To
Shri.Veerappa Moily,
Union Minister for Environment and Forests,
Government of India.
Dear Sir,
Sub: Bringing to your attention concerns related to GMOs in our environment including for field trials, and urging you to protect our food, farming and environment – Reg.
New year Greetings! Congratulations on taking up the challenging portfolio of the MoEF. We write to you from a large platform of farmers’ organisations, environmental organisations, scientists, intellectuals, consumer organisations etc., who have come together under the banner of the Coalition for a GM-Free India. This is to bring to your urgent attention our serious concerns on Genetically Modified Organisms (GMOs) which pose a serious threat to our environment and human health, besides jeopardizing the sustainability of food and livelihood security in our country.
The Environment Ministry, under your highly capable predecessors, had in the recent past taken commendable rational steps on safeguarding Biosafety when introducing risky technologies like GMOs into the environment – this is not surprising given that the very mandate of this Ministry is that of protecting the environment, and ensuring sustainable development. As you are kindly aware, this has built some confidence in the larger public on the intent and actions of the ministry in this matter, that too in the face of the unscientific clamour from promotional ministries. It is indeed unfortunate that the mantle of protecting biosafety should fall on the Environment Ministry alone, when environmental concerns should be an integral part of the governance of every Ministry, including Agriculture and Science & Technology. Be that as it may, the public certainly expects the Environment Ministry, with its responsibility for regulating GMOs, to ensure that biosafety is not compromised at any cost.
The debate around GM crops and the opposition to their open release, including in the name of experimental trials in the open air, had been growing in India ever since Bt cotton, the first GM crop, had been released for such experimental trials and later commercialization, more than a decade ago. This opposition became very vociferous and clear ever since Bt Brinjal, the first GM food crop reached commercialization stage – more scientists and other citizens started coming out into the open to explain their opposition to this risky technology in our food and farming. After a detailed democratic consultation process with various stakeholders including scientists, public, industry and state governments, the then Union Minister for Environment and Forests, Shri Jairam Ramesh, placed an indefinite moratorium on the commercialization of Bt brinjal. This decision had been hailed as one which is both responsive to society and responsible to science. This approach had been followed by Smt Natarajan who had succeeded Mr Ramesh as the Environment Minister. This is only natural given that both these Ministers were fulfilling the mandate of the Ministry. They also upheld the constitutional authority of state governments over Agriculture in ensuring that no field trials take place in any state without an express clearance from the government concerned.
This precautionary approach towards GM crops, a technology against which there is a growing body of scientific evidence has been recommended by other credible agencies that had looked into the matter, including the Parliamentary Standing Committee on Agriculture[1]. The Standing Committee comprising of M.Ps from various political parties (including many from the UPA) had tabled in the Parliament a unanimous report in August 2012, after detailed and expansive deliberations and consultations, strongly recommending against any haste in embracing GM crops owing to real and potential threats to human health, biodiversity, seed sovereignty, food security and farm livelihoods. They had also pointed to the serious lacunae in the current regulatory regime, in addition to the serious gaps in the proposed regulatory system under the Biotechnology Regulatory Authority of India (BRAI) Bill and advised against any open release of GMOs including field trials until a biosafety protection regime is put in place.
The Parliamentary Standing Committee report also helped in breaking the myth around Bt cotton where the committee found through its consultation that Bt cotton has not been the big success as hyped by its promoters which includes biotech seed companies and their promoters in the government (which unfortunately also includes the Union Ministry of Agriculture). This has also been substantiated by independent analysis of government’s own data by civil society groups which was put out in 2012, a decade after the commercialization of Bt cotton [2].
The recommendations of the Standing Committee were reiterated by the final majority report submitted by eminent independent scientists of a Technical Expert Committee (TEC) set up by the Supreme Court. These experts were drawn from the fields of Molecular Biology, Environmental Science, Nutrition Science, Toxicology etc. The TEC was constituted in response to a PIL against environmental release of GMOs.
The TEC in its final majority report submitted in July 2013 had also pointed to the scientific evidence on adverse impacts, the inefficiency of the current regulatory system as well as the potential for GM crop field trials to contaminate our biodiversity, our food and seed supply and therefore had recommended for a halt in field trials until the regulatory system is made robust. They had also suggested against the indiscriminate use of this technology and especially recommended against Bt food crops, Herbicide Tolerant GM crops and transgenic versions of those crops for which India is a Centre of Origin/Diversity. A recent letter to the Prime Minister by 256 Indian scientists, including eminent Padma awardees, 11 former as well as current Vice Chancellors of Universities and various others from relevant disciplines, had urged the PM to recognize the existing scientific evidence against GM crops and accept the final report of the independent experts in the SC TEC [3].
It is also important to note that state governments across the country had been raising concerns on GMOs. Given that Agriculture and Health come under the state list of our Constitution, it is important that the views of the state government are taken into consideration when it comes to any open release of GMOs. It is noteworthy that 13 state governments had formally sent their objections on commercialization of Bt Brinjal to MoEF at the time of public consultations on the same. State governments have also been opposing field trials.
It is these various factors involving science based evidence, widespread public opposition along with concerns raised by State governments which prompted your predecessor, Smt Jayanthi Natarajan to halt open field trials of GM crops until the Supreme Court takes a view on the final report of the TEC. We believe that there is no reason why field trials should be allowed in any urgency.
Given that various credible and independent agencies and experts are repeatedly pointing to concerns which are scientifically substantiated as well as socially relevant, it would be prudent to follow a precautionary approach towards GMOs so that as a country we do not become an experimental laboratory for this risky technology and inadvertently make our citizens lab rats. This is important because this is a living, irreversible technology with an ability to perpetuate itself. We sincerely hope that you will stand by the primary mandate of the Ministry of Environment and Forests of conserving biodiversity, protecting the environment and biosafety, and ensuring sustainability in our development pathways. We urge you to please continue with the precautionary principle-based approach on GMOs that the ministry has been following in the recent past.
Yours Sincerely,
Rajesh Krishnan,
Convenor, Coalition for a GM Free India
Mob: 09845650032
email: rajeshecologist@gmail.com
References:
1. The second edition of the compilation of references of peer reviewed studies with abstracts numbering more than 400 such studies can be accessed at http://indiagminfo.org/?p=657
2. The 10 year analysis of Bt cotton by coalition for GM Free India is available at http://indiagminfo.org/wp-
3. The letter to Prime Minister by more 256 Indian scientists highlighting the concerns with GM crops and urging the PM to accept the majority TEC report can be accessed at http://indiagminfo.org/?p=654
Copy to:
Dr. Manmohan Singh, Prime Minister, Govt of India.
Smt. Sonia Gandhi, Chairperson, UPA.