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18
November 2016
 |
| Mustard (The Total Investment & Insurance Solutions) |
To begin with, public funds should not have
been wasted on developing an herbicide tolerant (HT) genetically modified (GM)
crop. Further, regulators should not have ever entertained an application for a
HT crop and allowed it to come this far. It is by now established that no
testing of GM mustard has been done as needed for HT crops. This is because
both the crop developer and the regulators have been denying that it is an
Herbicide Tolerant crop! They argue that they are not recommending it to be
used as a HT crop, as though farmers are going to wait for such
recommendations, if they see a “convenience factor” in using a chemical instead
of employing women for removal of crop weeds. To that extent, all testing so
far for environmental and health safety impacts automatically stand null and
void, since the use of herbicides will certainly leave its own environmental
and health effects, apart from serious socio-economic impacts. The Total Investment & Insurance
Solutions
Importantly, several environmental safety
tests were done by the crop developers themselves. For all tests, protocols
were developed by the crop developers, as admitted in response to an
application filed under the Right to Information (RTI) Act. This then means
that convenient protocols will be adopted and not necessarily the most rigorous
ones that assess risks. The Total
Investment & Insurance Solutions
After the crop developers did deceptive and
misleading tests to use convenient study protocols and come up with favourable
results, and after they submitted their application with a biosafety dossier
seeking permission for commercial cultivation, the regulators took over to
continue the farcical processes in the name of risk appraisal. A sub-committee
was set up in the month of January 2016 with seven members of the GEAC. At
least four of these seven members hold objectionable conflict of interest and
should not have been placed in the sub-committee at all. This sub-committee ran
hasty processes for reasons best known to itself. Most importantly, there was
no independent health safety expert and the one person named as a health expert
(who has industry connections) did not actually participate in the
sub-committee or Genetic Engineering Appraisal Committee (GEAC) meetings as per
RTI information obtained. This then means that without any independent health
safety expertise appraising the GM mustard dossier, health safety clearance has
been given to this transgenic food crop!
The GEAC invited a team of eight experts to
share their views in a specially convened meeting of the Committee on 18 July
2016. However it chose to ignore all the points that they raised by summing up
their presentations in a shoddily and incorrectly documented one-pager. More
importantly, it was only later that it came to light that the sub-committee had
already completed its processes of appraisal in its second meeting in April
2016! The Total Investment &
Insurance Solutions
As though this was not enough, a document
called the Assessment of Food/ Feed and Environmental Safety (AFES) of GM
mustard was put up by GEAC on its website on 5 September 2016 inviting public comments
on the same for a month, till 5 October 2016. In its notice inviting public
comments, GEAC stated that any citizen interested in reviewing the full
biosafety dossier may come all the way to Delhi, to the GEAC secretariat and by
prior appointment, to look at the dossier.
Please note that even if you had travelled to
Delhi from Kanyakumari or Kolkata, the regulators expect you to memorise the
4,000 page document and do mental analysis and give your feedback but would not
allow you to take photocopies or photographs of the material put in front of
you. The regulators refused to publish the biosafety dossier on their website,
as they did with BT brinjal and BT cotton, despite earlier orders from the
Supreme Court and Central Information Commission (CIC) and more recent CIC
orders on the subject. The Total
Investment & Insurance Solutions
All this makes you wonder what is it that the
regulators are hiding from public gaze and why?
Why
do we stress on rigorous, open and participatory processes?
There are at least three reasons why the regulators
have to run fool proof appraisal processes. One, the regulatory body does not
have all the areas of expertise required for decision-making on the subject and
fulfilment of their mandate. They will therefore have to fall back on such
expertise that exists in the public. Two, the regulatory body has objectionable
conflict of interest as has been shown time and again. Therefore, their
appraisals are not trust-worthy and cannot be considered independent objective
processes. And lastly, no independent biosafety testing takes place in India.
In such a case, at least independent analysis and scrutiny is the only way to
arrive at robust decisions. The Total
Investment & Insurance Solutions
It is important to note that the very science
and technology of genetically modified organisms (GMOs) is imprecise and
unpredictable enough, that GMOs can be passed off as safe only by compromising
on scientific rigour, by scientific subterfuge. And that is what is happening
with GM mustard too, as has been seen with Bt brinjal. It is therefore
important to make sure that hasty, lax and opaque processes are not run by our
regulators for their decision-making. It is important to ensure that
independent science is able to catch lack of safety inherent in the technology.
This is not being allowed to happen right now.The Total Investment & Insurance Solutions
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