Shri Hem Pande,
Dear Shri Hem Pande,
Sub: Biosafety violations which require immediate action for fixing liability, by GEAC – Reg.
Greetings! This is to bring to your notice two apparent violations of biosafety norms, guidelines and EPA Rules and demand that you take immediate action to investigate and fix liability for these violations.
On 24th March 2015, the Finnish competent authorities have notified the European Union’s Rapid Alert for Food and Feed (RASFF) about unauthorized genetically modified papaya in frozen fruits smoothies that can come into Finland from Poland, but with the raw material from India. For more details, please use the link below: https://webgate.ec.europa.eu/rasff-window/portal/?event=notificationDetail&NOTIF_REFERENCE=2015.0357. This raises concerns about illegal cultivation or entry otherwise of GM papaya in India. GEAC should immediately swing into action and ascertain through proper investigation and adequate testing the veracity of this matter and fix liability in case of violations.
With regard to the BRL II trials of GM Mustard of Delhi University, we have reports that indicate that the trial in RRS of Punjab Agriculture University, Bhatinda is violating the conditions laid down in the permission letter dated 28/10/2014: Condition 3 (k) lays down the following: “The Permitted Party shall keep full account of the transgenic materials and seeds, if any, set in the transgenic plants…..The harvested crop from the border rows and the leftover plant and plant parts from the entire experimental plot shall be destroyed by burning after completion of the experiment and records to this effect needs to be maintained and submitted to the GEAC/State Department of Agriculture/District Collector and other field functionaries notified under the Seed Act 1966/EPA 1986. Condition 9 (iii)(c): A record of harvest/termination shall be prepared for each BRL II trial site and shall document the date and method of harvest, the amount of harvested material, the disposition of any harvested materials, the cleaning of any equipment used during harvest and method of destruction of any residual plant material on the trial site. The record must be verified and signed by a member of the Monitoring Agency or any nominee of GEAC/SAU authorized by GEAC during the conduct of a trial site inspection during harvest, or within 15 days of the completion of harvest.
The photographic evidence that we have with us, dated June 7th 2015 (available at https://www.dropbox.com/sh/4c8fys8okwchoej/AACZlTRziVrAu1De6TX7T2cka?dl=0 ) show that the crop has not been destroyed fully as prescribed. This is only one more example of the negligent way in which crop developers and regulators have been handling open air field trials, and this is not the first time we have brought such biosafety violations to your notice. We demand that GEAC fix liability for such lapses, especially in a crop like Mustard – contamination instances galore from all over the world, and this lackadaisical attitude in a season with just 3 trials of GM food crops in the entire country makes us shudder to think of the many lapses that would have surely occurred in other seasons when GEAC approves dozens of trials without any concomitant accountability towards monitoring.
Convenor, Coalition for a GM Free India
Mob: 09845650032, 07559915032, email: firstname.lastname@example.org
Notification details – 2015.0357
unauthorised genetically modified papaya in frozen fruits smoothies from Poland, with raw material from India
food – information for follow-up – official control on the market
no distribution from notifying country
papaya in frozen fruits smoothies
information for follow-up
fruits and vegetables
Substance / Hazard
unauthorised genetically modified
GMO / novel food
Countries concerned (D = distribution, O = origin)
Finland India (O) Poland (O)
Coalition for a GM-free India
Website: www.indiagminfo.org, email : email@example.com, Facebook page – GM Watch India