Scientists remind India's prime minister that a Parliamentary Committee and the Supreme Court-appointed Technical Expert Committee (TEC) recommended a moratorium on open field trials of GMOs

A group of senior scientists in India has written to the prime minister to voice their concern about the "shocking" decision of the discredited biotech regulator GEAC to approve open field trials of GMOs.

The scientists (item 1 below) remind prime minister Modi that both the Parliamentary Standing Committee on Agriculture as well as the Supreme Court-appointed Technical Expert Committee (TEC) have recommended a moratorium on open field trials of GMOs until such time as a robust regulatory system is put in place.

The scientists write, "We would like to highlight the fact that opposition to open releases of GMOs originated in the scientific circles and continues to be fuelled by ever-growing scientific evidences of its adverse impacts."

In addition, the eminent lawyer Prashant Bhushan has written to the new Environment Minister to express his "alarm" and "distress" at GEAC's move (item 2 below). Bhushan writes, "It is a moot point, for example, that the Tobacco Industry covered up, and lied about the link with cancer for over 35 years. It is regrettable that there is evidence of a similar pattern being repeated for GM crops; a new lab-based technology of a mere 20 years, which is nowhere near a tried and tested timescale for agriculture."

Both letters have been made public on India-based websites.

1. Scientists' letter
2. Prashant Bhushan's letter

1. Scientists' letter

New Delhi, 1 August 2014

To
Shri Narendra Modi,
The Prime Minister
Govt of India

Dear Sir,

Bringing to your notice the science-based concerns on the environmental release of Genetically Modified Organisms (GMOs) and urging your action to stop them.

We are writing this to bring to your attention the serious concerns of the Indian scientific community on the recent decision by the Genetic Engineering Appraisal Committee (GEAC), under the ministry of Environment and Forest, to approve numerous experiments on GM crops, including many GM food crops.

It is shocking that GEAC took this decision in their first meeting after your government took charge. It is unfortunate that the committee continues to follow the unscientific approach towards environmental release of GMOs when there is growing scientific evidence for the adverse impact of GMOs on human health and environment which has been repeatedly brought to their notice.

Equally important are the experiences from across the world on the potential of this technology to facilitate monopolisation of seeds by a select few multinational seed companies. One has seen that with Bt cotton, the only GM crop approved for commercial cultivation in our country. Within a decade of its approval, Monsanto, the largest Biotech seed company in the world, has taken total control of our cotton seed market through its proprietary Bt cotton.

We would like to highlight the fact that opposition to open releases of GMOs originated in the scientific circles and continues to be fuelled by ever-growing scientific evidences of its adverse impacts. This is precisely the reason that majority of the countries in the world have decided to take a precautionary approach towards this controversial technology.

Even in our country the first and only Agri biotechnology taskforce appointed by the government of India and headed by Dr M. S. Swaminathan in its report submitted in 2004 had recommended that transgenics should be resorted to only when other viable options have been exhausted. The task force also recommended that a robust regulatory system should be put in place.

This is the approach that has been further reflected in the reports by the Parliamentary Standing Committee on Agriculture as well as the Supreme Court-appointed Technical Expert Committee (TEC). Given the scientifically valid concerns on open releases of GMOs as well as the serious inadequacies in the existing regulatory system in our country both these committees had strongly recommended against any open release of GMOs, including their field trials, until a robust regulatory system in in place. Unfortunately the previous UPA government consistently rejected these prudent advices.

We hope that your government would rectify this mistake and ensure that safeguarding of biosafety and livelihoods of farmers as well as ensuring seed sovereignty and food security of the nation will be the primary concern when assessing the need and the safety of GMOs. We would also like to point out that this precautionary approach towards GM crops is consistent with the promise given by your party, Bharatiya Janatha Party (BJP), in its election manifesto.

We hereby enclose the letter that we had written to the previous Prime Minister of our country urging him to keep science, society and the interest of the nation in mind and accept the recommendations of the TEC. This letter was endorsed by more than 250 Indian scientists of eminence including Padma Awardees, Vice Chancellors of universities, etc.

Looking forward to your urgent action in stopping the field trial approvals and giving our
country a new policy direction in the regulation of such technologies which will put science, society and national interest before profit motives of a few.

Sincerely yours

Signed:
1. Padmabhushan Dr. P.M Bhargava
Former member, National Knowledge commission, Founder Director, Centre for Cellular and Molecular Biology, Hyderabad
2. Dr. Minoo Parabia,
Retd. Professor and Head, Dept. of Bio Sciences, Veer Narmad South Gujarat University, Surat, Gujarat
3. Dr. V.S Vijayan,
Former Chairman, Kerala State Biodiversity Board, Former Director, Salim Ali Centre for Ornithology and Natural History, Coimbatore.
4. Prof. Dinesh Abrol,
Institute of Studies in Industrial Development,Visiting Professor, Centre for Studies in Science Policy, Jawaharlal Nehru University, New Delhi
5. Dr. Tushar Chakraborty,
Sr Scientist, Indian Institute of Chemical Biology, Kolkata, Member, State Biotechnology Council, Govt of West Bengal.

2. Prashant Bhushan's letter

July 24, 2014

To:
Shri Prakash Javadekar
Hon’ble Minister
Environment, Forests & Climate Change
Paryavaran Bhavan, New Delhi

OPEN FIELD TRIALS OF GM CROPS IN INDIA’S ESSENTIAL FOOD CROPS

Dear Prakash ji

I take this opportunity to congratulate you on your appointment to this critically important Ministry, our only regulating Ministry with a mandate to protect India’s ecology. Your appointment comes at a time when the deleterious impacts of Climate Change on India are a visible reality. Should India lose her ecology, she will of course lose her "balance sheet".

I write to you on the specific matter of GM crops and their open field trials (OFTs). GM crops are without doubt one of the most important issues that we face in India because their introduction will place us in an irretrievable situation due to contamination with profound implications across many dimensions. GMOs will reproduce themselves in the environment and the food chain unless prevented and this fact is central to the discussion with the necessary application now, of the constitutionally supported Precautionary Principle. Unlike drugs, which can be recalled, contamination of the environment and of our genetic seed stock will be irreversible. You are, of course, aware that India’s genetic diversity is unique worldwide and critical to our own future food security. In this context, I am both alarmed and distressed to learn that the GEAC have just approved OFTs in several food crops including mustard, rice chickpea brinjal, corn etc. We are the only country to experiment with our food crops in this manner. Smt. Jayanti Natarajan, considering the report of the Parliamentary Standing Committee (PSC) had put a pro tem bar on OFTs pending the adjudication of the Final Report of the Supreme Court-appointed Technical Expert Committee (TEC).

I must inform you that the TEC was appointed by the Supreme Court and included experts nominated by the MoEF. The TEC has given a very scathing report against the regulatory system prevailing in India, pointing out how inadequate it is and is riddled with serious conflicts of interest. The TEC has also recommended a 10 year moratorium on commercial release of GM and BT crops. The PSC under the Chairpersonship of Shri Basudeb Acharia has also found that regulatory system to be inadequate and riddled with conflict of interest, and has recommended a probe against the regulator for approving the commercialization of BT brinjal (which was thankfully stopped by then Minister Shri Jairam Ramesh). The UPA government completely ignored the recommendations of the TEC and PSC.

Unfortunately, Shri Moily was appointed to the MoEF in the dying days of the UPA government in order to reverse the policy adoped by Smt Natarajan. Both Dr Manmohan Singh and his Minister of Agriculture Mr. Sharad Pawar, (heading a GMO-promoting Ministry), actively supported a policy to introduce this new & risky technology into India. I am hopeful that given the clear statement of the BJP Manifesto that “GM foods will not be allowed without full scientific evaluation on the long-term effects on soil, production and biological impact on consumers”, that you will on this principle put a moratorium on OFTs. Indeed, this well articulated policy of the BJP is also the essential mandate of the Supreme Court appointed TEC, with the issue of open field trials as the core inquiry, whether they should or should not be conducted and if so how and when. I emphasise that the TEC, its members and TOR, were accepted by the Supreme Court at the urging of your Ministry. I make the earnest request that you re-impose a bar on OFTs till a regulatory overhaul is done, as is recommended by the TEC as well as the PSC. There are several reasons for my request. I make the most important points based on the following incontrovertible facts:

i. OFTs are a confirmed source of contamination of sexually compatible Non-GM crops and there are several well documented examples with Bent grass, Bayer rice LL601 and very recently, the wheat contamination by a herbicide tolerant (HT) GM wheat discovered in a farmer’s field in Oregon. The latter happened despite the field trial site being several hundred kms away. No one yet knows how because GM wheat is not commercially approved in the US. Bayer’s rice LL601 field test caused over $1 billion of export losses in US long grain rice as a result of a single open field trial. Eventually, a $750 million out-of-court settlement was made to affected farmers. The ramifications of the wheat contamination may approximate those of LL601. Indeed, acknowledging the evidence, and the risk to a Rs 12000 crore export market for Basmati, the GEAC accepted the potential risk of contamination with the decision that no GMO rice field trials would be conducted in Basmati areas. This principle of course must cover all crops not just elitist rice like Basmati. And the principle of protecting organic and non-GMO export produce from GMO contamination is similarly critical because of India’s huge potential to cater to this most rapidly growing segment of the world market which she leads in. Ultimately, neither isolation distances however long nor rigour are safeguards against insect-mediated pollen flow and wind. We ought not to be surprised that we cannot control nature.

ii. There is the further matter that for every GMO crop that undergoes field-testing, the GMO parental lines must be planted out for seed production. These are entirely glossed over by the GEAC. Yet these present even greater potential for contamination than the actual field test because the crop has be allowed to "go to seed" quite literally, unlike in the field test where it is not allowed.

iii. These open releases involve untested and therefore, unsafe GMOs. Curiously, the Regulators and MoA in their Affidavit have demanded that this principle be accepted because field trials are required to undertake bio-safety studies. Frankly I am greatly surprised by this specious, circular argument and equally by its unscientific and factually wrong basis. Field testing is mainly for agronomic reasons. We all know this. The Bt brinjal dossier also proves this. There is a sequencing of bio-safety studies as part of a risk assessment protocol, which shows at which point if appropriate, open release of any GMO may be allowed. These are matters that the TEC have dealt with as part of the TOR agreed by the MoEF in their submission to the Supreme Court.

iv. The conspicuous lack of regulatory oversight of OFTs is not in dispute. Official reports of the Parliamentary Standing Committee (PSC), the Sopory Committee and now the TEC attest to just how negligent and unconcerned our regulators are with regard to the risks of GMO contamination. They also attest to serious conflicts of interest and lack of expertise. Indeed, the Sopory Committee Report is precisely about the contamination of BNBt, the ‘desi’ GM cotton Event, that was found to have a Monsanto gene. The manner of this contamination remains unknown; but BNBt was approved for commercial cultivation after the contamination had already occurred. It was subsequently withdrawn. The grave implications of this will no doubt be immediately apparent to you. Serious lapses of this kind extending to all dimensions of bio-safety were evident in the case of Monsanto’s self-assessed bio-safety dossier of Bt brinjal. The PSC in its final report of March 2014 replying to the Government has maintained its recommendation that Open field trials in “any garb” be stopped.

Finally, it is a moot point, for example, that the Tobacco Industry covered up, and lied about the link with cancer for over 35 years. It is regrettable that there is evidence of a similar pattern being repeated for GM crops; a new lab-based technology of a mere 20 years, which is nowhere near a tried and tested timescale for agriculture. Industry- generated safety studies cannot be any basis for safety claims of GMOs as made by our regulators. These must be disallowed. They show neither health nor environmental problems. Yet, new and reliable independent research in several separate independent research facilities in the West has thrown up the spectre of important long-term health consequences of at least some already commercialised GMOs, requiring India to take urgent steps to address the risks of GMOs in her agri-policy.

I hope very much that what I have said will resonate with you. Equally, I hope that you will advise your government to distance itself from the UPA government’s policy on GM crops which are not at all in India’s interests. I think it is fair to add that we need to be reassured that the BJP government will implement the promises of its Election Manifesto in the matter of GMOs and stop these unsafe OFTs as a first step in the letter and spirit of those promises. Prime Minister Shri Narendra Modi has also repeatedly emphasised on encouraging organic farming in the country.

You might also be aware that several major countries in the world, including almost all European Union nations, have prohibited the use of GM food crops.

I would like to personally meet you, as soon as possible, at a time of mutual convenience to discuss this issue further. Please let me know when we can meet.

Yours sincerely
PRASHANT BHUSHAN