Right from the beginning, the official regulatory bodies in India have shown their inability, disinclination and sheer apathy towards proper biosafety testing and monitoring during research and commercial use. Then there are issues beyond biosafety which are not part of the impact assessment process related to GMOs in any case. A larger issue of course is the decision-making related to whether GM crops are needed at all! It is not clear where, when and how it had been decided that GM alternatives with specific traits for particular crops are definitely needed in this country.....

Right from the beginning, accountability mechanisms have always been unclear and missing even though the EPA itself has a penal clause for violations of the legislation. In fact, it is not clear if the mandate of the regulatory bodies is to protect the interests of the farmers and consumers of the country or the commercial interests of biotech promoters. The DBT for instance had always appeared to see its mandate to be that of promoting biotechnology and that biosafety concerns should be addressed by other agencies, departments and ministries.....

It is in this context that civil society groups have taken it upon themselves to project the real growing conditions of farmers, their experiences, the problems being encountered and observed and so on.  

One of the important efforts from civil society was in the area of monitoring the performance of Bt Cotton in various states. Some of the civil society groups that consistently monitored the performance of Bt Cotton include:

Andhra Pradesh Coalition in Defence of Diversity [APCIDD] - 2002-03, 2003-04, 2004-05, 2005-06

Centre for Sustainable Agriculture [CSA] - 2002-05, 2004-05

Monitoring & Evaluation Committee [MEC] of 20 civil society groups - 2005-06 (in Andhra Pradesh and Maharashtra)

Gene Campaign - 2002-03 and 2003-04

Other groups like Greenpeace India, WWF-India, FAO's pesticides policy project etc., have also monitored the performance of the crop on the ground over various years.

Civil society groups also tried to draw the attention of the regulators to various new issues cropping up, including new diseases, pests etc., by organising fact-finding visits to various cotton-growing locations (Warangal-2004, Warangal-2005, Khammam-2005, Guntur-2005 - all in Andhra Pradesh, Salem-2005, Nanded-2005 and Badwani-2005 from other states). Many of these fact finding visits were taken up as part of the MEC (Monitoring & Evaluation Committee) set up by 20 civil society groups across five states during 2005-06 in response to the non-existent monitoring from the official MEC.

In some instances, public hearings (by Banjara Development Society in Hyderabad in 2003, by Centre for Sustainable Agriculture in 2006 and by people's movements in Madhya Pradesh in 2005) were organized to allow farmers to share their experiences and concerns.

IN addition to looking at performance of the Bt Cotton crop, either compared to conventional cotton or with NPM cotton, civil society also looked at issues beyond the cotton fields. One important area was to investigate into the marketing of Bt Cotton. Another was to look at the emerging health problems encountered by agricultural workers and ginning factory workers while working with Bt Cotton. An investigation in Madhya Pradesh brought out the clear correlation between Bt Cotton and the various allergies being reported from Bt Cotton areas. Similarly, from Warangal district of Andhra Pradesh, reports of sheep mortality after grazing on Bt Cotton threw more light on the additional problems with Bt Cotton. Subsequent reports from civil society groups based on information that they obtained under Right to Information confirmed that the sheep mortality is connected with Bt Cotton grazing.

The most important regulatory failures of the GEAC and others were captured systematically by independent investigations into field trials. These investigations show that serious and unacceptable biosafety violations are a consistent feature of various trials across the country, including on GM food crops (Bt Okra, Bt Rice and Bt Brinjal).

Despite these many reports, which include systematic, season-long, scientific reports [unlike the market research reports commissioned by the biotech companies], the regulators have chosen to ignore most such reports and have only touched upon superficial issues!