environment Education.
Introduction
Bt Brinjal is a genetically modified form of brinjal that involves inserting a cry1Ac gene from Bacillus thuringiensis, a bacteria found in soil, into the brinjal plant. The purpose of this genetic modification is to provide resistance against specific insects such as the Brinjal Fruit and Shoot Borer Leucinodes orbonalis and Fruit Borer Helicoverpa armigera.
Controversy Surrounding Bt Brinjal
The introduction of Bt Brinjal in India has sparked extensive debate. Supporters argue that it offers significant benefits to small farmers as it protects plants from insects, increases crop yields, reduces expenses, and has minimal negative impact on the environme
nt.
The Ministry of Environment and Forests (MoEF) has addressed concerns regarding the impact of Bt Brinjal on human health, bio-safety, livelihoods, and biodiversity. The MoEF's Genetic Engineering Approval Committee (GEAC), following recommendations from the Review Committee on Genetic Manipulation (RCGM) and two expert committees established by the GEAC between 2006 and 2009, has proposed releasing Bt Brinjal into the environment in India. However, acknowledging strong opinions both in favor of and against its introduction, the Minister of State (I/C) for Environment and Forests has decided to conduct nationwide public consultations before making a final decision. To facilitate these consultations, the Centre for Environment Education has been entrusted with organizing them. The primary objectives of these consultations are to allow stakeholders in different locations across India to express their perspectives and concerns about Bt Brinjal while providing valuable input
to the Minister prior to reaching a final decision.
The purpose of these consultations is to encourage the involvement of stakeholders with different perspectives in an inclusive manner. The consultations will be open to the public and will be conducted in the local language, as well as Hindi and English. Each consultation will invite a minimum of 250 representatives from diverse groups such as farmers, scientists, agricultural experts, farmers organizations, consumer groups, citizens forums, NGOs/CBOs, Government officials, media personnel, seed suppliers, traders, doctors, lawyers and others.
Advertisements will be placed in the local media prior to the event to fully inform the public about the event. The consultations at all locations will be led by Mr. Jairam Ramesh, who is the Minister of State (MoS) MoEF.
The brinjal, scientifically known as Solanum melongena, holds great significance in India. It is believed to have originated in India and has been cultivated for over 4000 years. Furthermore, it ranks as the second most produced crop after potatoes and remains a vital domestic crop in India, contributing 9% towards total vegetable production while covering 8.4% of vegetable cultivation land.
In India, there are approximately 2500 different types of brinjal in the Kingdom: Plantae. These brinjals come in various shapes such as oval or egg-shaped to long or club-shaped, and colors ranging from white, yellow, green, purple to almost black. They fall under the Class: Magnoliopsida and Subclass: Asteridae in the classification system. The family they belong to is Solanaceae and their genus is Solanum with a species name of melongena. Many of the brinjals available in today's market can be traced back to older varieties originating from India and China.
Brinjal is a
vegetable low in calories and fats but high in water content. It contains some protein, fiber, carbohydrates along with minerals, vitamins, water-soluble sugars, amide proteins, and other nutrients. This widely consumed vegetable holds great significance in the Indian diet nationwide. It also plays an important role in Ayurvedic medicine and offers specific benefits for individuals dealing with diabetes or liver problems.
The brinjal, also known as eggplant, is consumed both cooked and raw. It is used in various famous dishes from different regions of India. For example, in Eastern India, there is a dish called begun bhaja. Andhra Pradesh has a dish called gutti vankaya kura, while Tamil Nadu is known for katharikai kozhambu. In Kerala, it is used in a dish called upperi and in Karnataka, it's used in vangi bath. Maharashtra has the wangyacha bharit dish, Gujarat has olo and bharatu dishes, and Bihar has baingan jhonga dish. The brinjal also appears in folk songs from various parts of the country such as the Guthi vankya kooroyi baava song from Andhra Pradesh or Konkani songs from Maharashtra or Jaina songs from Karnataka or Bihu folk songs from Assam. The religious significance of brinjal can be observed through the traditional variety named Mattu Gulla found in Udupi District in Karnataka.
The brinjal crop in India has been cultivated in the region for at least 500 years and is offered to the main deity at the Sode matha temple. The brinjal is usually self-pollinated, but cross-pollination can range from 2% to as high as 48%. It is classified as a cross-pollinated crop due to the stigma projecting beyond the anthers, allowing for ample opportunity for cross-pollination. The
actual rates of natural cross-pollination are determined by the genotype, location, and insect activity.
The brinjal crop is affected by various pests, including the brinjal fruit and shoot borer, brinjal stem borer, mealy bug, lace wing bug, leaf hopper, leaf rollers, red spider mite, leaf-eating beetle, jassids, aphids, white fly and root knot nematodes. Among these pests, the most significant threat comes from the brinjal fruit and shoot borer which can cause a considerable loss in yield suitable for sale. Brinjal crops are commonly grown in small plots or as intercrops. The main states responsible for brinjal production in India are West Bengal Orissa Bihar Gujarat Maharashtra Karnataka Uttar Pradesh and Andhra Pradesh.
The average yield of brinjal varies from 15 to 30 tonnes per hectare, based on the variety and season. Certain hybrid varieties have the potential to yield as high as 50 tonnes/ha. Brinjal is an economically beneficial crop for farmers, with a research indicating an input-output ratio of 1:2.01. Nonetheless, in 2006, the National Horticulture Board disclosed no specific land being allocated for brinjal cultivation.
In 2007-08, India exported a total of 338 tonnes of brinjal valued at Rs 1.92 crores. The country's brinjal production reached 9.13 million tonnes on 55 million hectares. Among the importers, the United Kingdom was the top importer with a total import volume of 258 tonnes.
India imported the highest amount of genetically modified crops, specifically Bt Brinjal, which totaled 84 tonnes and valued at Rs 1.38 crores. Saudi Arabia, France, and Germany followed India as the next top importers. Genetic engineering, also referred to as genetic modification (GM), genetic manipulation, or genetic engineering (GE), is a method that utilizes recombinant
DNA technology to transfer a specific portion of genetic material with the ability to carry out new functions from one organism to another.
Genetically Modified (GM) crops are plants that have been genetically engineered by inserting a gene from another species into their genetic makeup. This differs from traditional breeding methods, where desired traits are achieved by crossing plants to pass on inherited genes.
GM technology is used to modify an organism's genes in ways that traditional breeding cannot, leading to the development of new plant varieties with diverse traits. These traits encompass resistance to environmental conditions and pests, longer shelf life, and enhanced nutrition. To expand biotechnology research capabilities, the Indian government established the Department of Biotechnology (DBT) in the 1980s. To regulate potential risks associated with products derived from modern biotechnology, such as GMOs, the Ministry of Environment and Forests (MoEF) implemented the Environmental Protection Act (EPA) rules in 1989.
The government places significant emphasis on agro-biotechnology tools like Genetic Engineering for improving agricultural production because agriculture plays a vital role in India's economy. Consequently, substantial funding and support have been allocated for Genetic Engineering and GM crops. The global market witnessed the introduction of Genetically Modified Organisms (GMOs) in the early 1990s.
Biotechnology tools like Genetic Engineering and Marker Assisted Breeding have revolutionized agriculture, increasing production. Understanding and modifying organism genetics has led to significant investments in agro-biotechnology research and development. Currently, India commercially cultivates only Bt cotton as a transgenic crop, but there are 12 crops (including 11 food crops) at different developmental stages. The objective of GM research in India is to develop crops that can withstand biotic and abiotic stresses while improving product
quality.
The process of genetic modification in plants involves copying and transferring genes from one organism to a plant, made possible by the presence of deoxyribonucleic acid (DNA) in every cell of all organisms. Genes, which consist of discrete segments of DNA, contain instructions for cell function and characteristics found in living organisms such as plants.
The plant genome is the complete set of genes found in a plant. Every cell in a plant contains an identical and complete genome, meaning each cell has at least one copy of every gene, although some genes may not be active. Plant cells can specialize into different types such as leaf, root, and flower cells by activating or deactivating various combinations of genes. Cells are considered the smallest unit of life with their nucleus acting as the central control system. Chromosomes hold genetic information, while genes represent smaller segments of this information. DNA is the fundamental building block for genes and has a double helix structure. Figure 1 illustrates how DNA is organized within a cell. It's important to note that all organisms have DNA composed of the same building blocks and encoded similarly.
One way to transfer a gene, which is a copy of DNA sequence that codes for a specific characteristic, into another organism's cell is by transferring genes from bacteria to plants. When the gene becomes part of the plant's genome, it leads to genetic modification and the new characteristic encoded by this gene is passed down in future generations.
The process of genetic engineering or modification involves transferring genes or fragments of genes from one organism to another in order to create unique traits in the recipient organism.
The development of genetically modified (GM) plants involves several steps:
a. Identifying genes with desired traits
b. Designing genes for insertion
c.
The process involves transferring to plant tissue, selecting and regenerating plants, conducting laboratory analysis and safety testing, performing greenhouse and field trials, obtaining approval from government agencies, and finally commercializing the product.
Monitoring the effectiveness and safety is initiated by identifying a distinct trait in any organism (be it a plant, animal, or microorganism) and determining the responsible genes.
After isolating the gene, a gene construct is created. This construct consists of a promoter sequence, termination sequence, and marker gene to guarantee successful integration and expression within the plant's genome.
The subsequent step entails plant transformation, which involves incorporating the introduced DNA into the plants. There are two main methods for achieving plant transformation.
The genetic modification of plants can be achieved through different methods, such as the Agrobacterium mediated method and the gene gun method (Figure 2). In the Agrobacterium mediated method, the Agrobacterium bacterium is mixed with plant cells to insert the gene of interest into a plasmid. This plasmid containing the gene is then replicated. On the other hand, in the gene gun method, DNA-coated gold particles are shot into plant cells to incorporate DNA into their chromosomes.
In both methods, it is essential to screen for successfully modified cells that contain the desired gene. This screening process involves selecting cells with a selectable marker, which could be a gene providing resistance to antibiotics or herbicides. Only cells expressing this marker will survive. These transformed cells are then utilized to regenerate transgenic plants from a single transformed cell.
To summarize, genetic modification of plants involves five main steps: identification and
isolation of genes of interest, insertion into a transfer vector, transfer to the organism being modified, transformation of organism's cells with genes, and selection of genetically modified organisms (GMOs) from successful modifications. Following the gene insertion process, plant tissues are transferred to selective medium containing antibiotics or herbicides. The process entails selecting plants with both the selectable marker gene and desired transgene.Later stages of the process involve using these selected plants.
Tissue culture is utilized in a controlled environment to cultivate transgenic tissues, like immature embryos. This process involves the use of nutrient and hormone-rich media. The resulting whole plants are then evaluated, ensuring the stable integration of the inserted gene without any adverse effects on other plant functions, product quality, or the intended agroecosystem. Additionally, the activity of the introduced gene and any unintended impacts on plant growth, yield, and quality are assessed. To achieve efficient transformation, the transformed plant is bred with enhanced crop varieties. However, these improved varieties lack certain desired traits found in modern cultivars. Henceforth, multiple rounds of crosses with the improved parent – referred to as backcrossing – must occur following the initial cross. The objective is to regain as much of the improved parent's genome as possible while incorporating the transgene from the transformed parent.
The next step in the process involves conducting multi-location and multi-year evaluation trials in both greenhouse and field environments to test the effects of the transgene and overall performance. This phase also includes the evaluation of environmental effects and food safety.
How was the Bt Brinjal created? Bt Brinjal is India's first genetically modified food crop that has reached the approval stage for commercialization. The development
of Bt Brinjal involved inserting a gene cry1Ac from a soil bacterium named Bacillus thuringiensis using an Agrobacterium-mediated gene transfer. This genetically modified brinjal was developed by the Maharashtra Hybrid Seed Company Ltd.
(Mahyco) is a prominent Indian seed company that has developed Bt Brinjal event EE1 in a Public Private Partnership (PPP) mode. This development was made possible through the Agriculture Biotechnology Support Project at Cornell University, where the Bt technology owned by Mahyco was transferred (free of cost) to Tamil Nadu Agriculture University in Coimbatore, University of Agricultural Sciences in Dharwad, and the Indian Institute of Vegetable Research in Varanasi. Bt brinjal contains three inserted foreign genes, specifically:
- The cry1Ac gene from the common soil bacterium Bacillus thuringiensis (Bt) subsp.kurstaki, which encodes the insecticidal protein Cry1Ac. The expression of this gene is regulated by the cauliflower mosaic virus (CaMV) 35S promoter.
- The nptII gene, which serves as an antibiotic resistance marker called neomycin phosphotransferase-II.
- The aad gene, another marker known as 3” (9) O-aminoglycoside adenyl transferase. These genes confer resistance against pests like fruit and shoot borers and help minimize damage.
Additionally, Mahyco has developed a novel DNA construct that incorporates a gene sequence for encoding the insecticidal protein throughout the lifetime of the brinjal plant.The cry1Ac gene, as well as the nptII and aad genes, are combined in a way that allows them to work together to produce a toxic insecticidal protein. This protein is effective against pests such as the fruit and shoot borer. When larvae of the fruit and shoot borer feed on Bt brinjal plants, they consume both the Bt protein Cry1Ac and plant tissue. Inside the alkaline insect gut,
which has a pH greater than 9.5, the protein is solubilized and activated by gut proteases. It then crystallizes into fine needle-like shards that penetrate the lining of the insect gut, creating holes.
This leads to disruption of digestive processes, paralysis, and subsequent death of the fruit and shoot borer larvae. The history of the development of Bt brinjal in India is as follows:
- 2000: Transformation and greenhouse breeding for integration of cry1Ac gene into brinjal hybrids and seed purification
- Preliminary greenhouse evaluation to study growth, development, and efficacy of Bt brinjal
- Confined field trials to study pollen flow, germination, aggressiveness, and weediness; biochemical, toxicity, and allergenicity studies; and backcrossing into the regular breeding program
- RCGM approves conducting multi-location research trials of seven Bt brinjal hybrids
- Through a MoU under the aegis of Agribiotechnology Support Programme II (ABSP II) of USAID, Mahyco shares the technology with TNAU, DAU, and IIVR to develop open-pollinated varieties of Bt Brinjal
- Backcrossing and integration of EE1 into 4 varieties of TNAU, Coimbatore, and 6 varieties of UAS, Dharwad are done.
Biosafety data regarding the impact of Bt brinjal on various aspects such as soil micro-flora, efficacy against fruit-shoot borer, pollen flow, germination, aggressiveness, weediness, toxicity, allergenicity studies, and chemical composition were submitted to the Review Committee on Genetic Modification (RCGM). RCGM then recommended conducting large-scale trials to the Genetic Engineering Approval Committee (GEAC). Mahyco, in turn, submitted the biosafety data to GEAC and requested permission for these trials. The timeline for these activities spans from 2001 to 2006. Furthermore, GEAC made the biosafety data on Bt brinjal available on their website and also formed a subcommittee to address concerns voiced by the civil society.
- The Supreme Court
stops the ongoing field trials of GM crops in response to a PIL filed by civil society representatives. In 2007, the subcommittee (also known as expert committee 1) submits a report suggesting that 7 more studies on bio-safety should be repeated to confirm the data obtained during confined multi-location trials. However, they give permission for large-scale trials. - The Supreme Court removes the ban on GM crop field trials with certain conditions, such as isolation distance. - The Genetic Engineering Appraisal Committee (GEAC) approves the large-scale trial.
- The Indian Institute of Vegetable Research (IIVR) took on the responsibility of conducting large-scale trials of Mahyco's Bt Brinjal at 10 research institutions in 2007 and 11 in 2008, as directed by the Genetic Engineering Appraisal Committee (GEAC). In January 2009, IIVR submitted the results of these trials. However, due to concerns raised by various stakeholders, including national and international experts, GEAC formed a second sub-committee (Expert committee 2 or EC2) to assess the adequacy of the biosafety data and address the raised concerns. In October 2009, this process was initiated.
On the 14th, the Subcommittee presents its report, leading to the approval of the environmental release of Bt Brinjal with event EE1 by GEAC. On October 15th, in response to strong arguments both in favor and against the release of Bt Brinjal, the Minister of State for Environment and Forests (I/C), who receives reports from GEAC, initiates a nationwide consultation in January and February of 2010 before making a final decision on this matter. The prospects and concerns surrounding Bt brinjal have sparked a heated debate in India regarding its necessity and regulation process. This discussion has centered
on various issues such as its impact on human health, the environment, farmers' seed rights, and consumer choice.
Both industry promoters and scientists from both the public and private sectors in India consider Bt Brinjal to be a significant advancement in agricultural research and development. However, there are opponents to Bt Brinjal, including scientists, civil society groups, farmers unions, and even some political parties, who argue that the risks outweigh the benefits.
Arguments in favor of Bt Brinjal include its effectiveness in pest management and its positive environmental impacts. Brinjal cultivation currently involves the usage of large amounts of pesticide, with 60% of the cost for plant protection being spent on controlling fruit and shoot borer. However, proponents argue that Bt Brinjal allows for effective non-pesticide pest management and that Integrated Pest Management techniques are already being practiced by small and marginal farmers.
The challenge of using 25-80 internal sprays of pesticides in Brinjal cultivation persists. Despite the widespread utilization of chemical pesticides, effectively controlling pests with these substances poses a risk to consumer health. The only viable solution for ensuring healthy crop production lies in implementing integrated pest management systems and adopting sound farming practices. A healthy farm ecosystem is essential, as larvae often remain concealed within the fruit and do not come into direct contact with insecticides. Additionally, farmers must carefully time the application of pesticides to eradicate larvae before they penetrate shoots and fruits.
- Botanical pesticides are not effective in managing pests. This includes using good seeds, proper irrigation, and improving soil quality.
- Some pests hide inside fruits/shoots and are not affected by botanical pesticides. These pesticides also have limited efficacy against
these pests.
were studied for a short period of time and there is no cross-pollination between cultivated brinjal and wild varieties. India is the center of origin and diversity of brinjal, with over 4000 years of cultivation and approximately 2000 varieties grown across the country. The transfer of the transgene to local species may result in different agronomic or morphological traits compared to non-Bt brinjal, potentially giving it an advantage over other species in the ecosystem. The use of hybrid varieties of brinjal, including Bt brinjal, could lead to the destruction of our brinjal diversity, which poses risks to human health and biosafety.GM crops should not be grown in the center of origin to prevent the extinction of native varieties due to cross-pollination with genetically modified plants.
Both human health and environmental safety are important considerations. The use of this transgenic brinjal, which is resistant to pests, can reduce the need for pesticides. However, there have been concerns about the lack of thorough testing for the impact on human health. Currently, no long-term studies have been conducted, as required by Indian regulations.
This paragraph discusses a range of toxicity studies conducted on Bt brinjal, a genetically modified vegetable. These studies include acute toxicity tests on laboratory rats, sub-chronic oral toxicity studies, allergenicity studies on rats and rabbits, and feeding studies on fish, chickens, goats, and milking cows. However, it is mentioned that there was no significant difference observed in a 90-day sub-chronic test on healthy adult rats. It is also acknowledged that there is a lack of studies on the possible health impact of Bt brinjal on humans, despite the fact that brinjal is commonly consumed. Furthermore, no significant
chronic toxicity studies, including carcinogenicity studies, have been carried out. There is a distinction noted between Bt brinjal and non-Bt brinjal in terms of allergenicity; however, further testing is needed in areas such as acute oral toxicity, subchronic oral toxicity in rats, allergenicity of protein to rats, germination, weediness and aggressiveness tests, and soil micro-biota studies. Additionally, it is mentioned that there are reports of a Bt variety with enhanced inherent properties such as allergenicity.
When pesticides were first introduced and promoted, they were believed to be safe for human health. At that time, the age of rats when they reach reproductive maturity was considered equivalent to 2125 years in humans. Therefore, a 90-day study was deemed sufficient. However, we have since learned important lessons about the true impacts of pesticides. The advent of Genetic Engineering brings significant and still uncertain consequences for human health. In India, Brinjal is commonly consumed lightly cooked.
In traditional medicine, the ingestion of brinjal is performed by a third party and verified by various levels of the regulatory system. The Cry1Ac endo-toxin, which is an enzyme, undergoes degradation through cooking. This enzyme remains effective solely in an alkaline environment, and as humans consume brinjal exclusively when cooked, it will not disrupt digestion. Furthermore, the introduction of the Cry1Ac toxin will have no impact on the digestive process due to the stomach's acidic nature.
The toxin in Bt brinjal, known as Cry1Ac, is harmless to humans because it breaks down into amino acids during digestion. These amino acids are normal components of our diet and do not cause toxicity or allergies. However, the Cry1Ac toxin can still harm the gut of fruit and
shoot borers, which have an alkaline digestive system. It is important to note that the Cry1Ac toxin is dangerous in its raw form, but once it enters the human digestive system, it becomes less harmful. The human digestive system is mildly acidic only in the stomach, where food stays briefly before moving to the duodenum. In the duodenum, the environment becomes alkaline to support the performance of digestive enzymes like tryptase, amylase, and lipase.
The remaining part of the human digestive system maintains an alkaline environment. Thus, if the Cry1Ac toxin is effective in an alkaline medium, it will be highly absorbed into the human body, resulting in increased toxicity. Currently, India does not require a comprehensive labeling and liability system to address this issue. Even if we implement a differentiation between labeling laws, it may not be helpful as only a small amount of Brinjal or any vegetable is packaged and sold.
No studies have been conducted on the accumulation or wash-out time span of this specific endo-toxin in Bt. brinjal. In the past, the absorption and accumulation of these endo-toxins have been found to be potentially carcinogenic to humans. The existing assessments have overlooked the impact of Bt brinjal on Indian systems of medicine, which is a significant oversight considering that brinjal and related plants are utilized in Ayurveda, Siddha, and other traditional practices. It is unclear whether the introduction of Bt brinjal could render Indian systems of medicine ineffective or even pose a toxicity risk when using brinjal.
In Ayurveda, there are approximately 14 different types of brinjal that are utilized for medicinal purposes. Each variety possesses unique medicinal properties. Any modification to
the fundamental characteristics of the plant will affect the taste, properties, potency, end taste, and synergetic properties of the drug. These properties are specifically encoded for each drug, enabling physicians to select the appropriate drug for a particular ailment. Transgenic alterations would modify these properties and create a new plant with unknown coding. Furthermore, Bt brinjal enhances marketable yields, thereby increasing farmers' incomes and considering livelihoods and economic aspects.
During trials, it was observed that average shoot and fruit damage in Bt brinjal hybrids was lower compared to non-Bt brinjal hybrids. However, Bt brinjal has not been compared with other agricultural practices like non-pesticide management or integrated pest management practices, which are currently being successfully implemented in the country. Additionally, the majority of farmers in India save and re-use seeds for hybrid varieties. Farmers practicing organic farming can do so by following established agronomic practices such as maintaining isolation distances and considering differences in flowering time.
For preventing cross-contamination and ensuring identity preservation for organic produce, it is important to consider the rates of crosspollination and its occurrence decreases with increasing distance from pollen source. However, at present, the percentage of organic brinjal growers/exporters is insignificant in the total production of brinjal in the country. Moreover, the pricing of the seeds will be affordable for small and marginal farmers, but this means the possibility for maintaining isolation distances is non-existent. Therefore, there is no guarantee that the prices will actually decrease.
Increased input costs may actually lead to an increase in the price of Bt brinjal. This can be observed in the case of Bt cotton, where the cost of seeds has risen.
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