Many people consider environmental activists to be good Samaritans who think no evil & do no evil. For sure, some are. But many of them have dubious characters, yet they manage to bask in public glory thanks to deft media relations. This article chronicles what could easily qualify to be the greatest ever scientific fraud of our times. What makes it all the more significant is that the fraud has been conceived and committed by India's most visible and, yes, most audible environmental pressure group - Centre for Science and Environment(CSE), led by Ms.Sunita Narain.

In any crime investigation, the sleuths will move from present to the past. I will be taking similar route as I unfold and lay bare a complex scientific fraud committed by CSE.

Fund raising from fear raising is a time tested wonder formula that works for environmental activists. In India, CSE has perfected this formula over years. It generates and releases pesticide residue analysis reports at regular intervals, raises unfounded fears and, in the process, achieves both popularity and pecuniary gains (funds& donations mostly from abroad!).

Every time it released self generated pesticide residue reports, CSE successfully managed to raise fears among general public about pesticide residues and got front page news coverage and prime time TV slots. 

Its most recent report was on 2nd August 2006, when CSE released a sensational report to the media claiming that its analysis had shown pesticide residues in all 57 soft drink samples collected from Indian market. The pesticide residues, according to CSE, ranged from 2.65 ppb to 31.55 ppb.

When CSE alleged that there were ppb levels of pesticide residues in colas, public outcry followed. Accusations were made that government was not doing enough to prevent poisons being bottled and sold as soft drinks.

After releasing the latest report on 2nd August 06, Ms.Sunita Narain was seen in all TV channels abusing every one who attempted to question the veracity of her findings. It was then the Government of India did what CSE least expected. On 4th August 2006, Ministry of Health constituted a six member expert committee to scientifically examine the claims made by CSE. The committee submitted its report in Sept 2006 to Ministry of Health stating that "the results and conclusions reached by the CSE in the report can not be accepted on its face value". Among the reasons given by the expert committee, the important ones are:

-Confirmation of residues by GC-MS was done by CSE only for 3 soft drink samples out of 57     samples.

-Analytical methodology was not validated by CSE before using them for quantitative analysis of    pesticide residues.

-CSE had altered the figure for recovery percentage subsequent to release of original report. For example, recovery of Monocroptophos as given in CSE's original report was 59.12%, it was subsequently altered to 77.8% by CSE.

Succinctly put, the six member expert committee set aside the report as CSE had failed to follow prescribed/appropriate procedure for pesticide residue analysis.

It must be recalled here that the Joint parliamentary Committee that had earlier examined the 2003 residue report of CSE, recommended in its report dated 4th Feb 2004 that the [analytical] results must be validated to ensure transparency. Apparently, CSE did not pay heed to this advice from JPC.

Failure to follow the appropriate analytical procedure and publication of erroneous/questionable results would have attracted strong legal action in US, Europe etc. Unfortunately, in India such crimes have not yet reached courtrooms. As a result, incompetent persons moonlighting as analysts with environmental NGOs manage to publish pseudoscientific reports. Willy-nilly, these environmental NGOs have grown to the level of being able to intimidate both the industry and influence regulatory policies on the strength of phobia that they manage to generate in the minds of people.

CSE is in the habit of releasing its analysis report at press conferences without any peer review by scientists. This helps CSE to gain public attention & opinion to its advantage. Dr.Robert L.Park of University of Maryland (author of "The Seven Signs of Voodoo Science") says that "when a discovery is released directly to the media, it suggests that the work is unlikely to stand up to scientific scrutiny".

Remember Ramar pillai, the con man from Tamilnadu? He claimed to be extracting petrol from boiling some leaves secretly collected from forests. He first released his "sensational discovery" to a group of unsuspecting media people and quickly became a hero, as he managed to pull the proverbial wool over our eyes. Tamilnadu chief minister gave him an expensive gift. Finally, scientists stepped in and found his claim to be a complete fraud. We do not know his whereabouts now.

It is said that if a criminal is not caught in his/her first attempt, chances are high that he/she will gain courage and continue nefarious acts. The same is true in case of insidious white collar crimes too. CSE had first taste of laboratory fraud, way back in 2001.

The United States Environmental Protection Agency (US-EPA) defines laboratory fraud as "deliberate falsification of analytical results".

In order to comprehensively understand the laboratory fraud, it is necessary to understand certain scientific terminologies.

All analytical laboratories use an instrument called Gas Chromatography (GC) to estimate chemicals in test samples (soil, water, milk, soft drinks, blood etc). GC is a chemical analysis instrument for separating and estimating chemicals present in a sample. The GC uses a narrow capillary tube known as column through which various chemical constituents of an injected sample pass in a gas stream.

As the chemicals exit at the end of the column, they are detected electronically. The GC produces a graph called a Chromatogram. Peaks on the chromatograms represent analysed/captured chemical compounds. The location of the peaks on the chromatogram would be compared with the peaks produced by the injection of pure chemical called standard. The comparison of peaks produced identifies the chemical compound present in the analysed samples.

To produce accurate and reliable measurements of chemical compounds, the GC must be properly calibrated before any sample is analysed. Besides, it is necessary to confirm the GC results using GC Mass Spectrometer (GC-MS) to remove ambiguities arising from false positive peaks.

Fraudulent practices in environmental testing laboratories receive strong penal action from US-EPA and federal agencies.

By now, a question will begin to rise in your minds. Did CSE commit any culpable laboratory fraud? Yes, first in the year 2001.

On 21st Feb 2001, CSE convened a press meet in Delhi and announced to popular media that CSE's own laboratory tests had found "alarming high levels" of Endosulfan, a popular pesticide, in all samples of water, milk, fruits and blood collected (by CSE) from a village called Padre in Kasargod district of Kerala.

This "alarming high levels", according to CSE, was responsible for causing a variety of health ailments including cancer of the people of Padre village. CSE concluded the press meet with a demand that Endosulfan should be banned in India. This was Ms.Sunita Narain's first dating with falsified data, under the full glare of unsuspecting media though. It was a huge success.

The media believed in everything that she said and flashed it across the nation. In Kerala the news became an emotional issue. Those who questioned CSE's claims were criticized as anti people. Ms.Sunita Narain abused the industrialists as cowards & criminals and accused them of committing chemical rape! Data deception worked wonders for CSE. It's visibility in the world wide web (www) increased phenomenally. 

One can fool some of the people all the time and all of the people some of the time, but one can not fool all of the people all of the time. This is one fundamental law at work ever since human society evolved. Many who thought that they could deceive people forever met with disgraceful end.

The list from history of those who ultimately suffered public humiliation and disgraceful exit extends from monarchs to local mafia. In the case of CSE' report involving Endosulfan, it soon became apparent to scientists and industry experts that the "alarming levels of Endosulfan" was a product of laboratory fraud.

After the sensational press meet on 21st Feb 2001, CSE also released a 17 page report exclusively for electronic access from the internet. This report, titled Pesticide Residue Monitoring Study CSE/PRM-1/2001, carried details of so called analysis of samples for Endosulfan residues and results obtained. The report was full of falsified/fabricated data. However, only experts could smell the rot in the report.

This is scientifically implausible as it exceeds the water solubility of Endosulfan by over 2800%. To understand the extent of falsehood in this claim of CSE, here is an illustration. The water solubility of common salt is 360 grams per litre of water. If any one claims to have dissolved in or extracted from one litre of water as much as 10 kgs of salt (i.e. about 2800% higher than its solubility), it should be considered to be a scientifically false & fraudulent claim.

As ludicrous as this were CSE's other findings including the one that claimed to have found lethal levels of Endosulfan residues from people who were/are alive. The levels found in their blood samples exceeded the known lethal level by over 10,000% to 20,000%.

When asked to comment on CSE's findings,the apex body in India for agricultural research- Indian Council of Agricultural Research(ICAR), had categorically stated that it's not at all possible to find 9.19 ppm of Endosulfan residues in filtered water.

The basic tenet in science is reproducibility. The industry wrote to Ms. Sunita Narain several times asking her- rather challenging her- to demonstrate her claim of finding Endosulfan residues in water nearly 2800% times higher than its water solubility. But Ms.Sunita Narain and her partners in the fraud (including Dr.Padma Vankar a college professor) have chosen to remain silent.

Forensic science extensively relies on laboratory analysis. The Canadian Society of Forensic Science says in its rules of professional conduct that labs must utilize methods and techniques with standards and controls to conduct analysis such that it could be reproduced by another qualified & competent person.

Dr.Roy-Keith Smith of Analytical Services Inc, USA lists following skills and qualities as essentials for anyone to run and work in analytical chemistry labs.

It's in fact a legal necessity to have competent persons. And, it's moral responsibility to have people of integrity and honesty. Did analysts at CSE posses all these qualities at the time of testing samples for Endosulfan residues? Scientifically absurd findings generated by them put a strong question on their competency.

It's also clear that CSE did not do data validation during and after analysis. Data validation is systematic process for reviewing lab data against a pre established "acceptance criteria". Had CSE done this, ridiculous residue data including the ones that exceed water solubility, lethal toxicity etc would not have been generated. Surprisingly, it did not strike CSE analysts that they were generating and releasing data that crosses the limits of sound science and richly qualify to be termed "pseudoscientific".

All this, brings in a big question. What was surreptitiously done by CSE that led to publication of data that could not be defended scientifically? 

In my view, either the analysts at CSE or their bosses must have indulged in one or more of the following criminal acts.

• Calibrating equipments amateurishly/intentionally using other than accepted procedure.

• Falsifying records.

• Fabricating data.

Most readers will remember from school that water can not hold in solution a solute in excess of its solubility. That you can not extract a compound from water in excess of its water solubility is a fundamental principle in analytical chemistry. Any body with basic knowledge of chemistry should know this. This raises another serious doubt.

Talking about laboratory fraud, the US-EPA said "the potential for computers to be used to generate and manipulate fraudulent data is increasing" .Could it be that CSE's Endosulfan residue analysis was simply created in a computer( without any lab analysis) by someone in CSE who does not have basic qualification in chemistry? 

Could it be that it was a hand work of someone who did not know/understand the fundamentals of basic chemistry?

Well, the needle of suspicion in this case points towards Ms.Sunita Narain BA (History), the Director of CSE.

Only a detailed investigation will bring out the truth. Achieving media visibility, popularity and pecuniary gains on the strength of falsified data is akin to profiteering from printing & circulating counterfeit currency notes. It is an anti social activity and should attract the strongest punishment possible under law.

In her press release dated 21st August 2006, Ms.Sunita Narain said that " it is right to hold the industries and government accountable for their action".

Yes, she is right; she has the rights. But, she should know that rights & responsibilities co exist& inseparable; you can not have one with out the other. As you have the rights to question others for their action/s, you have the duty & responsibility to respond to questions from others. "To be a good citizen is to acknowledge the other person's rights before asserting your own" said poet-philosopher Kahlil Gibran (1883-1931). Indian Supreme Court at the time of 42nd amendment to our Constitution said that "it's a fallacy to think that under our Constitution there are only rights and no duties." 

In the past few years, pesticides & chemical industry had sent several communications( including legal notice) to Ms. Sunita Narain and her partners in the laboratory fraud. But, till date they have not replied to scientific questions raised by the industry. Article 51A(h) of Indian Constitution says that it shall be the fundamental duty of every citizen of India "to develop scientific temper…" 

It is rather painful to note that Padmashree Sunita Narain does not seem to possess scientific temper, a fundamental duty as per our Constitution. She has sacrificed scientific temper at the altar of CSE and is openly engaged in and encouraging falsification/fabrication/distortion of analytical data. As said earlier, finding 9.19 ppm of Endosulfan residues in filtered water is as absurd as finding 10kgs of salt from one litre of water! It is ludicrous and scientifically implausible.

Padmashree. Sunita Narain must take a conscientious introspection and come out with an immediate and unconditional apology to Indian people, Indian Government, and Indian industry for the scientific fraud. The sooner this happens, the better.

Finally, it's time now for government of India to come out with measures to deter and detect laboratory fraud. After all, the compounded losses in time and resources spent to detect laboratory frauds are massive that neither the country nor the stakeholders can afford. As five major laboratory fraud cases came to light since 1993, the state of California in the year 1997 came out with "Best Practices for the Detection and Deterrence of Laboratory Frauds".

It stipulates that analysts must enter into an "ethics and data integrity agreement" which , among others, demands each analyst to declare that he/she understands the high standards of integrity required in analyzing environmental samples and that he/she shall not intentionally report data values that are not actual values obtained.

The US- EPA has established "Laboratory Fraud Directorate" to specially investigate laboratory frauds. Craven Laboratories Inc, a pesticide residue testing laboratory was fined $15 million and $3.7 million in restitution for laboratory fraud. The promoter-Don craven- received 5 year jail term. Similarly, in the year 2000, Intertek testing Services, USA was slapped $ 9 million in fine and $ 8.7 million in civil recovery.

Federal Office of Research Integrity found in 2002 that a researcher, Steven R Arnold of Tulane University Center for Bioenvironmental Research, had committed scientific misconduct by intentionally falsifying the research results involving pesticides and applied sanctions on him.

Creating unfounded fears & anxieties in the minds of gullible public with the aid of false & fabricated laboratory data is no less a crime than inciting social violence. It is a sophisticated rumour mongering. Environmental NGOs in India who habitually engage in this despicable crime must not only be punished legally but also be barred from receiving donations from within & outside India.

We need in India a strong system similar to USA to detect and punish those who indulge in laboratory fraud. Of course, Indian Penal Code (IPC) does address issues of injury/harm/damage arising from cheating, falsification, dishonesty, fraudulency etc. More specifically , Section 196 of the IPC states

"whoever corruptly uses or attempts to use as true or genuine evidence, any evidence which he knows to be false & fabricated shall be punishable in the same manner as if he gave or fabricated false evidence"

Fraudulent use of GC might also come under IPC 264 that says "whoever fraudulently uses any instrument for weighing which he know to be false shall be punished…". But , all this would only equate laboratory frauds with other petty crimes. We need to have a specific legal instrument to punish those found to have committed laboratory frauds. Environmental laboratory crimes must be considered at par with environmental crimes and should form an integral part of The Environment (Protection) Act1986. Its aim must be to detect, investigate, punish and prevent laboratory frauds in India. 

An expert investigation into the laboratory fraud/s committed by CSE since 2001 will help understanding the nuances involved in this crime and aid framing regulatory policies & controls. The chemical/pesticides industry must knock the doors of appropriate authorities and/or judiciary to expose the laboratory fraud committed by CSE.