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IN RATS SUB CHRONIC ORAL TOXICITY WITH NHH 44 Bt-COTTON SEEDS Report for: UNIVERSITY OF AGRICULTURAL SCIENCES AGRICULTURAL RESEARCH STATION DHARWAD-580007 KARNATAKA Guidelines: DBT, Guidelines for Toxicity and Allergenicity Evaluation of Transgenic Seeds, Plants and Plant parts Prepared by : DEPARTMENT OF TOXICOLOGY SHRIRAM INSTITUTE FOR INDUSTRIAL RESEARCH (A Unit of Shriram Scientific & Industrial Research Foundation) 19, University Road, Delhi 110 007 Tel. 27667267, 27667860, 27667436 Fax No. 91+011-27667676, 27667207, E. Mail : sridlhi@vsnl.com Page 1 of 93

IN RATS QUALITY ASSURANCE STATEMENT This is to certify that the work described in the study report entitled Sub chronic oral toxicity study with NHH 44Bt-Cotton Seeds has been audited and examined with respect to the study protocol and the Standard Operating Procedures in accordance to DBT, Guidelines for Toxicity and Allergenicity Evaluation of Transgenic Seeds, Plants and Plant parts for non clinical laboratory studies. The report provides true and accurate record of results obtained. The dates of inspections & dates on which findings were reported to the study director & SRI management are given below: Phases of study Dates of Inspection Dates of Reporting Protocol 15.12.2006 15.12.2006 Conduct 19.12.2006 19.12.2006 08.01.2007 08.01.2007 26.02.2007 26.02.2007 19.03.2007 19.03.2007 Records/ Raw data 15.04.2007 15.04.2007 Report 05.05.2007 05.05.2007 Sr. SCIENTIST QUALITY ASSURANCE Page 2 of 93

IN RATS STATEMENT OF COMPLIANCE WITH GOOD LABORATORY PRACTICE We, the undersigned take overall responsibility to conduct the work described in the study entitled Sub chronic oral toxicity study with NHH 44 Bt-Cotton Seeds performed with respect to the study protocol and the Standard Operating Procedures in accordance to DBT, Guidelines for Toxicity and Allergenicity Evaluation of Transgenic Seeds, Plants and Plant parts for non-clinical laboratory studies. All the raw data, documentation, protocol and copy of final report are retained in the archives at Shriram Institute for Industrial Research, Delhi. DIRECTOR SCIENTIST PATHOLOGY HEAD, DEPT. OF TOXICOLOGY Approved for issue DEPUTY DIRECTOR (MANAGEMENT) Page 3 of 93

IN RATS SCIENTIFIC PERSONNEL INVOLVED IN THE Dr. RAJUL SAXENA, M.V.Sc. (Scientist Pathology) Dr. VIVEK SRIVASTAVA, M.V.Sc. (Research Associate) Ms. LITHA THOMAS, M.Sc. (Analyst) Mr. ALISHA N. SINGH, D.M.L.T. (Lab Technician) Page 4 of 93

IN RATS INDEX S. No. Contents Page No. 1. Quality Assurance Statement 2 2. Statement of Compliance with Good Laboratory Practice 3 3. Scientific personnel involved in the study 4 4. Summary 7 5. Introduction 8 6. 7. Objective Test Substance 9 10 8. Experimental design 11 9. Experimental procedure 12 10. Animal groups and dosage level 13 11. 12. Clinical Laboratory studies Terminal Studies 15 17 13. Observations 18-19 14. Result and Conclusion 20 Page 5 of 93

IN RATS Tables 15. 16. Appendix-1 Body Weights and Survival Data Appendix 2 21-44 Feed Consumption data 45-55 17. Appendix 3 Haematology- Mean & individual data 56-63 18. Appendix 4 Bio-Chemistry- Mean & individual data 64-71 19. Appendix 5 Mean & absolute organ weight data 72-81 20. Appendix 6 Intensity of Lesions (Pathological findings) 82-87 21. Appendix 7 Intensity of Lesions (Histopathological findings) 88-93 Page 6 of 93

IN RATS SUMMARY This study was designed to investigate the toxicological effects of 90 days (5 days / week) repeated oral administration of NHH 44 Bt-Cotton seeds to determine, whether any types of effects could be induced, and to serve as a basis for selecting appropriate range of dosage for future studies and for establishing safety criteria for human consumption. Three groups of 20 rats each (10 males and 10 females) were made. First group was kept as control, which was given vehicle only i.e. corn oil. Second and third group was administered with NHH 44 Bt-Cotton seeds in powdered form at the dose level of 1000 mg/kg B.wt. and powdered NHH 44 Non Bt-Cotton seeds at the dose level of 1000 mg/kg B. wt. respectively. The NHH 44 Bt-Cotton seeds and NHH 44 Non Bt-Cotton seeds samples were prepared daily in corn oil (vehicle) for oral administration. Under the conditions of this study, the 90 days repeated oral administration of NHH 44 Bt-Cotton seeds and NHH 44 Non Bt-Cotton seeds at the dose level of 1000 mg/kg B.wt to wistar rats did not induce any observable toxic effects, when compared to its control counterpart. Hence, No Observable Adverse Effect Level (N.O.A.E.L) = 1000 mg/kg B.wt. Page 7 of 93

IN RATS INTRODUCTION This study was aimed to determine the sub-acute oral toxicity in wistar rats. The given study was carried out with the dose level of 1000 mg/kg B. wt. of NHH 44 Bt-Cotton seeds and NHH 44 Non Bt-Cotton seeds along with the vehicle control as per the DBT guidelines for Toxicity and Allergenicity Evaluation of Transgenic Seeds, Plants and Plant Parts.. Page 8 of 93

IN RATS OBJECTIVES To assess the toxicological effects of 90 days oral administration of NHH 44 Bt-Cotton seeds in comparison to the NHH 44 Non Bt-Cotton seeds and control (only vehicle ) in rats so as to provide information on the possible health hazards likely to arise from repeated exposure over a limited period of time, based on DBT guidelines for Toxicity and Allergenicity Evaluation of Transgenic Seeds, Plants and Plant Parts. Page 9 of 93

IN RATS TEST SUBSTANCE The sponsor is responsible for the necessary characterization and evaluations of the test substance. The details of the test substance provided by the Sponsor are as follows : NAME : NHH 44 Bt-COTTON SEEDS & NHH 44 NON Bt-COTTON SEEDS SPONSOR : UNIVERSITY OF AGRICULTURAL SCIENCES, DHARWAD MATERIAL DESCRIPTION : DARK BROWN COLOURED SEEDS PACKED IN : WHITE COLOURED PLASTIC BAGS DATE OF COMMENCEMENT : 19.12.2006 OF DATE OF COMPLETION : 18.03.2007 OF Page 10 of 93

IN RATS LABORATORY STRAIN AND SPECIES ANIMAL SOURCE SEX WEIGHT RANGE HUSBANDRY EXPERIMENTAL DESIGN Dept. of Toxicology Shriram Institute for Industrial Research 19, University Road, Delhi-110007 (INDIA) Wistar (albino) rats Lab animal facility, SRI, Delhi Male & Female 120 ± 20 gms All animals were caged in a group of 5 according to sex in plastic cages fitted with wire mesh tops and having sterilized paddy husk bedding. Water and standard rat diet were provided ad libitum. ENVIRONMENTAL CONDITIONS AGE OF ANIMALS Room temperature : 22 ± 3 C Relative humidity : 30 70 % Air exchange : 15 air changes / hour Lighting condition : 12 hrs light and 12 hrs dark cycle 6-8 weeks ACCLIMATIZATION PERIOD 7 days DATE OF COMMENCEMENT OF DURATION OF 19.12.2006 90 days DATE OF TERMINATION OF 18.03.2007 NECROPSY DATE Terminal Sacrifice : 19.03.2007 20.03.2007 21.03.2007 Page 11 of 93

IN RATS EXPERIMENTAL PROCEDURE Sample preparation Powdered samples of NHH 44Bt-Cotton seeds and NHH 44Non Bt-Cotton seeds were freshly prepared every day in corn oil (vehicle) for repeated oral administration for 90 days. Total 60 healthy adult male and female (30+30) rats were acclimatized for 7 days and animals were caged in a group of 5 according to sex in plastic cages fitted with wire mesh tops and having sterilized paddy husk bedding. The rats were randomized and assigned to 3 groups of 10 male and 10 female rats each and identified by cage tag and individual marking. The first group was kept as control and was given only the vehicle i.e. corn oil. Second and third group was administered with NHH 44Bt-Cotton seeds and NHH 44Non Bt-Cotton seeds at the dose level of 1000 mg/kg B.wt. respectively. The rats were observed daily for behaviour, appearance and toxicological signs and symptoms, if any. Page 12 of 93

IN RATS Animal Group and Dosage Level Group Dose No. of animals mg/kg B.wt Male +Female 1. Control 0.0 10 +10 2. NHH 44Bt-Cotton seeds 1000.0 10 +10 3. NHH 44Non Bt-Cotton seeds 1000.0 10 +10 Body weights : Recorded individually before treatment and at weekly intervals, thereafter group mean body weights were calculated. Feed Consumption : Recorded individually at weekly intervals, thereafter group mean feed consumption were recorded. Signs / symptoms : Recorded daily in terms of clinical manifestation, if any. Page 13 of 93

IN RATS Mortalities : If any, subjected to detailed macroscopic examination and tissue samples were preserved for histopathological examination. The following clinical laboratory determinations were made in all the animals of each group after termination of the experiment. The organs were weighed and subjected to detailed macroscopic / microscopic examinations. Page 14 of 93

IN RATS CLINICAL LABORATORY STUDIES Blood Sampling Food was withdrawn overnight prior to collection of samples. 5-8 ml of blood was withdrawn by cardiac puncture under CO 2 asphyxiation prior to sacrifice. Haematology Following haematological estimations were performed on control and treated group of animals : Haematocrit (Hct) Differential Leucocyte Count (DLC) Haemoglobin (Hb) Neutrophils (N) Total Erythrocyte Count (TEC) Lymphocytes (L) Platelet count Basophils (B) Monocyte (M) Eosinophils (E) Total Leucocyte Count (TLC) Page 15 of 93

IN RATS Biochemistry Following estimation were performed on control and treated rats using Boehringer Mannheim diagnostic kits: (a) Blood sugar (b) Blood urea nitrogen (BUN) (c) Total protein (TP) (d) Albumin (e) Serum glutamic oxalo acetate transaminase (SGOT) (f) Serum glutamic pyruvic transaminase (SGPT) (g) Serum alkaline phosphatase (SAP) (h) Cholestrol Page 16 of 93

IN RATS TERMINAL STUDIES Autopsy : After completion of treatment period all animals from each group were sacrificed and subjected to detailed macroscopic examination. The following organs were weighed : Heart, kidneys, liver, lungs, spleen, adrenals, testis, ovaries, uterus and brain. Histopathology: Microscopic examination of the following tissues from all animals from each group were carried out : Stomach Brain Intestine Heart Lungs Kidneys Liver Adrenals Spleen Testis Uterus Ovaries Any other macroscopically abnormal tissue. BIOSTATISTICAL METHOD USED All the data were analysed by using standard student s t- test of analysis Page 17 of 93

IN RATS OBSERVATIONS Mortality and toxic signs No mortality was observed in any of the test groups including the control group of animals. No toxic signs and symptoms were noticed in any of the two dose groups and the control group of animals. Mean body weights No significant differences were observed in the body weight gain (Appendix -1) pattern of the test groups when compared to the control group of animals. Feed Consumption The feed consumed by the rats in all the test groups was similar to that consumed by the animals of control group (Appendix-2). Haematological evaluations No significant changes were noted among the test groups and control group of animals with respect to haematological findings (Appendix-3) as all the parameters fell within the accepted limits of normal variations for albino rats. Page 18 of 93

IN RATS Clinical Biochemistry evaluations Serum Biochemistry evaluations (Appendix-4) disclosed no significant differences in the tests as well as the control groups of animals, as all the parameters fell within the accepted limits of normal variations. Organ Weight Absolute organ weights and their ratios (relative organ weights) with their respective body weights are shown in Appendix-5. As there were no significant changes in the organ weights of the test animals, when compared with organ weights of control group animals, the test substance (NHH 44 Bt- Cotton seeds and NHH 44 Non Bt-Cotton seeds) was failing to suggest any specific target organ. Necropsy examinations Necropsy examination of animals did not reveal any significant changes in both the test groups i.e. NHH 44 Bt-Cotton seeds and NHH 44 Non Bt- Cotton seeds at the level of 1000 mg/kg B.wt when compared to its control counterparts, as shown in Appendix 6. Histopathological examination No significant histopathological changes (Appendix-7) were noticed in the animals of NHH 44 Bt-Cotton seeds and NHH 44 Non Bt-Cotton seeds dosed at 1000 mg/kg B.wt when compared to its control counterparts. Page 19 of 93

IN RATS RESULT WITH CONCLUSION Under the conditions of this study, the 90 days repeated oral administration of NHH 44 Bt-Cotton seeds at the dose level of 1000 mg/kg B.wt for five days/ week to wistar rats did not induce any treatment related observable toxic effects, when compared to its corresponding NHH 44 Non Bt-Cotton seeds and the control group of animals treated with corn oil (vehicle) only. Hence, No Observable Adverse Effect Level (N.O.A.E.L.) = 1000 mg/kg. B.wt. The sample has been conducted as per DBT, Guidelines for Toxicity and Allergenicity Evaluation of Transgenic Seeds, Plants and Plant parts. Page 20 of 93