Bharat Krishak Samaj is India's leading farmers' organisation with some 5 million farmers as members.
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BHARAT KRISHAK SAMAJ (FARMERS' FORUM INDIA )
Chairman: A-1,Nizamuddin West,
Dr.BAL RAM JAKHAR New Delhi-110013
Governor, Madhya Pradesh Phone:4359508,
Telefax: 24359509
Executive Chairman Email:This email address is being protected from spambots. You need JavaScript enabled to view it.
Dr.KRISHAN BIR CHAUDHARY Former Chairman, State Farms Corporation of India
09th May, 2006

To
The Secretary,
Ministry of Health & Family Welfare,
Govt. of India
Nirman Bhavan,
New Delhi

Dear Sir,

Bharat Krishak Samaj is against the irreversible, uncontrolled, and potentially dangerous release of genetically modified organisms (GMOs) into the environment. We are also concerned about the health hazards of GM products

We are in favour of Mandatory Labelling of All GM products, irrespective of the percentage of traces of GM materials present in the product in any form whatsoever.

Labelling norms should clearly state that it is a GM product. There should be no soft provision to state "May Contain GM Traces".

GM products can enter the market either through imports or through domestic production. As of now only approved GM product in the country is Bt cotton. But we are sorry to note free clandestine imports of GM seeds and GM food and feed into the country, flouting all regulatory norms. Unapproved imported GM seeds are being cultivated in this country, in blatant violation of biosafety norms.

ON IMPORT ISSUES :-

We are happy to note new changes in the Foreign Trade Policy which said that all imported GM products should be labeled. If the consignment does not contain such a label and is later found to contain traces of GM material, the importer is liable for penal action under Foreign Trade (Development & Regulation) Act, 1992. This is an indication for Mandatory Labelling

But we are agrieved to note that the Foreign Trade Policy in another clause said : "It has been decided to allow pre-shipment test certificates from accredited international agencies in lieu of test reports." Similar are the words of the draft proposals of the health ministry on proposed amendments to the PFA rules which says that labeling should also "indicate that the product has been cleared for marketing and use in the country of origin so that the verification, if needed can be taken up with that country without having to resort to testing."

The Foreign Trade Policy and the draft amendments to the PFA Rules, therefore, in one voice wants to legalise the entry of GM products through labelling and without adequate tests on risks involved - WE VEHEMENTLY OPPOSE THIS MOVE

Recently, the GEAC in its last meeting gave a green signal to imports of crude and refined soyabean oils extracted from genetically modified sources. The consensus which emerged at the GEAC meeting was to allow soyabean oils extracted from a particular strain of GM soyabean, saying that oil from this particular strain is being imported in many countries of Asia. Besides, GEAC is of the opinion that only crude soyabean oil can contain traces of GM and not refined soyabean oil.

Further legalising the imports of GM soyabean oil, the GEAC has shown some motivated concerns. Motivated, because it wants to legalise entry of GM soyabean oil. It said that only crude GM soyabean oil should be labelled and the processors in the country should adhere to safe disposal norms - WE VEHEMENTLY OPPOSE THE GEAC MOVE TO LEGALISE THE ENTRY OF CRUDE AND REFINED GM SOYABEAN OILS.

ADEQUATE TESTS SHOULD BE DONE IN THE COUNTRY TO ESTABLISH THE SAFETY OF GM PRODUCTS TO BE APPROVED FOR IMPORTS. TESTS SHOULD ESTABLISH SAFETY OF HEALTH AND ENVIRONMENT. THE PROCESS AND RESULTS OF SUCH TESTS SHOULD BE MADE TRANSPARENT.

If such adequate tests cannot be conducted in the country to establish health and environment safety, precautionary principles of the Cartagena Protocol on Biosafety should be applied to deny imports of GM products for food, feed, processing and cultivation. However for research purposes, imports may be allowed, but with a strict provision of not allowing its release in the environment. Caution should be taken that the research materials are not clandestinely diverted for use in food, feed and processing for consumption.

Here is the relevant portion of the Cartagena Protocol : "lack of scientific certainty due to insufficient knowledge regarding the extent of the potential adverse effects of a living modified organism on conservation and sustainable use of biological diversity in the Party of import, taking also into account risks to human health, shall not prevent that Party from taking a decision, as appropriate, with regard to the import of the living modified organisms in question.....to avoid or minimise such potential adverse effects."

ON DOMESTIC ISSUES

Under the present WTO regime no member country cannot afford to have dual policies for domestic production and consumption and imports. The new changes in the Foreign Trade Policy has called for Mandatory Labelling of GM products intended to be imported. Therefore, under the present WTO regime, if GM products intended to be imported are to be labelled, the same has to be for products domestically produced and approved. HENCE WE SUPPORT MANDATORY LABELLING OF DOMESTIC GM PRODUCTS.

But we are very much concerned with the spate of approvals being given to new varieties of Bt cotton by GEAC, despites reported cases of failure of earlier approved varieties, largescale violations of biosafety norms and new evidences of adverse effects on animal health due to consumption of Bt cotton seeds and plant parts.

There are in pipeline a number of GM food crops for approval. We feel that there is no sufficient sphisticated mechanism in this country to establish the safety of GM crops. We, therefore, demand a moratorium on release of GM crops, invoking the Precautionary Principles.

ON OTHER COMPLEX ADMINISTRATIVE AND POLICY ISSUES ;

We are in doubt how far the efforts of the health ministry would be effective, in face of the behind the scene activity in the government.

The Commerce ministry through Foreign Trade Policy suggested Mandatory Labelling. The health ministry has taken up the issue. But there are other agencies in the country which can dilute the prescribed norms at their behest.

The agriculture ministry is in charge of implementing plant and animal quarantine norms. The ministry recently diluted prescribed quarantine norms to import wheat from Australia.

The Bureau of Indian Standards (BIS) is designated as WTO TBT point in the country. BIS is negotiating with standard setting bodies of other countries for working out Mutual Recognition Agreements (MRAs). MRAs are designed to relax norms for mutual acceptance by both the importing and exporting countries. The Export Inspection Council (EIC) is also engaged in working out MRAs with other countries. This they feel is designed to boost country's exports. In this context, we feel there are chances of strict GM Labelling norms and GM regulations in the country being relaxed to give easy entry to GM products and in return gain access for exports of other commodities

The most worrying situation has been created by the recent India-US Knowledge Initiate in Agriculture Research and Education. We fear that through this pact US may put pressure to relax our regulatory norms on GM products.

Next there are plans to dismantle GEAC which is under environment ministry. There are plans to set up an autonomous regulator for GM products as suggested by the MS Swaminathan Committee and RA Mashelkar Committee. WE FEEL SUCH A MOVE WOULD BE DANGEROUS. GEAC SHOULD CONTINUE UNDER ENVIRONMENT MINISTRY AND HEALTH AND ENVIRONMENTAL CONCERNS REGARDING GM PRODUCTS SHOULD BE VIGOROUSLY ADDRESSED WITH TRANSPARENCY.

Similarly there is a move to minimise the role of health ministry, directorate of PFA and ICMR in their say over the concerns for health hazards relating to GM food and feed. The Food Standards and Safety Bill 2005 tabled in Parliament seeks to take away the powers of health ministry, directorate of PFA and ICMR. It has suggested setting up of a Food Authority, presumably under the administrative control of the ministry for food processing industries. WE FEEL THAT SUCH A MOVE WOULD BE DANGEROUS. HEALTH MINISTRY, DIRECTORATE OF PFA AND ICMR SHOULD HAVE GREATER SAY AND THEY SHOULD BE AGGRESSIVE IN EXPERSSING CONCERNS OVER THE SAFETY OF GM FOODS.

Thanking you,
Yours sincerely,
(Krishan Bir Chaudhary) Executive Chairman