NSAI expressed that undue importance is being given for protein expression in the hybrid.  The protein expression varies from part to part and is different in leaf, seed, square and boll. The expression also varies from season to season and stage of the crop growth.  However, the most important aspect is presence of the protein above the LD50/LC50 value for the targeted four bollworm species.  The LD50/LC50 value is different for each species of four bollworms.  The highest LD50 value needs to be considered as the minimum expression required in a Bt cotton hybrid/variety.  Accordingly based on the lab data of LD50/LC50 available with CICR, the expression level for Cry1Ac can be maintained as notified in 2016/2005.  The minimum expression level for Cry2Ab2 protein can be 19.4 ppm (parts per million) per gram of tissue which is the highest LD50 value among the four targeted bollworm species of cotton.

The farmers grow the cotton crop for highest yield, better disease and pest reaction and other parameters like drought or excess water tolerance. If the hybrid/variety in evaluation is expressing adequate protein to be effective in the bioassay, it can be released.

Therefore the mistake of notifying very high protein expression in 2017 needs to be corrected and the notification may be scrapped and a new notification be issued based on the above.

NSAI also requests for release of all the Bt cotton hybrids / varieties evaluated by ICAR system in the past 3 years as soon as possible which is delayed due to the wrong notification of protein expression.

The proposal of Monsanto/Mahyco for joint collection of samples to test the protein expression is not required at all and will not lead to any conclusion on this issue.  It need not be therefore carried out. Involvement of private agencies in regulatory processes which was wrongly done in the past by DBT and GEAC shall not be continued in the Ministry of Agriculture.