To:                                                                                                                          July 27, 2017

Shri Narendra Modi,

Prime Minister of India.

 

Dear Sir,

Sub: Reject the “environmental release” application of GM mustard

Namaste. We write to you as concerned members of the medical fraternity of India, with regard to the possible approval to an application by Delhi University with the Ministry for Environment, Forests and Climate Change for “environmental release” or commercial cultivation of their GM mustard hybrid seed and of the parental lines too. This GM mustard happens to be a herbicide-tolerant GMO developed with nearly 100 crores of our taxpayers’ funds spent on it. Very often, it is being argued that since it is a public sector product, India should allow it, forgetting that what is inherently unsafe (created through transgenic technology) is bound to be unsafe whether it is from the public sector or private sector. A majority of countries around the world disallow GM crop cultivation due to the various risks associated with this technology and given the fact that this is an living, irreversible technology when released into the environment.

Several reports are available about the large environmental health crisis that is unfolding in some South American countries after they adopted herbicide tolerant GM crops on a large scale. In HT GM crops, the danger is both from the genetic engineering process as well as the chemical/herbicide that is used on the crop. In other countries, Maximum Residue Levels (MRLs) of herbicides were revised upwards, manifold, to accommodate the use of herbicides directly on the HT crop. This has implications for the consumers’ health, as can be imagined.

Health effects of GM foods: There is ample scientific evidence available that GM foods (often in combination with herbicides that are used on GM crops which are mostly herbicide tolerant given that 81% of the GM crop extent worldover is planted to herbicide tolerant GM crops) result in numerous adverse health impacts starting from allergies, to impaired immunity, organ damage, affected growth and development of an organism, reproductive health problems, and even carcinogenic effects.

Testing inadequate and appraisal processes unreliable: In the case of GM mustard sought to be introduced in India, evidence points to the fact that even the limited number of tests that were done on Bt brinjal (it was because of these tests and the results being made public that Bt brinjal was found to be unsafe and put under a moratorium) were not taken up for GM mustard safety assessment.

There were no chronic and inter-generational health impact studies done, and the longest test was for sub-chronic toxicity, for 90 days. This study was done without treating the GM mustard as a herbicide tolerant crop. From limited data available, it appears that there were indeed some significant differences found between GM mustard and other control groups, but that these differences have been simply brushed aside as issues with the experimental design itself, rather than perform the experiment rigorously!

Even though the face being projected is that of a public sector institute even here (for health safety testing), some tests were outsourced to private laboratories. No data has been put out in the public domain and it is unclear why this was so. On a matter that pertains the future health of citizens, such secrecy is inexplicable, that too when the regulatory body itself does not have all the required areas of expertise to assess risk.

There were no health ministry representatives who participated in the appraisal of GM mustard. Further, in the sub-committee created to appraise safety of GM mustard, the one health expert put in had objectionable conflict of interest by virtue of being a Board member in industry funded bodies like ILSI and by virtue of having taken up health safety studies in the institute that he headed (as Director of National Institute of Nutrition). Importantly, he also did not participate in the 4 meetings of the sub-committee but only gave a written sign-off towards the end. It is noteworthy that the regulatory system is not being rid of conflict of interest.

There has been no testing of GM mustard’s impacts on Indian Systems of Medicine.

Glufosinate’s known health impacts: GM mustard has been genetically engineered by the insertion of bar gene, to withstand the application of a weedicide called Glufosinate. In India, Bayer has an active patent on this chemical. The implications of more chemicals that are sprayed directly on our food are clearly worrisome – mustard leaves, for instance, in this case which are eaten as Sarson da Saag.

Glufosinate ammonium, the herbicide that goes along with this GM mustard seed is known to have several adverse impacts including on newborn babies.  Additionally, evidence points to toxicity to intestinal micro-flora, impact on fetal development etc. Farmers are very likely to use glufosinate indiscriminately on GM HT mustard, and in increasing quantities as ‘super weeds’ start emerging. It seems ill-advised that we should let our citizens be exposed to toxins like this.

Specious, unscientific arguments of promoters: Sir, it is often argued that in other countries like the USA, they have been eating GM foods for a long time and nothing untoward has been reported from there. This is an unscientific statement and conclusion on the safety of any food. Can the ones making this statement provide scientific evidence to show that the increasing incidence of various illnesses is not related in any way to GM foods being cultivated and consumed? Lack of evidence is not proof of safety, and building evidence on health impacts of GM foods in a real life situation with many confounding variables at play is going to be very challenging. That is the reason why we need sound, independent, long term testing in the experimental stage itself and base our decisions on the same. This was not done in the case of GM mustard.

It is also unscientific to equate the fact that we consume some GM edible oil imported from other countries, with risks that we will have to face if we grow a HT GM crop in our farms here in India. It is obvious that exposure to toxins are going to be more direct and higher, since our workers toil in the herbicide sprayed fields constantly and we also eat other parts like mustard leaves and seeds in our food (and not just oil).

It is also a completely untenable argument from the regulators that we can put into place new punitive measures to prevent farmers from using Glufosinate on this herbicide tolerant mustard crop. We have a proven history of failure of regulation both in the case of pesticides as well as GMOs. It is time that the government accepted clearly that this is a herbicide tolerant crop, and farmers are bound to use it as such. Which then presents unacceptable dangers to farmers, workers and consumers.

GM mustard is not needed: GM mustard is a danger for cultivators, agricultural workers as well as consumers. On the other hand, there are no good reasons that can be seen so far as to why this GM mustard is needed, or what kind of benefits it will offer. There is absolutely no evidence about this. It is unclear why the country should be taking this dangerous step of allowing GM mustard to be cultivated in India. Around the world, only 3 countries have allowed GM canola/rapeseed to be grown on their lands. A vast majority of other countries do not opt for GM hybrids, and their yields are better. This includes China too.

It is clear from the history of pesticides as well as other products like tobacco that products claimed to have been safe have been shown to have health hazards over a period of time.

It is against this background that we write to you now to request you to urgently reject this GM mustard commercialization application. This is an unsafe and unneeded GMO and India’s citizens and environment should not be forced to face the risks and dangers of this GM mustard.

As medical experts, we are aware that the impact of environmental toxins on an already malnourished population is going to be more adverse than on others. This is our reality in India, with its vast proportion of malnourished children and women. While there are unmet health and nutrition needs, GM mustard is definitely not needed. We cannot subject their precarious health to such toxins as GM mustard and its associated herbicide. Thank you.

Sincerely,

Dr Vallabhbhai Kathiria,

Former Union Minister of State for

Health and Family Welfare;

Chairman, Gauseva & Gauchar Vikas Board, Gujarat

 

 

Also endorsed by:

1. Dr Anbumani Ramadoss, Member of Parliament, and Former Union Minister for Health and Family Welfare
2. Padma Bhushan Dr B M Hegde, Retd. Vice Chancellor, Manipal Academy of Higher Education, Karnataka; Dr BC Roy Award recipient
3. Padma Bhushan Dr Inderjeet Kaur, All India Pingalwara Society, Amritsar
4. Dr Lalit Nath, Former Director of All India Institute of Medical Sciences, Delhi and Currently with Independent Commission on Health and Development, New Delhi
5. Dr GPI Singh, MD (Preventive & Social Medicine), Public Health expert and Vice Chancellor of Adesh (Medical) University, Bathinda
6. Dr Ashok D B Vaidya, MD, PhD, FAIM, Research Director – Kasturba Health Society-Medical Research Centre; Director-Clinical Pharmacology, BSES & Global (BK) Hospital; Adjunct Professor – Saurashtra University Rajkot, Drexel University Philadelphia, Transdisciplinary University Bengaluru and Gujarat Vidyapeeth Ahmedabad
7. Dr H N Ravindra, Member, Medical Council of India; Senate Member of Rajiv Gandhi University of Health Sciences; President Elect IMA KSB, Mysore
8. Dr Kanubhai Kalsaria, former BJP MLA of Gujarat Assembly (3 terms) and Chairman, Sadbhavna Hospital Trust, Mahuva, Gujarat
9. Dr Mihir Joshi, Chairman, Jyoti Hospital, Visnagar, Gujarat; Former President, Gujarat Ophthalmic Association
10. Dr Veena Shatrugna, Former Deputy Director, National Institute of Nutrition, Hyderabad
11. Dr P L Garg, Former Registrar, Baba Farid University of Health Sciences, Faridkot, Punjab
12. Dr Mira Shiva, Public Health Physician, Doctors for Food Safety and Bio-Safety; Initiative for Health & Equity in Society, New Delhi
13. Dr Amarsingh Azad, Paediatrician and public health expert, Punjab
14. Dr Arulmozhi Varman, Ophthalmic Surgeon, Tamil Nadu
15. Dr Arun Mittra, All India General Secretary, Indian Doctors for Peace & Development
16. Dr Basavaraju, Charaka Hospital, Tumkur, Karnataka
17. Dr Bharat Shah, Paediatrician and Director, Nature Cure Centre, Vadodara
18. Dr C Sathyamala, Epidemiologist and public health expert
19. Dr Chetan Deshmukh, Oncologist, Pune
20. Dr Dinesh Patel, Cardiologist, Ahmedabad
21. Dr G Sivaraman, Managing Director and Chief Siddha Physician, Arogya Healthcare, Chennai
22. Dr Jasbir Gupta, Gynaecologist, MBBS FBGO, Mhow, Madhya Pradesh
23. Dr Ketan Jhaveri, Physician, Surat, Gujarat
24. Dr Kishor Mistry, MD, Physician, Gujarat
25. Dr Mohan Rao, MBBS, PhD, Professor, Centre of Social Medicine and Community Health, Jawaharlal Nehru University, New Delhi
26. Dr Nirja Singh, Paediatrician, Mhow, Madhya Pradesh
27. Dr Pradeep Ninan, Consultant Paediatric Surgeon
28. Dr Sachin Hingmire, Oncologist, Pune
29. Dr Sameer Melinkeri, Haemotologist, Consultant, Dinanath Mangeshkar Hospital, Pune
30. Dr Shri Gopal Kabra, Director, Clinical Services, Bhagwan Mahaveer Cancer Hospital, Jaipur
31. Dr T Thirunarayanan, Centre for Traditional Medicine & Research, Chennai
32. Dr Uma Divate, Consulting Physician MD, Jahangir Hospital, Pune
33. Dr Vandana Prasad, Community Pediatrician, New Delhi
34. Dr Venkatesh Krishnamurthy, Urologist; Medical Director of NU Hospitals, Bangalore; Former President of Bangalore Kidney Foundation

 

Endorsements of Dr Suchitra Ramakumar, Chennai and Prof Dr. C S Pandav, former Head, Centre for Community Medicine, AIIMS, New Delhi came in subsequently.