To:
Shri Prakash Javadekar,
Minister for Environment, Forests & Climate Change,
Government of India.
Dear Sir,
Sub: Meeting to discuss concerns with regard to transgenic technology and its regulation in India – reg.
Greetings! This is as a follow up to our meeting that emerged out of a citizens’ protest outside MoEFCC on February 5th 2016 when the Genetic Engineering Appraisal Committee (GEAC) met to consider the application for “environmental release” of GM mustard hybrid DMH11. We would like to thank you once again for meeting with our delegation.
Sir, during the discussion, we brought up the issue of how policy directives are not in place and how this GM mustard application should not have been processed at all by the regulators and should not have come to this stage of development and commercial release. No needs and alternatives assessment precedes GMO application processing, even as there are objectionable and serious lacunae in biosafety assessment, non-existence of liability regime, no impact assessment related to socio-economic considerations etc. The following points explain that further:
- Mustard yield increases: Can be done through non-seed-based methods also, and bridging extension gaps for the same;
- Hybridisation of Mustard: Non-GM hybrid mustards exist in the market from both public and private sector;
- Centre of Diversity: India is the Centre of Diversity for Mustard and we should not be dabbling with a transgenic variety at all in this crop;
- Herbicide Tolerant crop: DMH11 is a herbicide tolerant crop and we should not be dabbling with a herbicide tolerant crop at all;
- Male sterility trait: DMH11 has Genetic Use Restriction Technology (GURT) employed, and this is not accepted by Indian law.
So, apart from the biosafety assessment issues of GM mustard (have all tests been done, has there been independent testing, have there been long term tests taken up, have the tests used scientifically rigorous protocols to capture risks if any, is the analysis upto the mark, is the interpretation of results accurate etc. etc.), there are fundamental issues with the very processing of this application that is underway, and we once again draw your attention to this fact. These fundamental issues include but are not limited to the ongoing Supreme Court case and the pending adjudication on the court appointed Technical Expert Committee report as well as the current contempt petition; state governments’ opposition; pending investigation into our complaint on field trial violation in this case and fixing liability for any violation (while the GEAC is busy processing the application, it has not bothered to even acknowledge the complaint made with photographic evidence: why?); farmers’ and consumers’ resistance from all over the country etc. There are of course other reasons why the application processing should not have happened, and be continuing. Therefore, we remain deeply concerned, despite your assurance that GM mustard will not be imposed on citizens of this country.
Secondly, about the secrecy around the data and the processes: it is absolutely untenable that meeting agenda and minutes are not shared in the public domain. We would like to remind you and the government, that India is one of the 170 signatories to the Cartagena Protocol, which asks for public awareness and consultations. We repeat again that the regulators are breaking established norms in the country by their secrecy. In terms of biosafety dossiers not being shared, it is a decided matter already, both by the Supreme Court on 8/4/2008 and 12/8/2008 further ordering compliance, and the Central Information Commission’s 2009 Orders, which were passed after the private company in question was also brought into the hearings, as the third party concerned. These are attached for your ready reference. Both the Supreme court as well as the CIC had emphasised that when it comes to issues that matter the larger public, public interest is more important than private confidential business Information and hence all data regarding safety studies of GM crops ( Bt Brinjal in that particular case) should be put in public domain.
Thirdly, you brought up the possibility of illegal Bt brinjal coming in from Bangladesh and the government does not want such an entry of GMOs in the country. Obviously, that is no reason why you will begin approving, if that was hinted in the first instance! Also, this is the reason why we have been writing to you to ask you to write to Bangladesh government, since you have the authority to write to any other country under the Cartagena Protocol about any matter of cross-boundary movement of LMOs. Please write to Bangladesh asking them what it is doing to ensure that illegal entry is not happening into India. Importantly, if illegal Bt brinjal comes into India, it shows our regulatory weaknesses once again – as the Minister, we request you to find out from our regulators/GEAC what exactly have they done so far to monitor the situation and to ensure that no such illegal entry happens. In fact, for all the other illegal cultivation of GMOs happening in India, we also demand that you fix liability on the regulators themselves for failing in their duty and responsibility.
Sir, since you often talk about the need for a scientific approach to the debate on GM crops we would like to place on record that there are more than 400 peer reviewed and published scientific studies that we had compiled (accessible here: http://indiagminfo.org/?p=657, and a hard copy of which has been submitted to you in our meeting with you) that points to the adverse impacts of GM crops to human health as well as the environment. Besides this, the Supreme Court-appointed TEC was comprised of eminent scientists (including a molecular biologist, nutrition expert, environmental scientist and toxicologist) who very well understand the biosafety aspects around environmental release of GMOs. Five of the biosafety experts who were all independent scientists, as opposed to the one agriculture technologist of this Committee in their final report had called for a halt in any open release of GMOs until serious lacunae in the existing regulatory system are addressed. They had also strongly recommended against our country venturing into Bt food crops or Herbicide Tolerant crops (citing the evidence of adverse impacts on human health and environment that already exists of these GMOs), as well as those crops for which we are a Centre of Origin/Diversity, a norm that is followed across the world. In the current proposal of GM mustard, it is a herbicide tolerant crop, and it is also a crop for which we are the Centre of Diversity. Therefore, a serious scientific approach to the GM debate requires you and the Government to take these aspects into account seriously and we hope that you will.
Speaking on behalf of lakhs of citizens, we would like to inform the government that it is under-estimating the resistance to GMOs when it is rushing through its clearance processes. We reiterate that the Environment Ministry nor its regulators are not meant for facilitating speedy, secretive, industry-friendly approvals, but to protect citizens from risks of modern biotechnology. At present, it does not appear to be so.
Sir, on this National Safe Food Day, – February 9th which is the day on which Government of India placed Bt brinjal on an indefinite moratorium being responsive to society and responsible to science, – to follow up on your promise to hold a meeting with us on our objections and concerns with regard to GMOs in our food and farming, we request you to please let us know about suitable dates in early March 2016, for a day-long meeting where all details can be discussed threadbare. We would like to come as a 15-member team from our side. Further, we would like this meeting to focus on policy level issues, and the overall regulatory regime, rather than just GM mustard, which we will discuss separately with GEAC, after all data has been made public. We repeat our request that GEAC be stopped in its proceedings. Thank you.
Sincerely,
Kavitha Kuruganti
Phone: 8880067772
Email: kavitakuruganti@gmail.com
Coalition for a GM-Free India
A-124/6, First Floor, Katwaria Sarai, New Delhi 16.
Website: www.indiagminfo.org, email : indiagmfree@gmail.com, FB : GMWatch India