Moneylife: Pune: Saturday,
November 19, 2016.
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.
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.
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!
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.
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.
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.