Dr Amita Prasad,

Chairperson,

Genetic Engineering Appraisal Committee.

Dear Chairperson,

Sub: Note inviting comments on the proposal on authorisation of Environmental Release of GE Mustard hybrid and use of parental events for development of new generation hybrids – reg.

Madam, the note inviting comments on “the proposal on authorisation of environmental release of GE mustard” tells us that there is already a proposal to authorize (and not just an application seeking permission for environmental release which you would have stated so if the feedback was on the application), and also that superficial and meaningless processes are being run by the GEAC in the name of seeking public feedback. This “proposal” is indeed alarming that it is a hurried process of 7 persons including ones who represent objectionable conflict of interest, and certainly not the full GEAC. If GEAC has not discussed the matter, how and when did this become a PROPOSAL TO AUTHORISE?

This is a mockery of the processes that GEAC has run, which also involved great efforts from our side to assist you with the safety assessment, and also reveals once again how the regulators have functioned unscientifically and high-handedly right from the beginning in the discharge of their duties. The fact that no minutes of the civil society group’s presentations on July 18th were prepared or shared yet (these presentations are all available athttp://indiagminfo.org/?p=1327 and http://indiagminfo.org/?p=1371), and no response to the points raised by us is forthcoming shows that you were never serious about rigorous scientific scrutiny of the benefits or risks of GM mustard.

There are at least the following aspects to this soc-alled feedback process that indicate the real intentions of the regulators/Government of India. 

1.     Only the AFES (Assessment of Food and Environmental Safety) document being put out, which is not the same as the biosafety dossier, and which does not have details of the study protocols or data generated, on which feedback is being sought. The sub-committee of course had concluded in this document that consumption of GE mustard is safe for human and animal health, and that environmental release may not pose any risk to biodiversity or the agro-ecosystem. Before reaching such a conclusion, the data should have been put out for independent scientific scrutiny. However, this was not done, and such a conclusion was drawn after 2 meetings in 15 days’ time, with the third meeting on August 11th 2016 giving a clearance.

2.     For the full biosafety dossier and data to be accessed, citizens from all over the country are being asked to come to MoEFCC office, that too with prior appointment. It is not clear if data will be shared even then or if it is expected that the citizen should memorise everything and come back. This is a violation of the CIC orders and also contrary to what GEAC itself has been promising to the CIC in the hearings of an ongoing case.

3.     Feedback is being sought only in a prescribed format (“the proforma” at http://www.moef.gov.in/sites/default/files/Proforma%20for%20Comments.pdf)-first of all, only one document with its own conclusions is put out in the form of AFES, and within that feedback is sought to be curtailed to narrow details while the most important details are kept out of public access, and no basic and fundamental aspects questioned.

4.     After forcing citizens to come all the way to Delhi in case they want to participate in these feedback processes, only 30 days’ time is being given for feedback. What is the rationale for this?

5.     The Proforma requires a citizen to use a subject line that says “Comments on RARM document on GE Mustard” which forces one to go straight into Risk Management, and there is no risk assessment related material put out in any case! This is cooption of citizens, apart from cooption of GEAC members into a proposal to authorize environmental release!

All these are an indication of the biased, pre-concluded processes that the GEAC is adopting.

We write to you now to demand that the full biosafety data be put out into the public domain immediately if this feedback process has to be a meaningful and SCIENTIFIC process. Further, at least 90 days’ time should be given for feedback from public. We also demand that you look into all feedback that is provided and not try and curtail it to formats that are conveniently created to keep out important questions and queries.

Sincerely,

Kavitha