Our letter to GEAC on its (facetious) so-called Review of GM mustard in its 134th meeting

———- Forwarded message ———-
From: GM Free India <indiagmfree@gmail.com>
Date: 14 May 2018 at 16:02
Subject: GEAC’s 134th meeting minutes – our serious concerns regarding the same
To: sujata@nic.in, cm.krishna@gov.in, akmehta@nic.in
Cc: geac.secretariat@gov.in, gyanesh.bharti@ias.nic.in, Madhumita Biswas <mbiswas2012in@gmail.com>, membersecretarygeac@gmail.com, kveluthambi@rediffmail.com, crb26@hotmail.com, sesikeran B <sesikeran@gmail.com>, nppbg@pau.edu, kk.sinha@nic.in, srrao@dbt.nic.in, aptesk@barc.gov.in, ddgcs.icar@nic.in, js_sandhuin@yahoo.com, kumarv@icmr.org.in, sonti@ccmb.res.in, Swati_sri_2002@yahoo.com, ppa@nic.in, ccb.cpcb@nic.in, jsseeds-agri@nic.in, O P GOVILA <govilaop@gmail.com>, lutherrangreji@gmail.com, vvr3@vsnl.com, bpsrinivasana@yahoo.com, renee@ces.iisc.ernet.in, Vijendra Mishra <vijendramishra.niftem@gmail.com>, rameshvsonti@gmail.com, sushilanitagupta@yahoo.com, Raman Kant Mishra <mishraramankant@gmail.com>, WARRIER <warrier@nic.in>, saranya.p@gov.in, drhrshvardhan@gmail.com, ps2mefcc@gov.in, chowdhury.renuka@sansad.nic.in

To:                                                             May 14th 2018

Shri A K Mehta,


Genetic Engineering Appraisal Committee,

Ministry of Environment, Forest & Climate Change,

Indira Paryavaran Bhawan,

Jor Bagh, New Delhi 110 003.



Dear Shri A K Mehta,


Namaste. This is with regard to the decisions taken by the GEAC, under your Chairpersonship, on 21/03/2018 in its 134th meeting minutes of which have been put in public domain recently.


  1. About Commercial/Environmental Release of transgenic mustard hybrid DMH-11 and parental lines, developed by CGMCP, University of Delhi (Agenda Item No.4.1): It is seen that GEAC decided that the “applicant may be advised to undertake field demonstration on GM mustard in an area of 5 acres at 2-3 different locations with a view to generate additional data on honey bees and other pollinators and honey, and on soil microbial diversity”. This decision of GEAC is an extremely inadequate one, in relation to the decision that the Government is supposed to have taken, and the fact that GEAC was therefore asked to re-examine the issue of its clearance. In fact, the Government and GEAC have committed to the nation that there would be a review, and now GEAC is obligated to begin by first stating what its scientific review plan is, and not just have a 13-member meeting in which the review is degenerated to some minor decisions being reiterated.


  1. In the month of October 2017, GEAC put out the minutes of its 133rd meeting wherein a quick correction was made to the 24th October 2017 version on 25th October 2017, to share the “Decision of Government” separately. The Decision of the government was noted as “Subsequent to receipt of various representations from different stakeholders, matters related to environmental release of transgenic mustard are kept pending for further review”. This clearly implies that the issues raised in the representations are to be reviewed further, and not just the couple of matters that a sub-committee has already penned down as its issues for review.


  1. You might be aware that the Parliament’s Department-Related Standing Committee on Science & Technology, Environment & Forests has presented its report (No. 301) on “Genetically Modified Crops & Its Impact on Environment”, in August 2017. This report refers to the clearance provided by GEAC to GM mustard, and says, “the Committee further learns that GEAC has given its approval for commercialisation of GM mustard in spite of the fact that the matter is pending for decision in the Hon’ble Supreme Court of India. The Committee has been given to understand that GM mustard being a herbicide tolerant GMO, there is clear evidence on the adverse impacts of such GMOs from elsewhere in the world. In the case of GM mustard, from what one can gather from different quarters, there are serious unanswered questions. The Committee has also come to know that many state governments in the country are opposed to its entry even in the form of field trials, leave alone commercial cultivation. The Committee strongly believes that unless the biosafety and socio-economic desirability, taking into consideration long run effects, is evaluated by a participatory, independent and transparent process and a retrieval and accountability regime is put in place, no GM crop should be introduced in the country”.


  1. From some media reports, we understand that National Academy of Agricultural Sciences (NAAS) has tried to give a clean chit to GM mustard as well as GEAC’s evaluation processes. NAAS did not respond to many issues raised by the Coalition for a GM Free India (at http://indiagminfo.org/1960-2/, which was also shared with Minister Dr Harshvardhan. You would see many unanswered relevant questions with regard to GM mustard testing in this letter of ours. We further understand that NAAS has also not given any response to its own Fellows like Dr P C Kesavan (who was also a Member in the Supreme Court’s Technical Expert Committee in the GMOs PIL) who had written to Dr Panjab Singh and Dr K V Prabhu about the many issues with GM mustard as well as NAAS’s processes.


Meanwhile, it is also learnt that Dr M S Swaminathan who headed the GoI’s Task Force on Application of Agricultural Biotechnology in India has written to the Minister for Environment on July 22 2017, pointing out that the present system of regulation is inadequate.


In the recent past, Dr M S Swaminathan and Dr P C Kesavan have also authored a Guest Editorial in Current Science, in its 25th April 2018 edition (114 (08)), available here (http://www.currentscience.ac.in/Volumes/114/08/1585.pdf) wherein they state several reasons and present evidence to say that “it is for these reasons that genetic engineering, as of now, is not a sustainable technology” and show that IPM is an example of an inexpensive traditional technology sought after to the rescue of an expensive and sophisticated but failing technology (of “Bollgard II”).


  1. In late July 2017, a group of 17 economists wrote to the Prime Minister of India (http://indiagminfo.org/1941-2/), urging that the environmental release of GM mustard should not be authorised and presenting their arguments for the same. A copy of their letter was sent to the Minister for Environment too.


  1. On July 27th 2017, around 35 eminent medical experts of India had written to the Prime Minister of India, seeking the rejection of the environmental release application of GM mustard (by DU). Their letter is present at: http://indiagminfo.org/eminent-doctors-of-india-write-to-pm-asking-him-to-reject-the-environmental-release-application-of-gm-mustard/


  1. Earlier, many experts had written to GEAC on the AFES document of the sub-committee of GEAC and why the safety conclusions therein are unreliable: http://indiagminfo.org/gm-mustard-expertspeak/ . Additionally, numerous opinion pieces from experts have been published on the subject, which a responsible regulator ought to take on board.


  1. In October 2017, we also wrote to GEAC, raising serious questions on the functioning of GEAC, including on tweaking of discussions and recording of minutes.The letter is available here: http://indiagminfo.org/thanks-to-geac-for-running-the-great-indian-circus-in-the-name-of-gmo-regulation/


  1. None of the critical points of objection to GM mustard have been addressed so far by the regulators– the fact that GM mustard is indeed a herbicide tolerant crop with many adverse ramifications is simply being brushed aside by GEAC; the main claim of reducing edible oil imports is unverified and unjustified as the yield advantage of GM mustard was never proven with scientific vigour; the fact that state governments are opposed to the environmental release of GM crops and that their constitutional authority over agriculture in their state has to be upheld by the Centre is being ignored; this also has an additional aspect, in the context of unapproved spread of seed across state borders, which has to be resolved; the evaluation of GM mustard for its socio-economic desirability did not take place at all and biosafety assessment was unscientific and fraudulent is a reality. The fact that alternatives exist, which are more effective and safe ways of addressing the edible oil imports issue, was consistently ignored. The fact that GM mustard cannot pass muster on the results of the biosafety tests that were conducted, that the bio-safety testing itself was inadequate and that the entire biosafety assessment regime was compromised upon is only one part of the story. The way GEAC then went about finding devious and unacceptable ways of executing its bias towards approving GM mustard is the other important part of the story.


  1. Against the above backdrop, it is apparent that GEAC went about the “re-examination” of the environmental release application of GM mustard in a completely facetious and non-serious way, as reflected in the minutes of the 134th meeting minutes and has not taken up any serious review of the entire matter of environmental clearance of GM mustard. A glib conclusion that “GEAC examined all the representations and reiterated that these representations have already been deliberated extensively while taking the decision in the 133rd meeting of GEAC” is untrue. You could not have deliberated on these when the representations came to you after the 133rd meeting. It is important that GEAC should improve its credibility by not failing the nation once again. You are not addressing critical issues being raised, and therefore, just asking the applicant to undertake a field demonstration for data generation on 3 parameters is inadequate and objectionable.


  1. While the major issues with regard to GM mustard remain unaddressed, the latest decision of GEAC on the applicant having to “undertake field demonstration” in an area of 5 acres at 2-3 different locations is a matter of concern. What is “field demonstration” in regulatory parlance? Where is it present in the guidelines? Why only 3 parameters?


  1. Why is GEAC yet again asking the applicant to submit a detailed protocol for consideration and approval? Doesn’t GEAC have the expertise and guidelines for these tests? Will the tests be conducted with herbicide usage as is going to the reality if GM mustard does get approved or not? What about the fact that GM mustard has never been tested as a herbicide tolerant crop, for its environmental and health ramifications when accompanied by glufosinate, a point that has remained unaddressed by the regulators?


Therefore, we write to GEAC to ask you to kindly explain what exactly is the re-examination that has happened or that will happen, when the only decision is a reiteration of a decision already taken in the 133rd meeting of GEAC?


  1. Exemption of state government NOCs for event-selection trials (ESTs) (Agenda Items 5 and 7.1): It was on the insistence of a state government that the system of NOC from state governments was brought in by GEAC in 2010 for conduct of field trials. It is also apparent that most state governments do not want to have any environmental release of GMOs taking place in their states. Therefore, the operationalization of exemption clause to NOC requirement in the context of Event Selection Trials is unacceptable. This is also applicable to the guidelines and Standard Operating Procedures adopted for conduct of ESTs , given that these do constitute deliberate environmental release of GMOs into the environment.


  1. Bulk Imports of GM grains (Agenda Items 6.1 to 6.9): GEAC and RCGM cannot clear at their end any bulk imports of GM grains for processing without a proper safety assessment regime in place, taken up by some responsible agency. An RARM needs to consider our socio-cultural and other conditions before clearing any such imports. Similarly, FSSAI should have a rigorous regime in place for safety clearance, and it is not adequate to have guidelines and policy on labelling, as recorded in the decision under Agenda Item 6. The results of the safety assessment have to be put out in the public domain for independent scientific scrutiny and to support rigorous and responsible decision-making, and public feedback taken on board before any decision is taken.


  1. Import of Dried Distillers Grain Soluble (DDGS) for animal feed from GM corn (Agenda Items 6.12 to 6.20): We demand that no DDGS guidelines be finalised that do not include rigorous safety assessment within the country, with the same operational principles as mentioned in Point 3 above incorporated.


  1. On illegal soybean being imported into India (Agenda Item 9): We are disappointed at the lack of serious response from GEAC on our complaint (http://indiagminfo.org/complaint-to-geac-for-gm-soybean-lmo-import/) with regard to illegal soybean imports into India. While you had forwarded our complaint to DGFT, they have also forwarded another complaint from us to them, to GEAC (http://indiagminfo.org/regulators-pass-buck-to-each-other-other-ministries-while-hundreds-of-tonnes-of-illegal-gm-seed-import-takes-place-into-india-english-and-hindi-press-release/). This requires all concerned agencies to have an emergency meeting and intervene immediately, to trace such GM soy imports into the country, in case cultivation of the same is happening as has been discovered in Gujarat, and then take action to destroy the same. This also requires strict and foolproof procedures to be put into place to prevent future instances. We demand that GEAC convene one such meeting to resolve the matter with all the seriousness that it deserves.


  1. On FISEC report related to illegal HT Cotton in India (Agenda Item 7.4): Media reports (like this one for example: http://www.thehindu.com/news/cities/Hyderabad/dbt-panel-seeks-destruction-of-ht-cotton-seed/article23798964.ece ) indicate that the regulators are finally intervening in this matter, which they should have, years ago. Tracing back illegal seed production as the root of the problem and destroying seed stocks are important mechanisms to control the menace, in addition to fixing liability. We hope that there will be concrete action that will emerge from this FISEC processes. We had made a presentation to the FISEC about why concrete action is needed, and what such action should be and the same is available here: http://indiagminfo.org/coalitions-letter-presentation-to-field-inspection-and-scientific-evaluation-committee-looking-into-illegal-herbicide-tolerant-ht-cotton-in-india/


Before we end, we would like to reiterate that GEAC must take the review assigned to it by the government in the case of GM mustard with utmost seriousness and scientificity.  Thank you.





Kavitha Kuruganti


Coalition for a GM-Free India

Ph: 8880067772


Copy to:

  1. Dr Harshvardhan, Minister for Environment, Forest & Climate Change;
  2. Ms Renuka Chowdhury, Member of Parliament who chaired the Standing Committee that presented Report No. 301 to the Parliament in August 2017;
  3. GEAC members

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