Category Archive Memorandums

Untested and Unapproved pesticides mandatory for seed treatment

190519 FAW outbreak
In a shocking incident the Seeds Division, Ministry of Agriculture, Government of India has issued a directive signed by Mr. Dilip Kr. Srivatsava, Asst. Comm (QC), making compulsory seed treatment with cyantraniliprole and thiomethoxam , we are shocked to see that such a direction is given in spite the formulation not registered in India and also not been evaluated in AICRP program and purely based on the feed back from seed growers feed back that the seed treatment giving protection for 2-3 weeks after germination. This is violation of Insecticide Act

we are amazed that the chemical seed treatment of an un-evaluated and un-registered formulation has been given more prominence in your advisory than all the collective wisdom and established field experience of farmers, organizations and state governments on Non Pesticidal Management, Natural Farming and Organic Farming.  monitoring and scouting measures to be taken up other than cultural, mechanical and bio-control measures being recommended. Furthermore, it has been made compulsory and we are keen on understanding the scientific basis for the same.
Biosafety issues with the chemicals recommended
Even if we assume that the emergency situation, it is illegal to make it compulsory to use chemicals which are not tested and registered in India.  As per the Central Insecticides Act, 1968[1] the Central Insecticide Board and Registration Committee (CIBRC) under the Directorate of Plant Protection, Quarantine & Storage, Department of Agriculture & Cooperation is supposed to register each pesticide in the country after scrutinizing their formulae and claims made by the applicant as regards its efficacy and safety to human beings and animals. The Registration Committee is also expected to specify the precautions to be taken against poisoning through the use or handling of insecticides.  The recommendations made has not taken into account the international published information which show the following serious concerns with cyantraniliprole and Thiamethoxam.
Cyantraniliprole is a systemic insecticide belonging to the diamide class of pesticides. Cyantraniliprole works by binding with insect ryanodine receptors, which leads to unregulated activation of ryanodine receptor. Insects exposed to cyantraniliprole “first exhibit lethargy, followed by muscle paralysis, and then death.” says the CYANTRANILIPROLE RISK ASSESSMENT by US Environmental Protection Agency[2]. It further states that
As a systemic insecticide, translocation of cyantraniliprole through the xylem and phloem results in expression of the chemical throughout exposed plants, resulting in multiple routes of exposure for various non-target organisms, including mammals, fish, invertebrates and plants.
Cyantraniliprole biodegradation proceeds more slowly in aerobic conditions than anaerobic conditions, suggesting that it could be fairly persistent in the agricultural environment and adjacent ecosystems.
Degradation times in soils and sediments reached 89 and 25 days, respectively, showing an extended period of activity after application. When the total toxic residues were calculated (including degradates), a range from 88 to 1327 days was identified. Cyantraniliprole is also characterized as moderately mobile, meaning that it can move off-site and affect nearby terrestrial and aquatic ecosystems. Some of the degradates of cyantraniliprole are more persistent and mobile than the parent compound, a concern for ecological effects as some may be more toxic than the parent and may accumulate over time.
Thiamethoxam is a second-generation neonicotinoid compound that belongs to the chemical subclass thianicotinyls and acts on target pests by interfering with the nicotinic acetylcholine receptor[3].  It is known to impair honeybee flight ability[4]. There are also evidences and published data which shows that TMX. as it is called, may also pose reproductive risks on mammalian reproductive health[5]. The American Bird Conservancy (ABC) report, The Impact of the Nation’s Most Widely Used Insecticides on Birds[6], concluded that it would take only six corn seeds coated with thiamethoxam to achieve a 50 percent chance of lethality (LD50) given sensitivity at the 5% tail of bird distribution, assuming an avian body weight of 50 g – somewhere between a large sparrow and a blue jay. Like-wise only 0.3 (roughly a third) of a treated seed would be enough to impair reproduction.
Adverse Impacts of Cyantraniliprole Products Co-Formulated with Thiamethoxam
While independently both the chemicals have their own biosafety problems, the co-formulated products may have much more severe impacts.  EPA conducted a specific risk assessment of this mixture and concluded that “the typical end-use products with thiamethoxam are also modeled because they presented more sensitive toxicity values than their technical-grade counterparts.”  In other words, this mixture of these two pesticides is more dangerous than the pure, technical grade active ingredient in isolation. EPA’s own initial analysis determined that “cyantraniliprole-thiamethoxam mixture would require buffer in excess of 1000 ft for all uses.”[7]
As the Fall Army Worm is a polyphagous pest, the order amounts to making the seed treatment with cyantraniliprole-thiamethoxam mixture for almost every crop mandatory, which can be an ecological disaster.
Hence, we request the Plant Protection Division, Directorate of Plant Protection Quarantine & Storage to retract this decision by the seeds division as it a violation of law a potentially dangerous chemicals are introduced without any basic research and registration.  This will set a serious bad precedence to violate the law.

Moving towards Agroecological Approaches
It is clear that the incidence of and losses due to FAW are largely due to increasing monoculture of maize and excessive use of chemical pesticides which is leading to disturbance of the ecological balance.
The major pest outbreaks in the last three years, if we consider, are Pink Boll Worm in Cotton across the country, Brown Plant Hopper in Odisha, parts of Andhra Pradesh, Fall Army Worm across the country.  All these outbreaks are in the areas of high monoculture of these crops and high use of chemical pesticides.  Whereas, the areas under agroecological approaches like Non Pestidical Management (NPM), Organic and Natural Farming, Zero Budget Natural Farming (ZBNF) have not shown any high incidence of the pest. Therefore, the solution lies in moving towards agroecological approaches which can restore back the ecological balance rather than doing more of the same with monocultures.  The experiences across the world proved the same.
The Non Pesticidal Management experience in Andhra Pradesh (united) between 2004 to 2010[8] showed that if farmers can be trained well on understanding their agroecosystem and trained on effective use of local resources, pests can be managed with a combination of scouting, preventative care, use of locally available botanicals and animal waste and without out using chemical pesticides.  While number of studies on these experience shows that the chemical pesticide use is reduced, neither major pest out breaks nor yield reductions were recorded.  In villages where Centre for Sustainable Agriculture ( Maize is grown and could be managed with minimalistic damage. The emphasis on deep summer ploughing, pheromone traps, prophylactic sprays of 5% NSKE, inter-cropping and using of trap crops, erection of bird perches, effective weed control, release of Trichogramma for bio-control, spraying of Bt powder formulations, application of dry sand into affected whorls etc. are all to be taken up with equal emphasis, that too on community-based, and area-wide approach for proper management.
The Zero Budget Natural Farming[9] model in Andhra Pradesh where large no of farmers also cultivates maize, the crop could be managed with the ZBNF + practices.  FAO was also involved in training farmers on agroecological approaches through Farmer Field Schools.
Similarly, the organic farmers across the country who grow maize as intercrop/mixed crop with organic farming practices have not reported any serious damage with Fall Army Worm as it happened in the monoculture maize crop under high input intensive cultivation.
Several studies from Africa observed that FAW damage was found to be lower for maize crops established through zero-tillage compared to maize crops established through conventional tillage[10], The lower FAW damage was also found when manure or compost were applied.  Similarly, the push-pull system, a stimulo-deterrent cropping strategy consisting of intercropping cereals with herbaceous legumes and surrounded by fodder grasses, is presented as a promising crop diversification strategy contribute to maize stemborer suppression, while improving soil fertility and providing feed for livestock[11].
Similarly, National Institute for Plant Health Management (NIPHM) has come out with what they call as ecological engineering[12] based on the Integrated Pest Management (IPM) model.
All these experiences show that a scientific approach to manage any pest including the Fall Army Worm is shifting towards agroecological approaches and not blindly recommend couple of toxic chemicals which may provide protection only for the initial 2-3 weeks of the crop.  The experience with a similar chemical Imidacloprid is still in front us, the bee collapse it has caused due to indiscriminate use.
It is this lack of balanced emphasis on cultural, mechanical and biological control measures with an over-emphasis on chemical approaches that has led to the current crisis, which then becomes the basis for further unscientific and unsafe technologies to be ushered in, like transgenics.
It is clear that timely, coordinated management practices will certainly help in checking the spread of FAW, and that the current urgency should not be used for promoting any untested, unproven and potentially hazardous solutions.
We urge the Ministry of Agriculture & Farmers Welfare to kindly refrain from promoting any unreasoned and unscientific recommendations – Thiamethoxam, for instance, has been banned on field crops in the European Union, given its adverse impacts on bees. The chemical is being considered for phasing out in Canada, where it is used as a seed treatment chemical (including on corn) after a review of impacts on aquatic insect species.
Thank you
(G V Ramanjaneyulu)
Executive Director
[2] CYANTRANILIPROLE RISK ASSESSMENT–joint-cyantraniliprole-registration-comments–final_16053.pdf

Memorandum to AP Chief Secretary on Loan Waiver

140622-Chief-Secretary-Telangana-final Download
Rytu Swarajya Vedhika has a submitted a memorandum with the following demands.

  1. As a first measure, the Government must delink the loan waiver proposal from distribution of Kharif loans for the current agricultural season and should immediately take action to disburse crop loans  without delay to all the farmers including Tenant farmers.
  2. While the farming community is in deep crisis due to indebtedness, loan waiver is not a solution to end the crisis. The crisis is still continuing even after the debt waiver and relief extended during 2008.   A comprehensive solution lies in bringing in policy changes related to all aspects of agriculture (Credit, input support, extension and marketing) as well as pursuing the land reforms agenda with renewed vigour to bring about a meaningful change in the agriculture sector to help close to 85% ofsmall and marginal farmersto secure and sustain their livelihoods. . A piecemeal, myopic solution to the problem in the form of loan waivers alone is a grossly inadequate solution to the larger, complex set of problems ailing the farming sector in the State.
  3. Tenant farmers, dalits, tribal and women farmers who received lands under various land distributionschemes do not have access to institutional credit. They are taking loans from private money lenders, input dealers or Microfinance Institutions at a higher interest rate (as high as 60% Rs. 5 per Rs. 100 per month).  These farmers  are in deep crisis and constitute a large chunk of farmers committing suicides. This loan waiver is of no help  to them.
  4. Government should make immediate effort to increase access to institutional credit to real cultivators.  One of the problems often expressed by the bankers in giving crop loans to these farmers is the lack of a guarantee for repayment. The state government should establish a Credit Guarantee Fund for small and marginal farmers which can give collateral security to the tenant farmers.
  5. All the real cultivators who are not covered under institutional credit are to be organised into cooperatives and linked to the institutional credit.  All their high interest private loans can be swapped with low interest bank loans.
  6. Loans of all farmers who have committed suicides since 1997 have to be waived and their private loans be swapped with no interest bank loans.
  7. Government should introduce special budget for agriculture with an allocation of atleast 10% of the total budget.
  8. Government must ensure that the loan waiver does not benefit non-cultivating, absentee land owners who have other major sources of income or livelihood and have taken loans in the name of agriculture. Specific mechanisms must be evolved to identify and eliminate the above categories of landowners from the purview of the loan waiver scheme. Further, steps must be taken to identify the actual cultivators and update the revenue records accordingly. Government must also actively explore mechanisms (e.g. setting up a separate Committee) for evolving a set of criteria to enable eligible farmers benefit from the loan waiver scheme in a meaningful manner.
  9. Government should also take care that the loan waiver does not apply to ineligible loanees through the following measures
    1. Restricting the loan waiver only to crop loans
    2. In case government decides to waive short term and allied sector loans, it should be restricted to small and marginal farmers only (up to 4 ha in rainfed areas, 2 ha in irrigated areas)
    3. Exempting Hyderabad district from the purview of the loan waiver. A thorough enquiry should be conducted and if need be waiver can be extended in the second phase. Pending this, the crop loan waiver up to one lakh for all farmers in the other district should be done immediately.
  10. Government should with stain from any effort to impose additional taxes or issue bonds and transfer the burden on to people or the next government.

Mr. Prime Minister – You are wrong. GM crops are dangerous, and there is sound scientific evidence. says Coalition for GM Free India

Mr. Prime Minister – You are wrong. GM crops are dangerous, and there is sound scientific evidence. says Coalition for GM Free India

Coalition challenges the PM to prove that concerns about Bt Crops are prejudiced.

New Delhi, 4th Feb, 2014: Reacting to the promotional statement on Genetically Modified (GM) crops by the Prime Minister Dr Manmohan Singh in his inaugural address at the Indian Science Congress which started in Jammu yesterday [1], the Coalition for a GM Free India stated that the Prime Minister is wrong and wilfully misleading the nation on the issue of genetically modified (GM) crops.

The statement by the PM that the nation “should not succumb to unscientific prejudices against Bt crop” comes at a time when there is a growing body of scientific evidence on the adverse impacts of GM crops on human health, environment and farm livelihoods. The Coalition had recently released a compilation of more than 400 abstracts of peer reviewed scientific papers that points to the various adverse impacts from GM crops [2].

The Final Report of the Technical Expert Committee (TEC) set up by the Supreme Court of India in a PIL against open releases of GMOs into the environment has pointed to the inherent risks associated with GM crops and the absolute failure of the Indian regulatory system on GM crops. The TEC comprised of eminent scientists from the fields of molecular biology, toxicology, biodiversity, nutrition science etc had recommended against any open release of GM crops including for experimental trials, until a robust regulatory system is put in place. This was followed by more than 250 eminent Indian scientists including Padma awardees and 11 current and former Vice chancellors, writing to the Prime Minister about the serious concerns on GM crops[3]. They demanded that the Government of India stay clear of any vested interests and accept the recommendations of the TEC Final report as it is based on sound science, principles of sustainability and intergenerational justice.

Challenging the PM to prove his point that concerns about Bt Crops (GM crops with  toxin genes from the soil bacteria Bacillus thuringenesis) are unscientific and prejudiced, the coalition also reminded that it was his own Government had agreed to serious lacunae in the biosafety studies related to Bt Brinjal, the first GM food crop that came up for commercialisation and had put it under an indefinite moratorium. The Coalition for GM Free India demands Dr Manmohan Singh and his government to stop peddling risky GM crops and stand by the side of sound science and people of India.

Notes to the editor

1. The Prime Minister’s inaugural speech at the Indian Science Congress can be accessed at

2. The 2nd edition of the scientific compilation on adverse impacts of GM crops can be accessed at

3. The letter to PM on concerns with GM crops by Indian Scientists can be accessed at

For more info:

Rajesh Krishnan, Convenor, Coalition for GM Free India,

Mob: 09845650032 , email:

Coalition for a GM-free India 

Website:, email :,  Facebook page – GM Watch India

CSA complaint on Illegal spread of Herbicide Tolerant cotton

Dr. G. V. Ramanjaneyulu
Executive Director
To                                                                                                                                           Hyderabad
The Commissioner Agriculture                                                                                   8th November, 2013
Department of Agriculture
Government of Andhra Pradesh

Dear Sir
Sub: Illegal sales of Herbicide Tolerant Cotton in Srikakulam Dist –reg
Greetings from Centre for Sustainable Agriculture!
CSA is actively working across the state in promoting sustainable agriculture.
During one of our field visits to srikakulam district, we came across cultivation of herbicide tolerant cotton in tribal belts of seethampet mandal of srikakulam dist. Seeds were sold by a person named Nagireddy from Guntur and the brand name of the seed is KALPAVRIKSHA.  The cover has no address and name of the supplier (empty packet attached).
In and around Kotturu, near about 200 + acres is under this cotton. In Kotturu itself, one farmer by name Siridi Bhaskar Rao who has 50+ acres under this variety this year. Other villages include Bukkuduguda, Puliputti village 4 farmers growing 9 acres, Dantalaguda village 6 farmers 14 acres, Vempaliguda village  6 farmers 14 acres, Mukundapuram village 2 farmers 7 acres and Rekulaguda village  2 farmers 7 acres.  The strip tests we have done confirmed that the cotton hybrid grown here is resistant to glyphosate.
We had video recorded interviews with the farmers (DVD attached). The samples are tested positive for Glyphosate resistant event (Roundup Ready) developed by Monsanto.
This event is not yet approved by GEAC for commercial cultivation and biosafety tests are not completed.
There are serious health concerns with the herbicide tolerant cotton and the glyphosate which is used. The spread of such unapproved, untested and highly dangerous seeds to farmers in the tribal farmers has to be immediately curbed and action has to be initiated on the concerned officials who failed in regulation and the company which is responsible for the spread.
This is not first time such illegal cultivation of herbicide tolerant crops is noticed. In 2008, the then Commissioner Agriculture of Government of Andhra Pradesh made a complaint to GEAC that around 20,000 acres of Herbicide tolerant cotton is under cultivation.  GEAC has discussed this issue in 98th meeting in December 2009, Agenda Item 6.4 was on complaints about sale of illegal HT cotton seed. It was clearly acknowledged that illegal HT cotton, tested in laboratories with the samples testing positive for the HT trait (MON1445 event), was being supplied and grown in Andhra Pradesh, Gujarat and Madhya Pradesh. Andhra Pradesh government reported suspension of seed license to one company and destruction of HT cotton crop and that more reports are awaited from some more districts, the decision was to “direct state governments to initiate punitive action against erring companies, and that follow up with respective state governments to curb the illegal cultivation of HT cotton should continue on a regular basis”. However, the presence of HT cotton in Srikakulam district showcases once again the incapable and apathetic regulatory system that refuses to take any effective action.
The Parliamentary Standing Committee on GM crops and the Technical Expert Committee appointed by the Supreme Court both recommended that the Herbicide Tolerant crops are not suitable for the country and also that the field trials should be stopped for atleast ten years till the regulations are improved.
The source of such illegal seeds seems to be the company which have developed them. The company has to take responsibility as they were only given permission for laboratory research and confined field trials. Escape of any form from these should be primarily be the responsibility of the company.
On 29th October, during a meeting at the commissioner office, we brought up this issue with you and showed the video of interviews with farmers and when we visited the field again on 3rd November, we found that no action has been initiated and even the concerned officials have not even visited the field.
In this context we request you to kindly

  1. Investigate to assess the extent of illegal, unapproved HT cotton cultivation in this area and all of Andhra Pradesh
  2. Fix liability on the offenders who are responsible for such spread as per the EPA rules, 1986. The state Governments should also fix liability under seed laws for unlicensed seed trade. Government of India should fix responsibility on regulators for failing to curb this illegal proliferation of unapproved GMOs.
  3. Write to GEAC to action on the company which is responsible for the leakage of the material from their research labs and confined field trials

We also bring to your kind notice that such illegal cultivation of several GM crops is happening across the state.  The companies which are permitted field trials are not taking responsibility when the trials are contaminating the neighboring crops or seeds escape and find their way into commercial market illegally.
Therefore we request the AP state government to kindly stop all permissions for the GM field trials without Biosafety approvals.
Looking forward for your immediate action
seed packet front side
Seed packets without any details
seed packet backside
strip test
Strip test confirming presence of Roundup Ready event